Animal Rights Research – ABC
Rules
Prof said to focus on the implementation issue and keep it a more
empirical study in its nature
Navigating the streets Examining the legal
and policy dimensions of free-ranging dog
management in India – by Gautam Aredath
& Abi T. Vanak.
judicial interventions have read in a right to feed free-ranging dogs
and a right of dogs to be fed (Maya D. Chablani v. Radha Mittal &
Others 2021 - “Community dogs/stray/street dogs have the right to
food and citizens have the right to feed community dogs but in
exercising this right, care and caution should be taken to ensure
that it does not impinge upon the rights of others or cause any
harm, hinderance, harassment and nuisance to other individuals or
members of the society.’), and the union government has brought in
legislative changes (i.e., Animal Birth Control Rules, 2023) that
promote the maintenance of dogs in public places without individual
ownership.
Under the Constitution, the state has a nonjusticiable obligation to
protect and improve the environment and to safeguard the forests
and wildlife of the country (The Constitution of India 1950a), and
citizens have a duty to protect and improve the natural environment
and to have compassion for living creatures (The Constitution of
India 1950b). The Prevention of Cruelty to Animals Act (PCA) is a
“welfare legislation”7 that prevents the infliction of unnecessary
pain or suffering on animals and penalises animal cruelty. However,
it recognises that the protection afforded to animals is subject to
exceptions that are necessary to protect human interests. The
question of what constitutes ‘unnecessary’ cruelty under the PCA
was discussed in the Parliament, but it acknowledged that practices
that are part of the society’s economic, religious, and scientific
pursuits may involve the use of force and violence against animals
which it may deem acceptable (Lok Sabha Secretariat, 1960).
The operational provisions for dog population management were
issued by the union government through delegation legislation
under the PCA, first, through the Animal Birth Control (Dogs) Rules,
2001 and was subsequently modified through the Animal Birth
Control Rules, 2023 (ABC Rules). Instead of the term ‘stray dogs’
used in the PCA, the rules use the term ‘street dogs’ (and
‘community animals’ in the 2023 rules, the implications of which are
discussed later). While the analysis in this part is based on the
provisions of the 2023 Rules, as it currently applies, these are
largely consistent with its predecessor (notably, many of the
ongoing legal disputes relate to the 2001 rules). Local authorities,
such as municipalities and district panchayats, are
responsible for the conduct of ABC programs, which may be
done directly, or through animal welfare organisations recognised by
the AWBI. The 2023 Rules introduce the requirement of a
certificate of project recognition for the proposed ABC
centre from the AWBI before commencing operations. The local
authorities are responsible for ensuring necessary facilities in the
ABC centres such as sufficient number of kennels, vans for
transportation, incinerators and for the maintenance of records of
their ABC operations. The 2023 Rules also introduce a
monitoring mechanism consisting of monitoring committees
at the local, state and national levels and contain more stringent
conditions regarding record keeping and reporting. The
responsibility for conducting ABC rests with the owner in the case of
pet dogs, and with the local authorities in the case of other dogs.
ABC shall be conducted for the ‘general purpose’ of controlling the
excess population of street dogs, and on ‘specific complaints’ about
dog bites from suspected rabid dogs. Before capturing the dogs in
the manner prescribed by the rules, the implementing agency is
required to provide a public notice to the residents of that area
regarding the capture, and that the dogs will be released in the
same area after the procedures. The dogs are to be identified with a
numbered collar upon their arrival at the ABC centre, to ensure that
they are released in the same area where it was captured. In the
case of complaints regarding dog bites or rabid dogs, such animals
shall be captured and kept for observation at the ABC centre. If such
a dog is found not to have rabies, but has some other diseases or is
furious in nature, it is to be handed over to an animal welfare
organisation, for curing and releasing the dog after 10 days of
observation. Euthanasia is permitted only for incurably ill and
mortally wounded dogs, except that suspected rabid dogs are to be
allowed a natural death. Pursuant to a change introduced in the
2023 Rules, the local authority may establish an animal helpline,
and complaints received on this helpline shall be recorded in a
permanent register. Another key change in the 2023 Rules is the
introduction of provisions relating to the feeding of community
animals. Community animals are defined as any animal born in a
community for which no ownership has been claimed by any
individual or an organisation, excluding wild animals. Resident
welfare associations, apartment owners’ associations, and local
body representatives of an area are made responsible to make
necessary arrangements for the feeding of community animals
residing in the area, including the designation of feeding spots,
feeding time, and feeders. Individuals residing in the area or
premises may be involved in this activity. The community or local
body is responsible to ensure that the relevant arrangements are
mutually agreed, in a manner that minimises interference with play
areas, entry/exit points, and other places likely to be frequented by
children and senior citizens. The Rules contemplate an ad-hoc
animal welfare committee being set up at a micro-level (i.e.,
including the complainant and the representative of the concerned
community or local body) to decide on any conflict arising from
feeding activities. Any aggrieved party (except the complainant, as
per rule 20(3) of the 2023 Rules) may appeal the decision before the
state animal welfare board. Finally, the Rules exclude the application
of any other acts, rules, regulations or bye-laws that are in force in
the state or the local areas in respect of “any of the matters for
which provision is made in these rules”, to the extent the former
“contains provisions more irksome to the animal than those
contained in these rules”.
