The Supreme Court on Wednesday expressed its displeasure at what it perceived to be lack of adequate measures taken by various States to sterilise stray dogs, establish dog pounds and remove dogs from campuses of educational and other institutions.

A Bench of Justices Vikram Nath, Sandeep Mehta and NV Anjaria noted that in Assam there were 1.66 lakh dog bites reported in 2024 but the State has only one dog centre.

"It is astonishing. In 2024 there were 1.66 lakh bites. And in 2025 only in January, there were 20,900. This is shocking," the Court noted.

As regards Gujarat, the Court noted that there was "no information on dog pounds at all."

On Jharkhand, the Court expressed concerns that the figures could be inflated since the State's affidavit said that around 1.6 lakh dogs were sterilised in the last two months.

The matter gained national attention last year after a Bench of Justices JB Pardiwala and R Mahadevan directed Delhi municipal authorities to round up and shelter stray dogs, drawing protests from animal rights groups.

That order triggered widespread protests by animal rights groups and was later modified by the present three-judge Bench.

The modified directions shifted the focus to vaccination, sterilisation and release of dogs in accordance with the Animal Birth Control Rules. Since then, the Court has expanded the scope of the case.

On November 7, 2025, as an interim measure, the Court directed states and the NHAI to remove stray animals from highways and institutional areas like hospitals, schools and educational institutions across the country. 

It also ordered fencing of government and private educational and health institutions within eight weeks to prevent stray dog bites, and directed that dogs picked up from such institutional areas should not be released back into the same premises.

During the hearing on December 7, the Court flagged the increasing number of dog bite incidents in the country and called out the municipal authorities and other local bodies for their failure to implement the Animal Birth Control (ABC) rules.

When the matter was heard today Amicus Curiae Gaurav Agrawal submitted a note detailing various issues in different States.

"For every State, I have addressed 4 aspects - one, functioning of Animal Birth Control (ABC) centres, two setting up of dog shelters, removal of dogs from institutional areas and removal of cattle etc, three, identification of stretches on highways prone to cattle ingress, and four, steps taken for removal," he said.

On the State of Andhra Pradesh, he said,

"Andhra Pradesh has 39 ABC Centres. 1,619 dogs can be sterilised each day. The state should audit existing facilities to see if they are fully utilised. A timeline should be given for setup of new ABC centres. 14,000 institutions have been identified. 12,000 institutions have established fencing. The State should take help of all concerned to identify strays in all institutional areas."

"We have filed certain details in the subsequent affidavit which I will share with the amicus," the counsel for Andhra Pradesh said.

On the State of Assam, Agrawal said,

"It has 3 municipal corporations. They have to start with that. ABC centres are inadequate. There should be a detailed action plan to increase ABC centres. Assam needs to take some more effective measures,"

"As of day, they don’t have a single dog centre?" the Court asked.

"Only Dibrugarh does. They are saying they will set it up in 6 months but the details are missing from the affidavit as to how they plan to do it. There are 318 stadiums in Assam," the Amicus pointed out.

"This affidavit is silent on manpower and human resources," the Bench noted.

"Yes," said Agrawal.

"Dog pounds etc being less is a fact. But 6 months time I have taken. We have taken steps," the counsel representing Assam said.

"The graver concern is regarding lack of manpower," the Court remarked.

"Three months time has been sought from the Court for this purpose," the State counsel replied.

The Court expressed shock at the number of dog bite cases reported in Assam.

"Look at the statistics of bites. It is astonishing. In 2024 there were 1.66 lakh bites. And in 2025 only in January, there were 20,900. This is shocking," the Court said.

"Lordships can give them (Assam) 6 months where they can take steps," Agrawal said.

On State of Bihar, Agrawal said,

"There are 34 ABC centres. 20,648 dogs have been sterilised. Daily capacity of sterilisation has not been mentioned. State should have done compete audit of ABC centres. If there are more than 6 lakh dogs in the state, sterilisation of 20,648 dogs is totally insufficient. 91 dogs are presently lodged in dog pounds. The affidavit does not indicate in how many institutional areas survey has been done to see if there are fences, boundary walls etc."

