PRAN (Policy Research Action Network) Foundation: Nip It in the Bud: Bombay HC's Push for Aggressive Stray Dog Sterilisation and What It Means for Public Safety

By Adv. Amarjeet Singh, Founder, PRAN – Policy Research Action Network Foundation

The Bombay High Court has directed the Maharashtra government to aggressively implement the Animal Birth Control (ABC) programme, holding that sterilising adult stray dogs at scale — rather than merely managing an ever-growing population — is the only sustainable way to resolve the state's stray dog crisis. The observation came in a suo motu petition the Court initiated to monitor compliance with the Supreme Court's nationwide directive on stray dog management.

Case Details

Field	Value
Matter	Suo motu petition on stray dog management compliance
Court	Bombay High Court
Bench	Acting Chief Justice Ravindra V. Ghuge, Justice Gautam A. Ankhad
Date	Order dated 14 August 2026; adjourned to 11 September 2026
Source	Bar & Bench

The Core Issue

Following the Supreme Court's judgment of 19 May 2025 on nationwide stray dog management, High Courts across India were directed to monitor how state governments implement humane population control measures. Maharashtra's compliance roadmap, presented before the Bombay High Court, centres on the ABC programme — the legally mandated, sterilisation-based method for managing stray populations under the Animal Birth Control Rules, 2023.

The bench's intervention was pointed and practical. Rather than treating the crisis as one of managing an ever-expanding population — vaccinating, feeding, and monitoring more and more dogs each year — the Court asked the state to attack the problem at its root:

Every dog sterilised cannot procreate. Stopping births is what actually halts population growth.
Catching adult dogs, not chasing an expanding number of strays, is administratively more achievable.
The Court cited its own experience at the High Court's Aurangabad campus, where a veterinary sterilisation drive brought the resident stray population down to just 3–4 dogs.

Why This Matters

Stray dog management sits at an uncomfortable intersection of public safety, animal welfare, and civic capacity — and citizens often feel caught in the middle.

For residents, unchecked population growth means more dog bites, more rabies risk, and more fear in public spaces, especially for children and the elderly.
For animal welfare advocates, the law is unambiguous — culling or indiscriminate relocation of strays is not a lawful option; the ABC Rules mandate humane sterilisation and vaccination.
For municipal bodies, an ever-growing population makes feeding, vaccination, and rabies control progressively harder each year, straining already limited veterinary infrastructure.

The Court's logic — sterilise first, and every downstream problem becomes easier to manage — offers a rare point of alignment between these competing concerns.

The Larger Structural Problem

This is not the first time courts have had to nudge municipal bodies toward compliance with the ABC Rules. Across Indian cities, sterilisation targets are routinely missed, veterinary capacity is inadequate, and ABC centres often operate without consistent funding or staffing. The result is a familiar cycle: population grows faster than sterilisation drives can keep pace, complaints of dog bites rise, public pressure mounts for drastic (and often unlawful) measures, and courts are compelled to step in.

But the deeper problem predates poor implementation — it lies in the design of the Animal Birth Control Rules, 2023 themselves. The Rules impose a rigid catch-sterilise-release framework on municipal bodies without matching resources, timelines, or enforcement teeth, while offering local administrations little flexibility to address genuinely dangerous or repeat-biting animals. A framework that is difficult to comply with in practice invites exactly the kind of chronic non-compliance seen across Indian cities today.

Reforming or replacing the Rules is a legislative and policy question that will take time, and PRAN believes that case for reform should be pursued through the proper channels. Until that reform happens, however, the Rules as they stand remain the law, and the only responsible position for citizens, municipal bodies, and courts alike is strict compliance — vigorous, well-funded, accountable sterilisation drives — rather than selective enforcement or ad hoc departures from the framework. The Bombay High Court's suo motu monitoring is valuable precisely because it presses for that strict compliance in the interim, even as the underlying rules deserve closer scrutiny.

