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Strays in the crossfire: The country’s dog dilemma

From rabies fears to stalled neutering programmes, India struggles to tame its stray dog population

Paran Balakrishnan
Published 23.11.25, 05:45 PM

How many stray or community dogs are there in India? In 2014 an international researcher reckoned there might be about 50 million. Animal welfare experts are convinced there could be around 100 million or even upto 150 million.

Even animal lovers agree this is far too many.

But they've come out onto the street to protest Supreme Court rulings which ordered that many should be put into shelters. Says Supreme Court lawyer Namita Sharma who's on the frontlines of the battle for the animals: “Unless the court and the government commit to real sterilisation, nothing will change,” warns Sharma.

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Students pet a dog during a protest march at Delhi University North Campus (PTI)

The courts themselves have become a welter of contradictions. In the Supreme Court, three sets of judges have handed down differing orders – even though the law is already clear.

The Animal Birth Control (ABC) Rules enacted in 2023 mandate that stray dogs be sterilised, vaccinated, and returned to the place they were found. Justices J. K. Maheshwari and Sanjay Karol stressed this in 2024: “Under all the circumstances, there cannot be any indiscriminate killing of canines and the authorities have to take action in terms of the mandate and spirit of the prevalent legislation in place.”

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A child holds a placard as she stands beside a stray dog during a protest organised by the People for Animals (PFA) Abhaya in solidarity with the dogs, in Hyderabad (PTI)
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With the law in place, it should have ended there. But a year later, in August, the system was thrown into chaos. Justices J. B. Pardiwala and R. Mahadevan took suo motu (on their own initiative) action after reading a story headlined “City Hounded by Strays, Kids Pay Price.” According to the report, six-year-old Chavi Sharma had died from rabies after multiple bites.

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The apex court last week took note of the "alarming rise" in dog bite incidents in institutional areas (PTI)

Ignoring five groups that tried to intervene, the bench issued an order that shocked animal rights supporters: create shelters for 5,000 dogs within an extremely tight deadline of eight weeks, staffed with trained workers to sterilise, deworm, and vaccinate all animals.

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Animal lovers take part in a candlelight march against the Supreme Court order directing authorities to remove stray dogs from institutional areas, in Prayagraj (PTI)

“It is a violation of the principles of natural justice. How can you pass such a harsh order without hearing us?” says advocate-on-record Sharma, one of the intervenors. “It’s not even about the harshness – you are supposed to hear us before passing any order. They have not heard us at all.”

The order’s most explosive clause: dogs could not return to their original neighbourhoods, directly contradicting the ABC Rules. Delhi alone, with roughly one million street dogs, would need permanent, fully funded facilities. Justice Pardiwala warned activists: “If any individual or any organisation comes in the way of forceful picking up of stray dogs and rounding them up, we shall proceed to take the strictest of actions against any such resistance which may be offered.”

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Animal lovers hold placards during a protest in solidarity with stray dogs, at Jantar Mantar, in New Delhi (PTI)

Protests erupted nationwide. Dog lovers and community caretakers argued they were ignored, that the order was unworkable, and that it flouted the law. Activists, including Sharma, returned to the Supreme Court.

Just 11 days later, India’s stray dogs were back in court, this time before Justice Vikram Nath. He overturned the harshest provisions of Pardiwala’s ruling.

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A volunteer holds a puppy during a protest, in Chennai(PTI)

But the three-judge bench led by Nath threw in a string of extra provisions that had the pro-canine community up in arms again. It ruled that while community dogs should be returned to their original locations after sterilisation, strays picked up in public spaces or near schools should not be returned but placed in “designated shelters” – with “near” undefined.

Dogs around educational institutions, hospitals, sports complexes, bus stations, railway stations and tourist spots must all be captured, sterilised and impounded “to liberate institutional areas” from free-roaming canines, the judges said. While Pardiwala’s ruling applied only to Delhi, Nath’s applies nationwide.

“This is just inhumane. There are no proper shelters or infrastructure to keep these stray dogs … They should get stray dogs vaccinated or sterilised and leave them in their territory. They don’t need to be in cages,” says Sudhir Sachdeva, founder of Stand for Animals.

The court also ordered fixed feeding zones and that “aggressive” dogs should not return to their territories. But “aggressive” remains undefined. Sharma warns this has already been misused:

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“In the name of ‘aggressive’, they picked up many animals.” She filed a contempt petition after seeing "horrendous videos -- I cannot describe the cruelty" from Jodhpur, Jaipur, Madhya Pradesh, and Mumbai.. The court promised to hear her, but did not.

Sharma stresses the ABC Rules already provide a framework for handling stray dogs. “When the law is in place, how can you (the court) set aside that law? You cannot. The law has to be challenged. Till the time the law is challenged before you, you cannot touch it. The legislature has to change it.”

Activists also claim official dog bite and rabies stats are inflated, counting pet dog bites and treating every rabies injection as a separate bite.

The scale of the challenge is staggering. Vets say neutering is the only solution – called Catch, Neuter, Vaccinate, Return (CNVR) – yet in Delhi, Sharma says, only 250 dogs were neutered in a year. Funds often go unspent. “If they are not sterilising or vaccinating, where is all the money going?” she asks.

Some progress exists. Jaipur’s municipal teams, in collaboration with residents and animal welfare groups, run targeted sterilisation drives, vaccinate dogs, and designate feeding areas. Only trained personnel handle animals, and fixed payments are set. This has gradually stabilised street dog numbers without relocations or mass culls.

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Internationally, sterilisation programmes work. Bhutan reports near-total sterilisation of street dogs. Bangkok has sterilised over 400,000, slowing population growth. Similar initiatives in the Philippines and Sri Lanka have reduced dog-human conflicts and rabies, showing humane population control is possible even with limited resources.

“If sterilisation were done regularly, the population would naturally decline over time. Other places have done it — Jaipur, Sikkim, places in Gujarat. Internationally, the Netherlands and Norway have done it,” says Sharma.

Yet in India, inconsistent enforcement, massive stray populations, and contradictory Supreme Court orders have created a perfect storm. The tools exist, but without authority, capacity, and coordination, India risks remaining trapped in a cycle of disputes – and stray dogs on the streets – for years to come. The problem is not impossible, but it comes close.

“Instead of chastising the municipal bodies, which should be implementing the sterilisation and vaccination rules properly, they are going after the poor dogs,” says Ambika Shukla, a trustee of People for Animals.

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