Feasibility and Policy Review for GoK re SC 7/11 Order

Feasibility and Policy Review of the Supreme Court's November 7th Directive on Stray Dog Relocation: A Prudent Path Forward for the State of Karnataka

Executive Summary: Balancing Judicial Mandate with Public Health Pragmatism

The Supreme Court (SC) of India’s directive issued on November 7, 2025, mandating the removal and permanent relocation of stray dogs from five key institutional premises—educational institutions, hospitals, sports complexes, bus stations, and railway stations—presents an unprecedented operational and financial challenge for the State of Karnataka.¹ This order, which strictly prohibits the release of sterilized and vaccinated dogs back into their original locations, fundamentally conflicts with the scientifically established Animal Birth Control (ABC) Rules, 2023, which rely on the Capture-Sterilize-Vaccinate-Return (CSVR) model.³

The State of Karnataka, particularly the Bruhat Bengaluru Mahanagara Palike (BBMP), stands as a national leader in the effective implementation of the ABC rules, having achieved documented population stabilization and high rates of Anti-Rabies Vaccination (ARV) coverage.⁴ Forcing compliance with the "no release back" clause threatens to negate these public health achievements. The mandatory mass impoundment is logistically paralyzing, requires a perpetual, non-recurrent expenditure exceeding hundreds of crores annually, and demands infrastructure (land, shelters, trained staff) that simply does not exist.²

This expert report provides a detailed critique of the relocation mandate and proposes a structured policy blueprint to navigate this regulatory conflict. The key recommendation is twofold: first, the Government of Karnataka must immediately file a comprehensive affidavit with the Supreme Court, detailing the financial and logistical impossibility of the current directive and proposing a revised, compassionate solution centered on institutional sealing and reinforced CSVR. Second, Animal Welfare Organizations (AWOs) must utilize a strict, phased Prerequisite Checklist to ensure that any execution of the order is conducted slowly, humanely, and only after all necessary, AWBI-compliant infrastructure is certified. This dual strategy seeks to secure judicial compliance while preserving the state’s successful, science-based approach to dog population management.

Section 1: The Regulatory Imperative and the Conflict of Directives

1.1. The Established Legal Framework: ABC Rules, 2023

Dog population management in India is governed by the Animal Birth Control (ABC) Rules, 2023, which codify the Capture-Sterilize-Vaccinate-Return (CSVR) policy. This policy is globally accepted and mandated in India as the singular legal mechanism to control dog populations and mitigate rabies transmission.³ The scientific rationale behind CSVR is that sterilizing and vaccinating the existing, territorial dog population and returning them prevents the influx of new, unsterilized dogs, thereby stabilizing the population over time and eliminating rabies as a public health threat.

Crucially, the successful implementation of this framework is predicated on strict procedural requirements. The Rules stipulate that ABC programs must be carried out exclusively by organizations recognized and approved by the Animal Welfare Board of India (AWBI).³ Furthermore, the personnel involved, including veterinarians, handlers, and para-veterinary staff, are required to undergo specialized training at AWBI-recognized centers to ensure humane handling and adherence to standards.⁷ This establishes the supremacy of the CSVR model as the humane, scientifically derived, and legally sanctioned method for management, directly contrasting with policies advocating for mass culling or permanent displacement.

1.2. The Supreme Court Directive (November 7, 2025): Mandate for Permanent Impoundment

The Supreme Court’s November 7, 2025, order, issued in the context of persistent dog bite incidents in institutional settings, directed all States and Union Territories (UTs) to take immediate action against the presence of stray dogs within five specific high-traffic public areas: educational institutions, hospitals, sports complexes, bus depots, and railway stations.¹

The most contentious element of this directive is the "zero-tolerance clause" regarding release. The court explicitly ruled that dogs collected from these premises, even after successful sterilization and vaccination in accordance with the ABC Rules, "will not be released back in the same area".¹ The bench justified this measure by stating that releasing them back "will frustrate the very purpose of the directive of the court" to secure institutional premises.¹ This necessitates their permanent relocation to designated shelters, a complete departure from the 'Return' element of the CSVR policy. This ruling transforms the temporary post-operative care mandate into an indefinite custodial mandate, drastically altering the logistical requirements for state and local governments.

The enforcement mechanism of the order carries significant weight: Chief Secretaries of all states and UTs are held personally responsible for ensuring strict compliance.¹ This creates a high-pressure environment for immediate, visible action, even if such action is structurally unsustainable.

