Supreme Court of India· 26 November 2025

Does Article 21 oblige the State to secure public premises against stray dog attacks?

In Re: City Hounded by Strays, Kids Pay Price

2025 INSC 1357
Coram: Justice Sandeep Mehta · Justice Vikram Nath · Justice N. V. Anjaria

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Answer

Yes. The recurrence of such incidents within institutional spaces meant for learning, healing and recreation reflects not only administrative apathy but a systemic failure to secure these premises from preventable hazards, calling for immediate judicial intervention to safeguard the fundamental right to life and safety under Article 21 of the Constitution of India. The State and its instrumentalities bear an affirmative obligation to ensure that no citizen, least of all children, elderly people and patients, are exposed to preventable injury or disease within public premises, and the constitutional mandate of safeguarding the right to life under Article 21 is not to be compromised by administrative inaction or inefficiency.

Headnote

Constitution of India, 1950 — Art.21 — Prevention of Cruelty to Animals Act, 1960 — Animal Birth Control Rules, 2023 — Stray dogs — Institutional areas — Stray cattle on highways — Constitution of India, 1950 — Art.21 — Affirmative obligation to secure public premises — Held: Recurring dog-bite incidents within institutional spaces reflect a systemic failure to secure those premises from preventable hazards. The State and its instrumentalities bear an affirmative obligation to ensure that no citizen is exposed to preventable injury or disease within public premises. (¶13, 24) Animal Birth Control Rules, 2023 — Stray dogs in institutional areas — No release to the same location — Held further: Every stray dog found within an educational institution, hospital, sports complex, bus stand or railway station must be shifted to a designated shelter after due sterilisation and vaccination, and shall not be released back to the same location, as that would frustrate the very effect of the directions. (¶25) Prevention of Cruelty to Animals Act, 1960 — Stray cattle on highways — Removal, shelter and patrolling — Held further: The municipal authorities, the road and transport departments and the National Highways Authority of India must remove stray cattle from National and State Highways, shelter them with veterinary care, run 24x7 patrol teams and file compliance affidavits. Directions issued. (¶10)

In the Court's own words

Paragraph 13The recurrence of such incidents, particularly within institutional spaces meant for learning, healing, and recreation, reflects not only administrative apathy but also a systemic failure to secure these premises from preventable hazards. The situation calls for immediate judicial intervention to safeguard the fundamental right to life and safety of citizens, especially children, patients, and sportspersons, under Article 21 of the Constitution of India.

Paragraph 23Despite the statutory framework of the Animal Birth Control Rules, 2001 as amended in 2023, and the existence of various municipal byelaws/guidelines/Standard Operating Procedures, the practical outcomes have remained suboptimal. The data emerging from several States and Union Territories reveal a year-on-year increase in reported dog-bite cases, many occurring within or near public institutions. The persistence of the problem calls for a holistic and coordinated approach involving municipal corporations, public health authorities, and administration of the institutions, to ensure that the constitutional mandate of safeguarding the right to life under Article 21 is not compromised by administrative inaction or inefficiency.

Paragraph 24The menace of dog bites, particularly in public and private institutions that serve as spaces of learning, healing and recreation, thus constitutes not merely a public-health challenge but a matter of human safety concern. The State and its instrumentalities bear an affirmative obligation to ensure that no citizen, least of all children, elderly people and patients, are exposed to preventable injury or disease within public premises. IV. Directions

Acts & Sections

Art. 21 Constitution of India, 1950Prevention of Cruelty to Animals Act, 1960Animal Birth Control Rules, 2023

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Also decided in this judgment

Must stray dogs removed from schools and hospitals be released back to the same location?Who must remove stray cattle from National Highways and State Highways?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections