The recent order by the Supreme Court of India, directing the relocation of all stray dogs from the streets of Delhi-NCR to permanent shelter facilities within eight weeks, represents a decisive and necessary measure to safeguard public health and safety. This move addresses the alarming and unprecedented escalation in dog-bite incidents, which have evolved into a genuine public health emergency. In 2025 alone, Delhi has recorded over 26,000 dog-bite cases, while hospitals across the city have been attending to nearly 2,000 such incidents on a daily basis. Importantly, even in cases involving vaccinated dogs, bite victims are still compelled to undergo the arduous and time-consuming process of post-exposure prophylaxis (PEP), imposing avoidable emotional strain on families as well as substantial burdens on the healthcare system.
This white paper unequivocally endorses the Court’s directive as an essential intervention to shield vulnerable demographics—particularly children and the elderly—from the devastating consequences of rabies, as well as the associated psychological trauma resulting from dog attacks.
The Public Health Crisis: Statistical Evidence Demanding Urgent Action
Overwhelming Dog-Bite Burden
The magnitude of Delhi’s stray dog crisis has reached unprecedented proportions. Current data reveals:
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Stray dog population: Estimated at approximately one million in Delhi, compared to the 560,000 recorded in the last official census of 2009.
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National bite statistics: In 2024, over 3.7 million dog-bite cases were reported across India, with Delhi contributing a significant share to this figure.
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Daily hospital load: Safdarjung Hospital alone recorded 91,009 dog-bite cases in just seven months of 2025, translating to an average of 249 cases per day at a single institution.
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Rising rabies fatalities: The number of deaths from rabies rose from 21 in 2022 to 50 in 2023, and further to 54 in 2024, with India accounting for 36% of global rabies-related mortality.
Healthcare System Overload
The economic and operational strain on healthcare infrastructure has reached an unsustainable level:
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Treatment costs: PEP expenses range from ₹1,400 in government facilities to ₹3,685 per patient in private hospitals.
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Vaccine availability: Merely 80% of public healthcare centres stock anti-rabies vaccines, while only 20% carry rabies immunoglobulin.
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Sterilization capacity: The Municipal Corporation of Delhi (MCD) operates just 20 sterilization centres, collectively capable of handling only 2,500 dogs—grossly inadequate given the city’s million-strong stray population.
The Trauma of Post-Exposure Prophylaxis: Why Even Vaccinated Dog Bites Remain a Concern
Physical and Procedural Burden
Bite victims, even when attacked by vaccinated dogs, cannot bypass the demanding PEP process, which includes:
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Multiple hospital visits: The Essen regimen requires five doses over 28 days.
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Urgency of initiation: Treatment must commence within 24 hours for optimal effectiveness.
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Additional interventions: Category III bites require infiltration of rabies immunoglobulin around wound sites.
Economic Burden
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Direct costs: Between ₹2,000 and ₹22,894 per complete treatment, depending on case severity and healthcare provider type.
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Indirect costs: Loss of wages, travel expenses, and accommodation costs ranging from ₹1,220 to ₹1,800 per case.
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Family impact: Parents often accompany children, amplifying the overall economic burden.
Psychological Trauma in Children
Research demonstrates that dog-bite incidents inflict long-term psychological damage, particularly in young victims:
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Post-Traumatic Stress Disorder (PTSD): More than 50% of dog-bite victims exhibit PTSD symptoms within 2–9 months of the attack.
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Common symptoms: Nightmares, flashbacks, heightened anxiety, social withdrawal, and hypervigilance.
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Long-term effects: Personality alterations, including excessive caution and restricted thinking, persisting for up to four years.
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Child-specific vulnerabilities:
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70% of bitten children exhibit notable behavioural changes post-incident.
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Sleep disruptions, such as insomnia, nightmares, and bedwetting.
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Social withdrawal stemming from fear of outdoor activities.
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Developmental hindrance affecting both cognitive and social growth well into adolescence.
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Disruption to Daily Life
The PEP regimen significantly disrupts routine activities:
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Healthcare system navigation:
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Multiple scheduled appointments over a four-week period.
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Emergency department visits involving prolonged waiting times.
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Follow-up appointments for wound management and complication checks.
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Family repercussions:
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Loss of productive workdays for both patients and accompanying caregivers.
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School absences for children undergoing treatment.
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Emotional strain on parents, including anxiety, guilt, and worry, impairing caregiving capacity.
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Constitutional and Legal Justifications
Right to Life and Safety
The directive aligns with Article 21 of the Constitution, ensuring citizens’ right to life and a secure environment. The Court stressed that “infants and young children should not at any cost fall prey to stray dog bites leading to rabies,” thereby prioritising the protection of human life over sentimental considerations.
Public Interest Above Individual Preferences
Justice Pardiwala’s pointed observation—“All these animal activists, will they be able to bring back those children who have fallen prey to rabies?”—reinforces the moral imperative of prioritising public safety over individual sentiment.
Legal Precedent for Emergency Measures
The suo motu intervention underscores the judiciary’s recognition of the crisis’s urgency. The directive to establish shelters for 5,000 dogs within 6–8 weeks, complete with sterilization and vaccination capabilities, represents a balanced and humane response.
Public Health Benefits of the Court’s Decision
Immediate Risk Mitigation
Relocating stray dogs from public spaces directly reduces the primary vector for rabies transmission and the incidence of bites, thereby:
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Providing immediate safety for vulnerable groups.
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Reducing demand on overburdened healthcare systems.
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Lowering long-term healthcare costs.
Long-Term Population Management
Permanent sheltering combined with sterilization is more effective than the current catch-neuter-release model:
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Eliminates territorial disputes, reducing aggression.
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Prevents uncontrolled breeding.
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Ensures ongoing veterinary care, vaccination, and adequate nutrition.
Scientific Rationale
The Court correctly critiqued the Animal Birth Control Rules’ stipulation of releasing sterilized dogs back to their original locations as:
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Perpetuating territorial aggression.
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Failing to reduce bite incidents.
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Creating a misleading sense of public safety.
Addressing Opposition Arguments
Resource Constraints
While critics cite high costs, the projected ₹15,000 crore shelter investment is justified when compared to the annual treatment costs for over 3.7 million bite cases.
Animal Welfare
Opponents labelling the order as “inhumane” overlook the reality that stray dogs on the streets suffer from disease, malnutrition, accidents, and aggression. Shelters will offer professional care, regular feeding, and medical attention.
Implementation Challenges
Concerns over feasibility are mitigated by:
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Existing MCD sterilization infrastructure.
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Partnerships with 11 NGOs already engaged in animal control.
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The Delhi government’s commitment, with CM Rekha Gupta promising a “comprehensive, well-structured plan.”
Evidence from Successful Models
International Examples
Rabies elimination in several Latin American countries was achieved through integrated vaccination and population control strategies. Cities globally manage strays via shelter-based systems.
Domestic Precedents
Bangalore achieved a 10% reduction in stray populations through systematic ABC implementation, while states with more robust enforcement have shown improved rabies control outcomes.
Conclusion: An Urgent, Humane, and Scientifically Sound Solution
The Supreme Court’s order to relocate Delhi’s stray dogs to permanent shelters is constitutionally justified, scientifically supported, and morally essential in addressing a clear public health emergency. With over 26,000 dog-bite cases this year and hospitals treating hundreds daily, the current policy framework has failed to protect citizens.
The directive offers an actionable and humane path forward—prioritizing sterilization, vaccination, and monitored sheltering—while reducing the human and economic costs of rabies prevention. Implementation must be immediate; every day of delay prolongs preventable suffering and risk to the most vulnerable members of society.
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