The effectiveness of ABC is crucially reliant on the coverage that can
be attained within a short time frame. However, the local
authorities that are primarily responsible for its
implementation have meagre or no budgetary allocations for
this purpose, and are riddled with weak capacity (Sudhi 2022;
Timsina 2019; Chakraborty 2023). The financial resources allocated
by Indian cities for ABC is typically half of the requirement
calculated for highly conservative modelling scenarios (Belsare &
Vanak 2020). In the context of the 2001 Rules, the AWBI has
submitted to the Supreme Court that “in most states
[implementation] has been … inadequate, haphazard and
poorly planned” and that “the shortage of resources has
also led to huge cruelties being inflicted on the animals, and
in increased conflict” (AWBI v. PEST & Others 2016). The grants-
in-aid received by AWBI from the union government for the
ABC program reduced from Rs. 41.17 lakh in 2015-16 to Rs.
7.35 lakh in 2019-20; of the latter, only Rs. 2.93 lakh was
utilised by AWBI. India’s local governments have notoriously weak
capacity to raise their own sources of revenue, and remain heavily
dependent on grants from Union and State governments to perform
their functions (National Council of Applied Economic Research
2022, 57). The failure to address the inadequacy of human,
physical and financial resources that are required to
implement ABC at scale in the legal and policy framework
continues to impede ABC programs, despite increased focus
in the 2023 Rules to some aspects of implementation (such
as the registration of implementing agencies and the
inclusion of monitoring mechanisms). Tellingly, there are
only 17 animal welfare organisations in the whole country
that have been granted permission by AWBI to implement
the ABC program as of July 2022 (Government of India 2022).
Animal Birth Control Rules Implementation in India: An Empirical
Analysis of Policy Failures and Administrative Incompetence
Executive Summary
The Animal Birth Control (ABC) Rules, despite being in place since 2001
and revised in 2023, have fundamentally failed to achieve their primary
objective of managing India's street dog population through sterilization
and vaccination programs. This empirical study reveals systematic
implementation failures, chronic underfunding, and administrative
incompetence that have rendered the ABC framework largely ineffective
across India, with Delhi serving as a particularly stark example of
institutional breakdown.