Your Rights / What You Can Do

Report unsterilised stray colonies to your local municipal corporation's ABC centre or animal welfare department.
Insist on lawful methods. Culling, poisoning, or unauthorised relocation of strays is not permitted under the ABC Rules, 2023 — residents and RWAs can push back against such measures.
Track municipal compliance. Citizens can use RTI applications to ask municipal bodies for ABC programme data — number of dogs sterilised, vaccination coverage, and pending targets.
Report dog bite or rabies incidents promptly to enable proper medical response and to feed accurate data into municipal planning.
File a complaint and claim compensation. Dog-bite victims are not without remedy. The Punjab & Haryana High Court has directed a minimum compensation of ₹10,000 per tooth mark, payable by the concerned municipal body through district-level committees headed by the Deputy Commissioner. Several municipal corporations, including Chandigarh, have set aside dedicated funds for such payouts. Separately, the Supreme Court, in its ongoing suo motu proceedings on stray dog management, has warned States that heavy compensation may be ordered for every dog-bite and dog-bite-related death where municipal negligence in implementing the ABC Rules is established. Victims should preserve medical records, photographs of injuries, and treatment bills, and approach the municipal corporation, the district committee (where constituted), or the appropriate civil/consumer forum to pursue a claim.

PRAN's Perspective

PRAN believes this order gets the immediate priority right, even as the framework it enforces needs reform. The ruling recognises three important realities:

1. Prevention at the Source Is Good Governance

Chasing symptoms — more feeding stations, more vaccination drives for an ever-larger population — is a losing strategy. The Court's emphasis on stopping procreation first is a structurally sound approach that any resource-constrained municipal body should adopt, regardless of what the law ultimately looks like.

2. Strict Compliance Is Non-Negotiable Until the Rules Change

The ABC Rules, 2023 are, in PRAN's assessment, part of the problem — their rigid design has made consistent compliance difficult and left municipal bodies chronically short of the results the law demands. But until they are amended or replaced through proper legislative process, they remain binding law. Selective or half-hearted enforcement is not an acceptable response to a flawed rule; strict, well-resourced compliance and vigorous sterilisation drives are the only lawful path forward in the meantime. Judicial oversight, as seen here, plays a vital role in holding administrations to that standard.

3. Public Safety and Animal Welfare Are Not Opposing Interests

This order shows that humane, lawful methods and genuine public safety outcomes can move in the same direction. Citizens do not have to choose between compassion for animals and safety for their families — a properly and strictly implemented ABC programme, even an imperfect one, delivers both while reform is pursued.

Conclusion

The Bombay High Court's direction is a practical reminder that the toughest civic problems often have the simplest structural fixes — if implemented with discipline. The ABC Rules, 2023 themselves may well need reform, and that debate deserves serious policy attention. But until that reform arrives, strict compliance and aggressive sterilisation are not optional extras — they are the law, and the only responsible course. As Maharashtra's compliance roadmap unfolds and the matter returns before the Court on 11 September 2026, the real measure of success will not be in submissions made in court, but in sterilisation numbers on the ground. PRAN will continue to track how this compliance process develops.

Disclaimer: This article is intended for legal awareness and public policy discussion purposes only. It does not constitute legal advice.

For more legal-policy analysis and consumer rights advocacy, visit: PRAN – Policy Research Action Network Foundation www.publicrightaction.org

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हिंदी सार

बॉम्बे हाई कोर्ट ने महाराष्ट्र सरकार को आवारा कुत्तों की नसबंदी (एनिमल बर्थ कंट्रोल कार्यक्रम) को सख्ती से लागू करने का निर्देश दिया है। अदालत का मानना है कि बढ़ती आबादी को संभालने के बजाय, वयस्क कुत्तों की नसबंदी पर ध्यान देने से समस्या जड़ से हल हो सकती है — न नए बच्चे पैदा होंगे, न आबादी बढ़ेगी, और टीकाकरण व देखभाल भी आसान हो जाएगी। यह मामला सुप्रीम कोर्ट के 19 मई 2025 के फैसले के अनुपालन की निगरानी हेतु शुरू की गई एक स्वतः संज्ञान याचिका से जुड़ा है। अगली सुनवाई 11 सितंबर 2026 को होगी। PRAN का मानना है कि एनिमल बर्थ कंट्रोल नियम, 2023 में स्वयं सुधार की आवश्यकता है, परंतु जब तक ऐसा सुधार नहीं होता, तब तक मौजूदा नियमों का सख्त पालन और नसबंदी अभियान ही कानूनी रूप से एकमात्र सही रास्ता है। कुत्ते के काटने से पीड़ित व्यक्ति नगर निगम से मुआवज़े का दावा भी कर सकते हैं। PRAN नागरिकों से आग्रह करता है कि वे नगर निकायों से जवाबदेही की मांग करें।