The regulatory environment is further complicated by judicial volatility. Prior to the November 7 directive, the Apex Court had ordered a 'no release' policy for Delhi-NCR in August 2025, only to modify that position shortly thereafter, reinstating the core CSVR 'return' policy in an order dated August 22, 2025.³ The November 7 order, by selectively reverting to mandatory permanent relocation for the five institutional spaces, introduces regulatory chaos. This instability forces municipal bodies, such as the Pune Municipal Corporation (PMC), into constant "re-evaluating" of their stray dog management action plans, compromising the ability of governments to plan and execute long-term, resource-intensive public health programs effectively.⁸

1.3. Synopsis of the Karnataka Chief Secretary's Compliance Circular

Although the full text of the 11-page circular issued by the Chief Secretary of Karnataka is not available for direct translation, its content can be inferred based on the SC mandate and documented state responses.¹ Given the personal responsibility clause placed on the Chief Secretary, the circular undoubtedly serves as an initial compliance roadmap. It is highly probable that the circular instructs urban local bodies (ULBs) and municipal corporations, such as the BBMP, along with relevant departments (Animal Husbandry, Transport, Education), to immediately initiate comprehensive surveys to count the dogs in the affected areas and prepare for removal drives.⁸

It is essential to acknowledge that the Government of Karnataka has historically demonstrated a strong willingness to comply with the public health aspects of judicial concerns regarding animals. For example, the state previously amended the Karnataka Private Medical Establishments (KPME) Act to strengthen legal provisions ensuring timely and lifesaving treatment, including Anti-Rabies Vaccine (ARV) and immunoglobulin access, for dog bite victims. This amendment was made in response to previous SC directions.¹⁰ This history suggests the state is deeply committed to public safety but requires a pragmatic, functional path forward that does not undermine its existing successful programs.

Section 2: The Karnataka Model: Success of Scientific Dog Population Management

Karnataka’s extensive investment in the ABC program, particularly within Bengaluru, provides concrete evidence that the scientific framework laid out by the ABC Rules, 2023, is effective when implemented diligently. This successful implementation forms the factual basis for advocating against the impractical relocation mandate.

2.1. Quantitative Validation of ABC Efficacy

The Supreme Court’s generalized criticism regarding the "ineffective implementation" of the ABC Rules, 2023, often cited as a basis for radical interventions, finds an exception in Bengaluru’s performance.⁴ Data from the BBMP consistently highlights the city as a leading example of robust stray dog management across the country.

The efficacy is measurable and validated by demographic studies. A survey conducted by the BBMP in 2023 estimated the stray dog population in Bengaluru at approximately 300,000, representing a notable 10% decline compared to the 2019 survey data.⁵ This decline is directly attributed by the civic body to the "effective implementation of Animal Birth Control measures," proving a clear cause-and-effect relationship between sustained CSVR efforts and population stabilization.⁵

The commitment to sterilization coverage is high. Official BBMP records indicate that between April 2020 and June 2025, more than 2.75 lakh stray dogs were neutered within the BBMP limits.⁴ Experts agree that compared with other cities, Bengaluru limits have a significantly higher percentage of neutered dogs, demonstrating sustained operational capacity.⁴ This high rate of surgical intervention is the cornerstone of achieving long-term population stability, aligning the state’s approach with World Health Organization (WHO) guidelines.

Furthermore, Karnataka maintains a strong focus on Anti-Rabies Vaccination (ARV), essential for public safety and the ultimate goal of rabies eradication by 2030. The BBMP’s Animal Husbandry Department reported vaccinating 50,055 stray dogs in the first three months of the fiscal year 2025–26, with an ambitious plan to cover over 2 lakh street dogs by March 2026.⁴

The existence of a successful, demonstrably effective program in Karnataka presents a crucial dilemma. The state has invested resources in a model that is producing positive, measurable public health outcomes (population decline, high ARV coverage). Compelling the state to abandon this model for mandatory, permanent impoundment not only compromises animal welfare but constitutes a massive waste of public funds and risks reversing years of successful governance outcomes. The judicial order, in this context, effectively penalizes successful implementation by demanding adherence to an ecologically flawed policy.