1. Introduction
India's approach to street dog population management through the
Animal Birth Control program represents one of the most significant policy
implementation failures in contemporary animal welfare legislation. The
2023 Rules, superseding the 2001 framework, were designed to create a
comprehensive three-tier monitoring system and standardized
implementation protocols. However, empirical evidence demonstrates
that these regulatory improvements have failed to address fundamental
structural deficiencies that have plagued the program for over two
[Link]+1
The magnitude of the challenge is staggering: India houses between 62-
80 million street dogs according to various estimates, with the State of Pet
Homelessness Index 2020 ranking India last among nine countries with a
score of 2.4. The ABC program's core premise—that systematic
sterilization and vaccination can control populations while maintaining
dogs in their territories—requires achieving sterilization coverage of at
least 70% of the population to be effective. This threshold has never been
achieved at scale across India, rendering the entire approach scientifically
and practically [Link]+1
2. Legal and Policy Framework
2.1 Evolution from ABC Rules 2001 to 2023
The Animal Birth Control (Dogs) Rules 2001 first established the legal
framework for systematic street dog population management, mandating
capture, sterilization, vaccination, and release protocols. The 2023 Rules
introduced several key modifications: mandatory project recognition
certificates from the Animal Welfare Board of India (AWBI), establishment
of monitoring committees at local, state, and national levels, and
provisions for community feeding [Link]+1
The 2023 Rules also expanded the scope from "street dogs" to
"community animals," introducing feeding provisions that require resident
welfare associations and local bodies to arrange designated feeding spots
and times. This shift reflects judicial interventions that have increasingly
recognized dogs' right to food and citizens' right to feed [Link]
2.2 Judicial Interventions and Right to Feed Dogs
The Delhi High Court's landmark judgment in Maya D. Chablani v. Radha
Mittal & Others (2021) established that "community dogs/stray/street
dogs have the right to food and citizens have the right to feed community
dogs but in exercising this right, care and caution should be taken to
ensure that it does not impinge upon the rights of others". This judicial
recognition has been incorporated into the 2023 Rules, creating complex
implementation challenges around designated feeding areas and
community [Link]+2
2.3 Constitutional Framework and Implementation
Responsibilities
Under Article 243W of the Constitution, local bodies are mandated to
control stray dog populations, while Article 246(3) places animal welfare
under state government jurisdiction. This division of responsibilities has
created coordination challenges, with local authorities lacking adequate
resources while state governments maintain oversight responsibilities. The
Prevention of Cruelty to Animals Act provides the overarching legislative
framework, but its implementation through ABC Rules has consistently
fallen short of intended [Link]+1
3. Empirical Analysis of Implementation Challenges
3.1 Financial Resource Allocation and Budgetary Constraints
The most damning evidence of ABC program failure lies in funding data.
According to Lok Sabha records, the Centre allocated zero funds to any
state for ABC programs from 2021-22 to 2024-25, after providing only
₹4,03,981 in 2020-21. This represents a complete abdication of central
responsibility for a program mandated by central [Link]
The financial requirements for effective ABC implementation are massive.
Delhi alone would require approximately ₹1,000 crore annually just for
feeding costs at ₹40 per dog per day for an estimated one million dogs.
Infrastructure development for permanent sheltering has been estimated
at ₹15,000 crore nationally, highlighting the scale of investment
[Link]
Local authorities demonstrate consistently inadequate budget allocations.
Delhi's Municipal Corporation allocated only 0.64% of its ₹17,002.66 crore
budget to veterinary services in recent years, far below requirements for
effective ABC implementation. This chronic underfunding has resulted in
delayed payments to NGOs, with many organizations forced to discontinue
services due to unpaid [Link]+1
3.2 Institutional Capacity and Coordination Failures
RTI data reveals shocking deficiencies in program implementation. In
Nagpur, RTI findings confirmed that the ABC program receives no funding
from AWBI or State Welfare Boards, with all expenses met locally. Similar
patterns emerge across India, with only 17 animal welfare organizations
nationally holding AWBI recognition to implement ABC programs as of July
[Link]+1
The monitoring mechanisms established under the 2023 Rules remain
largely non-functional. Most states have failed to constitute required local
ABC monitoring committees, and where they exist, they lack capacity for
effective oversight. Delhi's ABC centers frequently violate basic
operational requirements, with multiple independent inspections
documenting locked facilities, overcrowding, unsanitary conditions, and
poor [Link]+2
3.3 Coverage Thresholds and Effectiveness Metrics
Scientific literature consistently demonstrates that ABC programs require
sterilization coverage of 70-80% of the target population within short
timeframes to be effective. However, empirical data shows coverage rates
far below these thresholds across India. Bangalore's 2023 census found
only 71.81% of dogs neutered on average, with significant variation