"They are all building castles in the air. None of the States have given data on how many bites except Assam," the Court said.

"We are putting things into place. The result will be there. After the chief secretaries were called. Things have progressed," the counsel for Bihar replied.

"We will have to call them again," the Court said.

"Within 3 months substantial improvement will be there," the State counsel assured.

On Goa and Kerala, Agrawal highlighted the issue plaguing the beaches in the two States.

"There are dogs in beaches of Goa and Kerala. They cannot be released back," he said.

"They scavenge on leftovers. Fish carcasses and from shacks. it will ultimately affect their tourism. SCAORA made us have a first hand experience (referring to the recent SCAORA conference in Goa)," the Bench said.

For Gujarat, the Court noted that there was "no information on dog pounds at all."

"I have sought for information on that. We are in the process of creating more animal pounds and shelters. There are kennels where dogs are being kept. 60 crores budget is sanctioned for this year and 75 crore for next year. We are in the process," the counsel for Gujarat said.

The Court told the counsel for Haryana that its affidavit was silent on steps taken to remove dogs from institutional areas.

"I will take instructions," the counsel replied.

As regards State of Jharkhand, the Court expressed disbelief at the figures provided.

"We can’t believe this. 1.89 lakh dogs have been sterilised," the Bench exclaimed.

The counsel for Jharkhand said that 29,000 dogs were sterilised before November 2025.

"1.6 lakh dogs were sterilised in 2 months? Now many dogs can a caged vehicle catch in a day? Absolutely fudged up figures," the Court said.

"There is no compliance on fencing, dog pounds etc.," the Amicus pointed out.

"We will get appropriate instructions," the counsel said.

On Karnataka, the Court noted,

"This is the only state which has given number of stray dogs in institutions."

"Yes. Although they have been identified, they have not been picked up," Agrawal pointed out.

"They haven’t picked up a single stray from institutions," the Court concurred.

"We will place on record the details," the State counsel said.

"We will pass strong strictures against the government for all the States. If you would have said you don’t have information and need more time, we would understand. All the States who have put these vague averments in their affidavits, will get a proper dressing down. Total eye wash," the Court warned.

The counsel for Madhya Pradesh said,

"Catching is not happening as of now, because we don’t have shelter homes. 475 dogs have been put in shelter homes."

"Capacity of about 300 still remains," the Court said.

"We will file an additional affidavit," the State counsel replied.

The counsel for Maharashtra said that they have created an online dashboard giving details.

"We have created a dashboard. It will show real numbers of bites, sterilisations, vaccinations, veterinary centres etc. We are collecting all the data," it was submitted.

"It is a good beginning. It may perhaps be emulated by other States also," the Bench remarked.

On Odisha, the Court noted that as per the State's affidavit, they have picked up significant number of dogs from institutions.

"They can do a complete audit. Places like Puri, Konark etc should have ABC centres. They can come up with a clear action plan," Agrawal suggested.

The counsel for West Bengal said that in 2024, 12,000 dogs were sterilised.

"In 2025 until December it was 10,000," it was submitted.

"If you have 1-2 lakh in the city, if you vaccinate 10-12000 a year, how will you bring the population under control?" the Bench asked.

For Delhi, Additional Solicitor General SD Sanjay appeared.

"Chief secretary of Delhi has filed a detailed affidavit. NDMC is a small area. Rest is taken care by MCD," he said.

"If they are sterilising 68,000 dogs in 8 months, it will be around 80,000 in a year. It will not be sufficient to reduce dog population," the Court said.

"It should be doubled by this year," Agrawal suggested.

"When you bring in a dog for microchipping, simultaneously it can be vaccinated and sterilised. Because it will have to be captured anyway for microchipping. They (MCD) has not said anything about population. The shelters may not be permanent facilities. For 6 months you can go very aggressive. Then gradually it can be phased out," the Court remarked.

"Now that the State and the corporation are in synergy, they can probably set up some more centres etc," Agrawal suggested.

The hearing will continue on Thursday at 2 pm.

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