2.2. Proactive Management Strategies by BBMP

In addition to core ABC measures, the BBMP has engaged in proactive strategies that link animal welfare directly to public safety. Recognizing that aggression and dog bite cases are often linked to resource scarcity, the BBMP launched an initiative to provide one meal a day to a portion of the stray dog population.¹¹

This pilot initiative, estimated to cost the civic body ₹2.88 crore annually, covers non-vegetarian food for approximately 4,000 to 5,000 stray dogs in select areas.¹¹ The underlying rationale is that reducing starvation will naturally reduce aggressive territorial behavior and decrease dog bite incidents.¹¹ This strategy exemplifies compassionate pragmatism—an approach that addresses public safety by enhancing humane care. The compulsory mass relocation of dogs would immediately disrupt these managed feeding areas, potentially leading to increased starvation and aggression among any replacement dogs that move in, rendering these significant public investments in humane solutions moot.

The effectiveness of Karnataka’s current framework is summarized in the table below:

Table 1: Key Performance Indicators of Dog Population Management in Bengaluru (BBMP)

Metric	Data/Finding	Source Significance
Stray Dog Population Trend (2019-2023)	10% Decline (3.1 lakh to 3 lakh estimated) 5	Proves the long-term effectiveness of the current ABC policy.
Total ABC Surgeries (Apr 2020 – Jun 2025)	>2.75 Lakh 4	Demonstrates high, sustained operational capacity relative to national standards.
Annual Rabies Vaccination Goal (2025-26)	>2 Lakh 4	Confirms focus on rabies eradication by 2030, aligned with global targets.
Cost of Humane Intervention (Feeding Pilot)	₹2.88 Crore annually 11	Indicates financial and administrative commitment to preventative humane solutions.

Section 3: The Feasibility Crisis: Logistical, Financial, and Capacity Constraints

The primary obstacle to strict compliance with the November 7 SC directive is not political will, but the sheer, insurmountable physical and financial impossibility of execution. The state’s ability to comply with the relocation mandate is structurally compromised by immediate constraints on space, budget, and specialized human resources.

3.1. Scale of the Infrastructure Requirement

Current ABC infrastructure is designed for temporary holding—typically 3 to 5 days of post-operative recovery following sterilization and vaccination. These centers are not equipped, nor do they have the land area or mandate, for permanent, indefinite custodial care.²

The volume of animals requiring permanent housing across Karnataka is staggering. Even if a conservative 10% of Bengaluru's estimated 3 lakh stray dogs need to be removed from the five institutional zones, this necessitates permanent housing capacity for at least 30,000 animals.⁵ When scaled to encompass all major urban and semi-urban centers in Karnataka, the required capacity rapidly increases into the tens of thousands.

To comply, the state must rapidly acquire massive, suitable tracts of land; secure immense capital funding for construction of specialized, AWBI-compliant permanent kennels; and then sustain the operational costs indefinitely. The court order necessitates the immediate creation of large-capacity shelters across multiple jurisdictions ³, a process that requires years of planning and budgetary allocation, not weeks of frantic removal drives.

3.2. Financial Modeling of Permanent Impoundment

The financial burden of mandated permanent impoundment is the clearest evidence of the directive’s infeasibility. Housing dogs indefinitely requires continuous expenditure on feeding, medical care, waste management, and staffing.

Based on projections from similar proposed mass relocation efforts in other major cities, the daily operating cost is estimated at approximately ₹110 per animal per day for logistics and maintenance.⁶ This figure covers only daily care and does not include the capital outlay for infrastructure development.

Applying this cost to a hypothetical, conservative figure of 50,000 relocated stray dogs across the state yields the following minimum annual operating expenditure:

$$50,000 \text{ dogs} \times \text{₹}110/\text{dog}/\text{day} \times 365 \text{ days} = \text{₹}200,750,000 \text{ per year}$$

This equates to an annual, recurrent expenditure of ₹200.75 Crores solely for the maintenance of 50,000 animals. This expenditure is perpetual and non-productive, serving only custodial purposes. Attempting to ring-fence this budget would inevitably require crippling the Animal Husbandry department’s budget, leading to the severe diversion of funds away from proven, successful programs like the high-volume ABC and ARV initiatives.⁴ The policy, therefore, places an impossible financial demand on the government, ensuring eventual budgetary collapse and subsequent failure to maintain humane standards.

3.3. Deficiency in Human Resources and AWBI Compliance Standards

Beyond finances, the mandate faces an immediate constraint in human capital and operational compliance. AWBI guidelines are explicit about the standards required for humane housing, requiring facilities to be equipped with quarantine kennels, dedicated operation theaters, reliable power backup, monitored CCTV coverage, and meticulous record-keeping of animal treatment and mortality (AWBI Rule 12).⁷

Crucially, the success of any shelter operation hinges on sufficient staffing. AWBI mandates appropriate staffing ratios, requiring trained veterinarians, skilled handlers, and para-veterinary staff.⁷ Karnataka cannot instantly generate the hundreds of certified, compassionate professionals needed to staff permanent, mass-capacity shelters humanely and responsibly.