between zones. Goa achieved 65.8% coverage in the highest-performing
intervention site, still below optimal [Link]+2
National data shows mixed results at best. While the overall street dog
population declined from 1.71 crore in 2012 to 1.53 crore in 2019, this
represents only an 11% reduction over seven years. Seventeen states
actually experienced population increases, indicating that ABC programs
in these regions are completely [Link]
4. Case Study: Delhi's ABC Program Implementation
4.1 MCD's ABC Centers and Infrastructure Analysis
Delhi operates 20 ABC centers through partnerships with NGOs, but only
13 are reportedly functional. These centers lack basic infrastructure
required under ABC Rules, including mandatory CCTV cameras in
operation theaters and isolation wards for suspected rabid dogs. The
combined capacity of all centers can accommodate approximately 2,500-
4,000 dogs simultaneously, grossly inadequate for a city with an
estimated one million street [Link]+2
Independent inspections reveal systematic violations of operational
standards. Centers frequently operate without proper project recognition
certificates, lack trained veterinary staff, and maintain inadequate records
of sterilization activities. Many facilities are locked during official working
hours or operate with skeleton staff, making effective implementation
[Link]
4.2 Sterilization Data and Coverage Statistics
MCD claims to have sterilized seven lakh dogs over seven years, yet
Delhi's street dog population continues growing. This discrepancy
suggests either massive data falsification or complete program
ineffectiveness. Expert analysis indicates that if MCD's figures were
accurate, Delhi should have achieved complete population sterilization
given the claimed coverage [Link]
Actual sterilization throughput shows some improvement post-2014, with
yearly outputs peaking near 1,00,000 pre-pandemic, but this remains
insufficient for city-wide coverage. The total reported sterilizations of
~5.75 lakh dogs between 2014-2023, costing ₹55+ crore, represents poor
value for money given persistent population [Link]
4.3 Financial Expenditure vs. Outcomes
Delhi's ABC spending reveals significant inefficiencies and potential
corruption. With allocated budgets consistently underspent or misdirected,
the gap between claimed sterilizations and actual population control
suggests systematic financial mismanagement. NGOs report delays in
receiving payments for sterilization services, forcing many to discontinue
operations or reduce [Link]
The cost per sterilization has risen substantially while outcomes remain
poor. Current rates of ₹1,000 per dog for sterilization and post-operative
care compare unfavorably with international benchmarks, yet fail to
achieve population control [Link]
5. Recent Supreme Court Intervention (2025)
5.1 Background of the Delhi Stray Dog Case
The Supreme Court's suo motu intervention in August 2025 followed
escalating public concern over dog bite incidents. With over 37 lakh dog
bite cases nationally in 2024 and 54 suspected rabies deaths, the court
took cognizance of what it characterized as administrative failure. Delhi
recorded 25,201 dog bite cases in the first half of 2025 alone, highlighting
the scale of human-animal [Link]+1youtube
5.2 Court Orders and Legal Controversies
On August 11, 2025, a two-judge bench ordered complete removal of
stray dogs from Delhi-NCR to shelters, prohibiting their release back to
streets. The order, calling ABC Rules "absurd," directly contradicted
established legal frameworks and previous Supreme Court precedents
affirming ABC implementation. The controversial directive sparked
nationwide protests and was subsequently referred to a larger bench for
[Link]+2
The court's intervention highlighted fundamental questions about the rule
of law. By dismissing established legislation and scientific evidence, the
bench effectively rewarded administrative incompetence while punishing
innocent animals for human institutional failures. This represents a
troubling precedent of judicial overreach circumventing legislative
[Link]
5.3 Administrative Incompetence and Rewarding Failure
The Supreme Court proceedings exposed systematic failures by Delhi's
Municipal Corporation. Justice Vikram Nath explicitly stated: "What is your
stand? This is happening because of the inaction of the Municipal
Corporation. The Government does nothing. The local authorities do
nothing". Rather than holding authorities accountable for decades of non-
compliance with ABC Rules, the court sanctioned an illegal alternative that
punishes animals for human administrative [Link]
The MCD's documented failures include: engaging ABC agencies without
mandatory project recognition certificates, failing to constitute required
monitoring committees, absence of progress reports under Rule 13, and
inadequate CCTV monitoring at ABC centers. These violations constitute
systematic contempt of existing legal orders, yet no administrative
officials face [Link]
6. Comparative Analysis and Best Practices
6.1 Successful ABC Programs in Other States
Limited success stories demonstrate that effective ABC implementation is
possible with adequate resources and commitment. Tamil Nadu achieved
significant population decline from 6,47,798 dogs in 2012 to 4,41,208 in
2019. Goa's integrated One Health program eliminated human rabies
deaths from 17 in 2014 to zero in 2018-2019 through comprehensive
vaccination and sterilization [Link]+1
6.2 International Models and One Health Approach
The One Health approach, integrating human health, animal welfare, and
environmental considerations, has proven cost-effective internationally.
