Aug 19, 2025 Man Bites Dog: Indian Supreme Court Conundrum

In the United States, it is well known that proposing a law change about pet dogs, such as increasing the license fee, can spark a heated debate at a local council meeting. The Indian Supreme Court now recognizes that such a proposal also generates national uproar.

On Monday, August 11, 2025, a two-member bench of the Indian Supreme Court (which currently has thirty-two justices) ruled that all stray dogs in New Delhi must be rounded up and housed in shelters. According to a report in the Hindustan Times, the court’s decision was prompted by the death of a six-year-old girl from rabies after she was bitten by a stray dog while walking to her aunt’s house. The court emphasized the increase in dog bite cases in New Delhi and their impact on children and senior citizens in its order. The bench made a “suo motu” decision, meaning it was made on its initiative without any request to the court. However, this decision went against previous rulings by the Indian Supreme Court regarding managing street dogs in India. It was also described by Arya Suresh, an advocate at the Indian Supreme Court, as “misguided and legally problematic.” She also expressed concern over the “exclusion of expert voices” and findings. Suresh referenced two academic papers—one on a street dog management project in Jodhpur[i] and another on the economics of managing street dogs in Tamil Nadu[ii].

However, she could have referenced a much more persuasive case for street dog management stemming from a sterilization project launched by the Indian NGO Help in Suffering in 1994, which is still ongoing. The impact of that project has been well documented over the past thirty years. The findings show that the systematic implementation of an ABC initiative has led to a halving of the street dog population in Jaipur, eliminating human rabies cases in the city (with cases outside the program’s area remaining unchanged), and a two-thirds reduction in dog bite rates. A study of the project’s economic impact revealed that the $659,000 invested by the animal NGO over the 30 years of the ABC initiative saved the municipality and its residents $38 million—a cost-benefit ratio of fifty-eight[iii].

Jaipur is not the only municipality in India that has benefited from the work of animal NGOs. A survey of street dogs in Mumbai fifteen years ago found that about 70% had already been sterilized by the non-profit organizations working in the city. Dr. S. Chinny Krishna reported that the number of human rabies cases in Chennai dropped from around 120 annually to zero in recent years when the municipality ended dog culling and began supporting ABC in 1994.

It is also worth noting that Dr. Krishna was the first to propose the ABC approach in Chennai in the late 1960s. ABC or variants of ABC have since become the international standard for managing street dogs. ABC, which stands for Catch, Neuter, Vaccinate, and Return (CNVR), has been used in Kabul, Mauritius, Central and South America, and many other locations worldwide. The Taliban were so impressed by the success of the Kabul project that they asked Mayhew Afghanistan, the British NGO that manages the dog program, to continue its work shortly after they took control of the government in Afghanistan in 2021.

The debate over what to do about street dogs in India is fueled by passion and a shortage of facts. No one knows the exact number of street dogs in India. A newspaper discussing the current uproar in India claimed that there are around 15 million street dogs. However, a survey of the dog population in Haryana, a state with a population of just twenty-five million, reported 2.5 million dogs in the state. Extrapolating this estimate to India suggests there could be about 140 million street dogs in the country.

Reports on the number of dog bite incidents and human rabies cases in India are also highly unreliable. In 2007, Dr. Sudarshan of Bangalore and his colleagues, after a thorough and careful study, reported an estimated 20,000 human rabies cases annually in India[iv]. Recent data[v] indicate that this figure may have decreased by as much as 75% since then. Thanks to animal NGOs, we know that the incidence of rabies in Jaipur, Chennai, and other urban areas has declined following the successful implementation of ABC. Dog bite rates are also expected to decrease because of reduced breeding behavior and fewer puppies needing protection. However, dog bites will never be wholly eradicated. Dogs are predators that defend themselves and their territories with their teeth. Nonetheless, dog bite rates can and should be lowered. In countries with well-managed dog populations, annual dog bite rates are typically less than 100 bites per 100,000 people (0.1%), whereas some cities in India report over 1,000 dog bites per 100,000 people (1%) each year.

The Indian Supreme Court needs to regain its footing. Reviewing its previous findings and decisions on animal issues, considering expert opinions, and recognizing India’s unique position as a nation influenced by ahimsa would be a good starting point. It should also be noted that any human death from rabies today signifies a failure not only of dog management but also of the national health system. India only designated rabies as a notifiable disease in 2021 and has just begun implementing healthcare measures that adequately address the rabies threat. South America began implementing a dog vaccination program in 1983 to eliminate human rabies. Since then, it has recorded a 95% reduction in human rabies cases and a 98% reduction in dog rabies cases. The continent achieved these results through large-scale dog vaccination, improved access to pre- and post-exposure rabies prophylaxis, better vaccines, and enhanced surveillance and diagnosis. India has more than enough skilled professionals to implement such a program, and over 2,000 animal NGOs are already involved in humane street dog management.

India stands at a pivotal moment in its approach to humane street dog management and rabies control. With the collective support of the national government, municipalities, NGOs, and community stakeholders, there is an unprecedented opportunity to transform public health and animal welfare outcomes across the country. India can implement evidence-based, scalable, and compassionate solutions by advancing Animal Birth Control (ABC), supported by innovative dog population estimations and a centralized knowledge repository documenting the successful ABC projects in Jaipur, Chennai, Lucknow, Bangalore, Rajkot and other cities, as well as in the states of Uttarakhand and Sikkim.

[i] SC Totton et al (2010) Stray dog population demographics in Jodhpur, India following a population control/rabies vaccination program. Prev. Vet. Med. 97(1):51-57. Accessed on August 18, 2025, from https://www.sciencedirect.com/science/article/abs/pii/S0167587710002084.

[ii] MC Fitzpatrick et al (2016). One Health approach to cost-effective rabies control in India. Proc. Nat. Acad.. Sci. 113(51):14574-14581). Accessed on August 18, 2025, from https://www.pnas.org/doi/full/10.1073/pnas.1604975113.

[iii] AJ Larkins et al (2020) An economic case study of the control of dog-mediated rabies by an animal welfare organization in Jaipur, India. Prev. Vet. Med. 183: 105120. Accessed on August 18, 2025, from https://www.sciencedirect.com/science/article/abs/pii/S0167587720300374.

[iv] Sudarshan et al (2007) Assessing the burden of human rabies in India: Results of a national multi-center epidemiological survey. Intl J. Infect. Dis. 11(1):29-35. Accessed on August 18, 2025, from https://www.sciencedirect.com/science/article/pii/S1201971206000117.

[v] JWV Thangaraj et al (2025) Estimates of the burden of human rabies deaths and animal bites in India, 2022-2023: a community-based cross-sectional survey and probability decision-tree modelling study. The Lancet Infectious Diseases 25(1):126-134. Accessed on August 18, 2025, from https://www.thelancet.com/journals/laninf/article/PIIS1473-3099(24)00490-0/abstract.