The pressure exerted by the Chief Secretary’s mandate, coupled with the critical lack of AWBI-compliant facilities and personnel ¹³, creates a dangerous scenario. Municipal authorities, facing the threat of personal responsibility, may be forced to either fail to comply or outsource the operation to uncertified, third-party entities specializing in animal capture and confinement. Such rushed, unmonitored operations inevitably compromise the humane intent of the judiciary, leading to cruelty, high mortality rates, and procedural violations. Therefore, the absence of existing, certified infrastructure and adequate human resources makes immediate compliance inherently inhumane.

Table 2: Comparative Feasibility Assessment: CNVR vs. Mass Impoundment

Metric	CNVR Model (Karnataka’s Current Approach)	Mass Impoundment (SC Nov 7 Directive)
Objective	Long-term population stabilization, rabies control.	Short-term site clearance, perceived public safety.
Cost Profile	High one-time surgery/vaccination cost, low recurrent maintenance.	Massive capital construction + Perpetual, high recurrent daily cost (₹110+/dog).6
Sustainability	High, scientifically proven results (10% population decline).5	Low, prone to "Vacuum Effect" and inevitable budgetary collapse.
Infrastructure Needs	Small ABC centers for temporary post-operative care.	Massive, permanent custodial shelters (non-existent).

Section 4: The Humane and Ethical Imperative

Compliance with the SC directive, in its current interpretation requiring permanent relocation, represents not only a logistical failure but a profound ethical regression, undermining the very principles of animal welfare laid down in the ABC Rules.

4.1. The Compromise of Animal Welfare

Stray dogs develop social structures and exhibit high territorial fidelity. Their sudden, forced, and permanent removal from known environments causes severe psychological distress, leading to stress-related diseases and high morbidity rates in confinement. When shelters lack adequate capacity, the conditions quickly deteriorate. As civic officials in Chennai noted, the lack of facilities prevents them from accommodating large numbers of dogs outside ABC centers.¹³

When institutional capacity is overwhelmed, as is inevitable given the scale of the relocation mandate and the existing shelter deficit ², the resulting crowded and often unsanitary conditions fail to meet the "minimum kennel and staffing ratios" demanded by AWBI protocols.¹⁵ This failure transforms the intended solution into a massive, state-sponsored animal cruelty situation. Without operational details and concrete protocols, the humane intent of the court is lost in hurried, financially unviable compliance.¹⁵

4.2. The Scientific Failure: Inevitability of the Vacuum Effect

The most compelling scientific argument against permanent mass removal is the "Vacuum Effect." Removing established, neutered, and vaccinated dog populations from an area does not lead to a lasting reduction in density. Instead, the void in the territory is rapidly filled by new, often younger, unsterilized, and unvaccinated dogs migrating from surrounding areas.

This ecological phenomenon directly negates the years of investment and success documented in Karnataka.⁴ If neutered and vaccinated dogs are removed, the replacement population will be uncontrolled and carry a higher risk of rabies, thus actively increasing the public health hazard and necessitating perpetual, highly expensive clearance operations. The attempt to secure five institutional areas through mass removal is scientifically self-defeating and counterproductive to the long-term goal of population management.

4.3. Integrating Community Feeders and Designated Spots

Successful stray dog management, particularly within high-density urban areas, requires the integration of community involvement. Community feeders and animal welfare advocates are essential stakeholders, often performing the initial vaccination and care for dogs in their localities.⁸

AWBI guidelines mandate that local bodies, including municipal veterinary officers and resident welfare associations (RWAs), are required to designate feeding spots for stray dogs to ensure appropriate feeding practices.⁷ The reliance on relocation, which is viewed by local feeders as impractical and inhumane, risks antagonizing this crucial network.⁸ If local feeders withdraw cooperation, the government’s ability to conduct future ABC drives, which require community assistance for locating and capturing animals, will be critically hampered.

A policy of compassionate pragmatism requires pivoting the compliance strategy from impractical impoundment to effective perimeter control. The Supreme Court itself directed the fencing of government institutions to bar the entry of stray dogs.⁹ Leveraging this aspect of the ruling—the use of physical barriers—combined with utilizing designated, secured feeding areas outside the sealed institutional perimeters, offers a humane, sustainable, and legally supportable path forward.

Section 5: Strategic Compliance and Pragmatic Delay (The AWO Action Plan)

The immediate implementation of the relocation mandate carries an unacceptable risk of mass cruelty and financial insolvency. The only mechanism to ensure humane outcomes and logistical viability is to institutionalize a delay by insisting that all mandated legal and infrastructure prerequisites are certified before any mass physical removal occurs.

5.1. Strategic Objective: Institutionalizing the Delay through Diligent Compliance

The core principle guiding this strategy is the unwavering insistence that physical execution must be preceded by complete procedural correctness, as mandated by the Prevention of Cruelty to Animals Act and the Animal Birth Control Rules, 2023.¹⁴ Animal Welfare Organizations (AWOs) must leverage every procedural requirement—from certified staffing to certified infrastructure—to transform the rushed compliance timeline into a structured, long-term process. This ensures that the severe logistical and financial checks, which constitute the "difficulty of this" order, must be solved before a single animal is relocated permanently.

5.2. AWO Prerequisite Checklist for Humane Implementation (The Slow-Roll Strategy)

AWOs must demand that the Government of Karnataka publicly certify completion of the following phases, thereby acting as procedural checkpoints that guarantee a slow-roll compliance run only when all institutional and humane boxes are checked.

Phase of Compliance	Mandatory Action (Checklist)	Legal/Operational Justification
Phase I: Institutional Sealing	All five categories of institutional premises must submit architectural and administrative evidence of completed, dog-proof perimeter fencing or structural sealing. Verification must be conducted and certified by the Public Works Department (PWD) and local ULB officials.	Directly addresses the SC’s instruction for fencing 9; prevents frustration of the directive's purpose by ensuring animals cannot re-enter.
Phase II: Verified Dog Census	A detailed, scientifically rigorous census (e.g., sight-resight method) 5 must be conducted specifically for dogs within the five institutional premises. Data must include ID, neuter status, vaccination history, and be verified by an AWBI-nominated representative.	Required for accountability and accurate resource planning (AWBI Rule 12).14
Phase III: Shelter Capacity Certification	Designated permanent shelters for relocation must be constructed and independently AWBI-certified to meet the required capacity identified in Phase II before capture begins. Certification must verify quarantine kennels, functional operating theatres, power backup, CCTV, and minimum staffing ratios.	Mandatory compliance with AWBI facility and operational standards 7; precondition for humane permanent housing.
Phase IV: Financial Guarantee	The State must submit documented proof of a non-lapsable, ring-fenced budget covering the perpetual operating costs (feeding, medical, staffing) of the new shelters for a minimum of five years, verified by the Finance Department.	Addresses the fundamental difficulty of budget execution and ensures long-term sustainability for custodial care.6
Phase V: Relocation Protocol	A written protocol must be established ensuring that each dog receives a final health examination, is microchipped, and has its complete record file (including capture location and health status) transferred to the new shelter prior to relocation.	Ensures transparency, traceability, and adherence to record maintenance mandates (Rule 12).14

5.3. AWO Action Points

Animal welfare stakeholders must focus their efforts on meticulous documentation. Any deviation from the AWBI standards in Phases I through V must be documented and immediately utilized to file contempt applications or request judicial intervention, advocating for the temporary suspension of mass relocation efforts until humane compliance is guaranteed.

AWOs should actively support and monitor Phase I (fencing) as the most effective and humane compliance measure. By collaborating with institutional management to install and verify high-quality physical barriers, the AWOs directly implement a portion of the SC’s directives while simultaneously preventing the need for traumatic, mass impoundment, transforming the directive from a relocation crisis into a permanent boundary management solution.

Section 6: Policy Recommendation: Advocating for a Revised Directive

Given the proven scientific success of the Karnataka ABC model and the insurmountable financial and logistical constraints of the mass impoundment mandate, the responsible course of action for the Government of Karnataka is to seek a modification of the "no release back" clause through the Supreme Court.

6.1. Rationale and Procedure for Filing an Affidavit

Filing a detailed affidavit is not an act of non-compliance but a necessary legal mechanism to inform the judiciary of the severe, unintended consequences and execution difficulties arising from the order, especially in a state already adhering successfully to the scientific model. This submission is essential given the threat of Chief Secretaries being held personally responsible for non-compliance.¹

The affidavit must be a solemn statement, typically sworn by the Chief Secretary or Principal Secretary of the Animal Husbandry or Urban Development Department. The procedure requires the state to outline the detailed execution difficulties encountered in attempting to comply with the directive, utilizing factual data and financial modeling.¹⁷ Such an affidavit must be structured to respectfully request a review and revision of the specific clause mandating permanent relocation.

