Introduction: Urbanization and the Canine Crisis
The stray dog problem in Indian cities is the result of rapid urbanization, inadequate infrastructure and poor governance. India has the largest stray dog population in the world with 62 million strays and a rabies related death toll of over 20,000 per year, accounting for 36% of the total deaths due to rabies across the world. The Supreme Court’s orders in 2025-26, arising out of the increasing number of bites and deaths have raised issues of human health, animal rights and constraints imposed by judicial orders.
However, the Netherlands, on the contrary, is celebrated as the only country that has attained the status of zero stray dogs due to the holistic strategy that involves animal welfare laws, the efforts of local governments, and the change in societal mentality. This blog examines why the Dutch model is effective, why Indian legal and judicial practices have failed, and what lessons can be adapted to India’s unique urban and cultural setting.
Section I: Legal Frameworks – Dutch Statutory Integration vs. India’s Patchwork
• The Dutch Recognition of Intrinsic Value
The Dutch Parliament recognized the inherent value of animals by 1981, a notion that was subsequently incorporated into the Animals Act 2011 through Article 1.3, which, in general terms, permits “the intrinsic value of the animal” to be considered, thus demanding that all regulations and decisions take into account the impacts on animals’ sentience and welfare.
The main legal framework for animal protection in the Netherlands is based on the Animal Act 2011, which mainly relies on Article 2.1, which specifies that the infliction of pain, injury, or impairment of health without a reasonable purpose or more than necessary for the animal is generally prohibited. Such a provision is further supported by Article 1.3, which articulates the concept of intrinsic value, meaning that the animal is treated as a sentient creature whose integrity is to be respected, irrespective of its utility to humans.
The practical application of these rights is provided in Article 1.4, where all citizens are put under the obligation of care towards the animals in need. This duty is further defined by the specific welfare standards set out in Article 1.3(3), which incorporate the Five Freedoms into Dutch law. Subsections (a) through (e) of this article explicitly require that animals be kept free from thirst, hunger, physical and physiological discomfort, pain, injury, disease, fear, chronic stress, and the restriction of their natural behaviour.
Dutch law is not only punitive but preventive. The country’s coordinated, government-funded Collect-Neuter-Vaccinate-Return (CNVR) program sterilized over 70% of female dogs, with the state subsidizing costs. With very high taxes on the purchase of puppies and strict licensing requirements for breeders, demand has shifted toward adoptions. Indeed, over 90% of dog owners in Holland adopt their pets from shelters. Registration and microchipping are required to ensure traceability and responsibility.
• India’s Duty-Based Welfare Framework
In India, there are nonetheless, different legal systems and a list of constitutional obligations of duties, such as Article 51A(g), that include the protection of all living beings, Article 48A, which emphasizes the protection of the environment more, and the laws like the Prevention of Cruelty to Animals Act, 1960 (PCA) and the Animal Birth Control (Dogs) Rules, 2023 are in place as well. Section 11 of the PCA criminalizes the act of cruelty, while Section 325 of the Bharatiya Nyaya Sanhita (BNS) criminalizes killing and maiming animals.
The revised ABC Rules of 2023 have introduced the CNVR policy, which stands for Catch, Neuter, Vaccinate, and Re-release, and that essentially bans culling and recommends releasing stray dogs into their natural habitats once they have been sterilized, rendering them infertile. These rules are enforced through the Animal Birth Control Monitoring Committee, established at the state, district, and municipal levels. Further, Local administrations carry out the enforcement under Article 243W.
Section II: Judicial Interventions – Ambition, Backlash, and the Realities of Urban Management
The intervention of the Supreme Court in 2025-26 was after sustained community complaints about public health, as Delhi recorded 35,198 animal bites and 49 cases of rabies in the first six months of 2025. On August 11, 2025, the Supreme Court directed the complete removal of all strays in the Delhi-NCR area to a faraway shelter within eight weeks, overriding the ABC Rules’ requirement to return strays to their original territory. The directive included the construction of new shelters for 5,000 dogs, legal action against those who would hinder the process, and the prohibition on returning the dogs to their habitat.
However, the mandate was operationally and fiscally impossible. The Municipal Corporation of Delhi, with only 20 ABC centres, 11 NGOs, and 4 veterinary doctors, could not possibly process the estimated one million dogs. It was estimated that shelter construction alone would require 3,000 enclosures and ₹15,000 crore, an amount that was out of the question. The city ground to a halt due to a lack of enough vans and handlers, with only 2-3 vans per zone.
Within days, the Supreme Court reversed itself on August 22, 2025, allowing sterilized and vaccinated dogs to remain in their original neighbourhoods, sheltering only rabid or dangerously aggressive dogs. But, the November 2025 order narrowed the scope to schools, hospitals and public transport areas, with tougher controls on feeding and more support for fencing. Schools and colleges were estimated at 1.5 million by January 2026, with an eight-week deadline that was totally unrealistic in terms of municipal capacity.
These swings illustrate the inadequacy of judicial remedies for complex urban ecological problems. The Court policy involved removal, fencing, and exclusion, where they view street dogs as a nuisance that must be totally eliminated, as opposed to a population that must be managed and controlled. The orders did not consider the urban ecological vacuum effect: when dogs are removed from an area, others migrate in, as food sources and habitats remain. There are 85,109 garbage points and 327,069 feeding sites alone in Delhi, accommodating a carrying capacity of over 1.5 million dogs. The legal emphasis on enforcement and exclusion did not factor in the fact that the density of dog packs is linked not to removal but to the density of feeding stations and garbage points.