Goa's program achieved elimination at $526 per DALY averted, well below
WHO cost-effectiveness thresholds. Mathematical modeling demonstrates
that vaccinating as few as 7% of dogs annually could reduce human rabies
deaths by 70% within five [Link]+2
6.3 Cost-Effectiveness Studies
Comparative economic analysis shows that focused vaccination programs
are more cost-effective than combined sterilization-vaccination
approaches. However, these findings assume functional implementation
systems, which are largely absent across India. The efficiency gains from
optimal program design are negated by implementation failures and
institutional [Link]
7. Empirical Evidence and Data Analysis
7.1 National Street Dog Population Census Data
The 20th Livestock Census (2019) provides the most recent
comprehensive data, showing 15.3 million street dogs nationally, down
from 17.1 million in 2012. However, this aggregate decline masks
significant regional variations, with 17 states experiencing population
increases. States with established ABC frameworks show better outcomes:
Tamil Nadu, Sikkim, and West Bengal achieved substantial
[Link]+2
7.2 Dog Bite Statistics and Public Health Impact
Dog bite incidence remains alarmingly high despite ABC programs. India
reported 37.15 lakh dog bite cases in 2024, with Delhi accounting for
25,201 cases in six months. The WHO estimates 18,000-20,000 annual
rabies deaths in India, representing 36% of global deaths. These statistics
demonstrate the complete failure of ABC programs to achieve their
primary public health [Link]+2
7.3 ABC Program Success Rates Across States
State-wise analysis reveals dramatic disparities in program effectiveness.
Bangalore's street dog population declined 10% from 3.1 lakh in 2019 to
2.9 lakh in 2023, with 71.81% average sterilization coverage. In contrast,
Mumbai experienced a 72% increase to 1.64 lakh dogs from 95,000 in
2014. These variations reflect differential resource allocation and
implementation capacity rather than program design
[Link]+1
8. Recommendations and Policy Implications
Evidence-based policy reform requires fundamental restructuring of India's
approach to street dog management. First, the Centre must assume direct
financial responsibility for ABC implementation, allocating sufficient funds
based on scientific coverage requirements rather than symbolic budget
lines. Second, specialized animal welfare courts should be established to
ensure swift accountability for implementation failures. Third, the
institutional framework requires centralization under a unified
enforcement mechanism to eliminate coordination failures between
multiple [Link]+2
The 70% sterilization threshold should be legally mandated with time-
bound targets, supported by adequate infrastructure development.
Community engagement programs must be strengthened, integrating
traditional practices with animal welfare principles through dialogue with
cultural leaders. Finally, comprehensive monitoring systems with real-time
data collection should replace the current ad-hoc reporting mechanisms
that enable data manipulation and [Link]+2
9. Conclusion
The Animal Birth Control Rules represent a comprehensive policy failure
that spans over two decades of implementation. Despite scientific
evidence supporting sterilization-based population control and clear legal
frameworks mandating systematic implementation, India's ABC program
has failed catastrophically due to chronic underfunding, institutional
incompetence, and administrative corruption.
The recent Supreme Court intervention, while highlighting legitimate
public safety concerns, demonstrates how judicial frustration with
administrative failure can lead to unconstitutional solutions that violate
established legal frameworks. Rather than holding local authorities
accountable for systematic non-compliance with ABC Rules, the court's
order rewards incompetence while punishing innocent animals.
Future research should focus on developing implementation models that
account for India's institutional constraints while maintaining scientific
rigor in population management approaches. The fundamental challenge
remains political: creating accountability mechanisms that ensure
adequate resource allocation and competent implementation rather than
continued policy experimentation without institutional reform.
The ABC Rules framework, if properly implemented with adequate
resources and institutional capacity, could achieve its intended objectives.
However, the empirical evidence overwhelmingly demonstrates that India
lacks the political will and administrative competence necessary for
effective implementation. Until these fundamental issues are addressed,
any regulatory framework—regardless of its scientific merit—will continue
failing, leaving both human and animal populations to suffer the
consequences of institutional [Link]+2
Source Files for Citation Management
term_paper_sections.csv
Generated File
term_paper_sources.csv
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Word Count: Approximately 2,500 words
Note: This term paper provides a comprehensive empirical analysis
focusing on implementation challenges as requested by your professor.
The extensive source base (54 references) includes government data,
court cases, academic research, and expert analysis to support the
empirical nature of the study. The recent Supreme Court case is analyzed
as a key example of how implementation failures lead to problematic
judicial interventions. Each section is structured to build the argument
that ABC Rules fail not due to design flaws but due to systematic
implementation incompetence and institutional breakdown.
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