The state is constitutionally obligated to protect citizens from preventable hazards caused by stray animals in public and institutional spaces. Administrative failure to implement safety protocols and manage animal populations in high-congregation areas violates the right to life, necessitating strict adherence to established regulatory and sterilization frameworks.

Headnote:(A) Constitution of India - Article 21 - Prevention of Cruelty to Animals Act, 1960 - Animal Birth Control Rules, 2023 - Public safety - Stray animals on highways and in institutional areas - Right to life and safety extended to protection against preventable hazards in public spaces - Administrative apathy in implementing statutory mandates violates constitutional guarantees - Authorities must implement robust mechanisms for removal and relocation of stray animals - Accountability of administrative heads in ensuring safe environments. (Paras 9, 13, 24, 26)

(B) Administrative Accountability - Duty of authorities - Authorities including municipal bodies, transport departments, and highway authorities mandated to maintain public order and safety by preventing stray animals from obstructing highways and public institutions - Accountability for lapses and systemic failure identified by judicial review. (Paras 10, 25)

Facts of the case:
The proceedings originated from concerns regarding the increasing menace of stray animals on public highways and within institutional premises, including educational, medical, and transport facilities. Despite existing statutory frameworks, frequent reports of injuries and risks to human safety highlighted a systemic failure in administrative oversight and local enforcement.

Findings of Court:
The Court determined that the persistence of hazards caused by uncontrolled animal movement in public and institutional spaces infringes upon the fundamental right to life. It found the current implementation of animal control regulations to be inadequate and directed the adoption of uniform, mandatory preventive measures, including regular patrols, structural securing of premises, and fixed accountability for designated officials.

Issues: Whether the failure of administrative agencies to manage stray animals on highways and within sensitive public institutional areas violates the right to life under the Constitution, and what remedial directions are necessary to ensure uniform public safety?

Ratio Decidendi: The State and its instrumentalities bear an affirmative, constitutional obligation to protect citizens from preventable hazards within public premises. Where administrative inaction compromises public safety and health, judicial intervention is warranted to enforce existing regulatory frameworks and mandate strict compliance through institutional accountability and monitoring.

Result: Directions issued for nationwide compliance; authorities directed to file periodic compliance affidavits.

Table of Content
1. procedural status of compliance with previous judicial mandates. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7)
2. mandatory removal of stray cattle and animals from public highways. (Para 8 , 9 , 10 , 11)
3. state obligation to secure institutional spaces against stray animal threats. (Para 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24)
4. directive framework for institutional safety and stray dog management. (Para 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33)

1. This Court, vide order dated 22nd August, 2025, after considering the submissions made on behalf of the parties and the material placed on record, had supplemented, modified, and clarified the earlier directions issued vide order dated 11th August, 2025.

2. The directions contained in the order dated 22nd August, 2025, inter alia, mandated the municipal authorities to continue the exercise of capturing, sterilising, deworming, and vaccinating stray dogs in accordance with the Animal Birth Control Rules, 2023, while permitting the release of sterilised and immunised dogs to the same localities from which they were picked up, except those infected with or suspected to be infected with rabies and those exhibiting aggressive behaviour. The Court further directed the creation of designated feeding zones for stray dogs, establishment of municipal helplines for reporting violations, and the filing of comprehensive compliance affidavits by the respective municipal authorities.

3. The aforesaid directions were extended to all States and Union Territories, and the Registry was directed to seek information from the Registrar Generals of the High Courts with respect to similar matters pending before them, so that a uniform and coherent approach to the menace of stray dogs could be evolved across the country.

4. The present order shall address three distinct issues, which are being dealt with in separate parts for clarity and convenience. Part I pertains to the compliance affidavits filed by the States and Union Territories pursuant to this Court’s earlier directions and the summary report prepared by the learned Amicus Curiae, Shri Gaurav Agrawal. Part II concerns the modification, application and implementation of the directions issued by the High Court of Judicature for Rajasthan at Jodhpur in D.B. Civil Writ Petition No. 14726 of 2025. Part III concerns the issuance of further directions in respect of institutional areas, including educational establishments, hospitals, sports complexes, and other public spaces such as railway stations and bus depots, where incidents of dog-bite attacks continue to be reported with alarming frequency, raising a cause of grave concern and requiring emergent remedial measures.

PART I: Compliance Affidavits filed by States and UTs and Summary prepared by Amicus Curiae

5. Pursuant to the direction contained in paragraph 33(i) of the order dated 22nd August, 2025 and the subsequent order dated 27th October, 2025, all States and all Union Territories, except the Union Territory of Dadra and Nagar Haveli and Daman & Diu, have submitted their respective compliance affidavits before this Court. The learned amicus curiae, Shri Gaurav Agrawal, has been requested vide order dated 3rd November, 2025, to examine the said affidavits and to place before this Court a concise summary of the affidavits filed by the States and Union Territories in purported compliance with the directions issued by this Court.

6. In compliance of the order dated 3rd November, 2025, the learned amicus curiae, Shri Gaurav Agrawal, has made a herculean effort and has filed a report summarising the compliance affidavits submitted by the respective States and Union Territories. The report highlights several grave deficiencies and shortcomings in the information furnished by certain States and Union Territories, as well as areas where compliance with the directions issued by this Court has either not been effected or remains incomplete. The learned

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