The judicial pendulum swung back with the Supreme Court’s decision on May 19, 2026 dismissing challenges to the AWBI’s SOP of November 2025, bringing much needed clarity to its position on canine management. The Court dismissed the notion of a blanket license to arbitrarily pick up, relocate or cull stray dogs from ordinary public streets, reaffirming that the Animal Birth Control Rules are the guiding framework. Significantly, the bench limited euthanasia to rabid, incurably ill or demonstrably dangerous dogs, stating that these acts must be subject to veterinary assessment and the Prevention of Cruelty to Animals Act, 1960. Now the Supreme Court has decentralized oversight, acknowledging the failures of centralized judicial micromanagement, directing all High Courts to register suo motu proceedings to supervise the execution of sterilization, vaccination and relocation measures, redirecting attention from elimination back to scientific population control.
Section III: Urban Planning, Feeding, and the Dutch Precedent
Empirical research studies in Delhi indicate that the primary causes of urban dog populations are not sterilization rates or removal efforts, but rather the presence of human food sources, including garbage, feeding stations and ritual provisioning. In wealthy areas, regulated feeding and sanitation contribute to a higher dog density, while in poor areas, scavenging is a prominent phenomenon. This problem was recognized by the Netherlands from a very early stage, and the management of animals was included in city planning through the enactment of strict laws that prohibited open dumping of garbage, banned open feeding, and legalized, or rather banned in most cases, feeding.
India acknowledged this fact through the ABC Rules, which allowed Resident Welfare Associations to identify feed spots, but it falls short of establishing a robust municipal licensing and accountability framework. In Kolkata’s SOP in 2024, limiting feeding to designated areas and times of day, enforced by the police, is a partial recognition but has not yet led to general acceptance. The Dutch approach, by contrast, considers feeding and breeding as a concern for the municipality, thus imposing very strict licensing, traceability, and enforcement measures.
The Netherlands’ success is not attributable to any one law, but to the combination of law, infrastructure, and culture. Stringent penalties for cruelty and abandonment are provided under Article 8.8 and are backed by robust enforcement. Government-implemented CNVR programs and services encouraging micro-chipping and registration, and excessive government taxes on commercial puppy purchases have shifted public behaviour towards adoption and responsible ownership. Public awareness campaigns have made abandonment morally unacceptable.
In India, the problem still exists when it comes to putting things into action. The Supreme Court’s directives for mass removal and fencing, disconnected from urban planning and municipal realities, have ultimately proven unenforceable. The ABC Rules put the responsibility on the civic bodies, but they don’t have the resources to do it. Unregulated feeding and a lack of systematic sterilization and vaccination coverage mean that dog populations keep growing, as data suggests that the population only dropped by 10% between 2019 and 2023.
Section IV: The Way Forward – Integrated Urban Dog Governance
What India needs is a legal and integrated solution to the problem of stray dogs. We need a legal and integrated strategy that includes practical law, urban planning, and community involvement for its permanence, and which goes beyond court orders.
First, dog management needs to be integrated into the municipal master plans and development policies. Zonal Dog Management Plans would help identify where dogs are most common, where they leave waste, and where they eat the most, enabling planning interventions. For instance, they could sterilize the area with the highest pack density and manage waste in areas where food is most abundant. This would be made possible if local administrations act on the recent directive by the Supreme Court to set up at least one fully functional and well-equipped Animal Birth Control (ABC) centre in every district, ensuring the infrastructure is commensurate with the scale of the issue.
Second, the Supreme Court’s November 2025 order called for a licensing system for feeding in cities. This system is already in place in the Netherlands and the city of Kolkata. This system will make it clear who is responsible for what and reduce disagreements. This system ensures regulated feeding and places an additional onus on Registered feeders for the sterilization and vaccination of animals.
Third, the Central Public Works Department’s urban design guidelines, which are part of the National Building Code, must address and ensure the provision of dog-friendly zones. This includes dog-proof trash cans, enough light, and places for both casual workers and community dogs to rest. These solutions will address dog-human problems that happen at certain times and places.
Fourth, setting up a One Health Municipal Cell will connect public health, animal welfare and urban planning. Preventive investments in vaccination and sterilisation are crucial. Besides, this cell has to ensure that there is a constant supply of anti-rabies vaccines at all government medical facilities so as to ensure a rapid public health response as per recent Supreme Court directives.
Fifth is using technology to support data-driven governance with GPS tracking of sterilized dogs, online databases for sterilization or vaccination, mobile reporting apps, and predictive analytics for bite hotspots.
Finally, community education programs and public awareness campaigns that have been so successful in the Netherlands should emphasize the responsibilities of ownership and adoption and the ethical imperative to avoid abandonment. The legal consequences of abandonment should be upheld with severe penalties, including imprisonment.
*Faraz Ahmad 5th-Year B.A. LL.B. (Hons.) Students, Faculty of Law, Jamia Millia Islamia
**Mantasha Khan 5th-Year B.A. LL.B. (Hons.) Students, Faculty of Law, Jamia Millia Islamia