6.2. Key Arguments for the Affidavit Structure

The affidavit must rigorously integrate the findings of this report to form three core arguments:

1. Argument of Proven Success: The affidavit must commence by submitting the quantitative BBMP data (as detailed in Table 1), unequivocally proving that the existing ABC framework in Karnataka is effective, achieving population decline, and maintaining high vaccination coverage.⁴ This challenges the fundamental assumption that the CSVR model has failed and necessitates punitive measures.

2. Argument of Financial and Logistical Collapse: The submission must present the perpetual, non-recurrent cost analysis (as detailed in Table 2), projecting the financial crippling necessary to maintain permanent shelters for the requisite number of animals.² It must detail the insurmountable capacity gaps regarding land acquisition, shelter construction, and the inability to staff hundreds of facilities with AWBI-certified professionals.⁷

3. Argument of Public Health Detriment: The affidavit must clearly explain the scientific inevitability of the Vacuum Effect. It should articulate that forced mass impoundment will actively destabilize the neutered population, reintroduce unvaccinated dogs, increase rabies risk, and therefore directly frustrate the court’s underlying public safety goals.

6.3. Proposed Revised Directive: A Compassionate and Pragmatic Solution

The Government of Karnataka should respectfully request the Supreme Court to approve a revised strategy that focuses on prevention through physical barriers rather than perpetual, financially impossible custody:

1. Primary Focus on Perimeter Management: The state should request that the judicial compliance benchmark be shifted to the successful execution of dog-proof fencing and sealing (Phase I) of the five institutional premises.⁹ This action secures public safety by physically separating humans and animals without compromising the ABC program.

2. Targeted Permanent Removal: Permanent removal to dedicated, empanelled shelters should be strictly limited only to dogs exhibiting confirmed clinical rabies or documented, habitual, unprovoked aggression, as provided for under existing ABC Rules.³

3. CSVR Principle Maintained: All other captured dogs (sterilized and vaccinated) must be returned to designated, demarcated feeding spots established outside the newly sealed institutional perimeters, thereby maintaining the territorial stability necessary to prevent the Vacuum Effect and preserving the successful outcome of the state’s ABC investment.

Section 7: Conclusion: Policy, Pragmatism, and the Path to Humane Governance

The Supreme Court’s November 7, 2025, directive correctly highlights the imperative of securing public institutional spaces. However, the mandatory "no release back" clause imposes a financial and logistical burden on the State of Karnataka that is impossible to meet humanely or sustainably. The requirement of permanent relocation stands in direct contradiction to Karnataka’s successful, science-based model of dog population management, which has yielded demonstrable results in population decline and rabies control.⁴

Uncritical, hurried compliance with the relocation mandate would divert critical resources, cripple state budgets, and ultimately lead to widespread animal suffering due to inadequate shelter capacity and staffing deficits. This outcome would undermine years of public health progress and investment.

The pathway forward demands a sophisticated, evidence-based response. The immediate filing of a comprehensive affidavit, meticulously detailing the logistical constraints and the high probability of public health regression, is the state’s most responsible legal and fiduciary action. Simultaneously, Animal Welfare Organizations must utilize the structured Prerequisite Checklist to ensure that any execution of the order proceeds at a pace dictated by certified humane capacity, effectively institutionalizing a necessary delay. Success for Karnataka lies not in blind adherence to an unfeasible directive, but in transforming the judicial requirement from a costly, cruel relocation crisis into an effective, sustainable infrastructure and boundary management solution based on the state’s existing, proven success.

Works cited

1. People stage protest at India Gate over SC's order to remove stray dogs from hospitals, schools, railways and bus stations, accessed on November 16, 2025, https://www.aninews.in/news/national/general-news/people-stage-protest-at-india-gate-over-scs-order-to-remove-stray-dogs-from-hospitals-schools-railways-and-bus-stations20251109215321

2. Remove strays from public places, top court tells states | India News, accessed on November 16, 2025, https://www.hindustantimes.com/india-news/remove-strays-from-public-places-top-court-tells-states-101762540647328.html

3. Supreme Court Orders Relocation of Stray Dogs from Public Premises, accessed on November 16, 2025, https://vajiramandravi.com/current-affairs/supreme-court-orders-relocation-of-stray-dogs-from-public-premises/

4. Bengaluru leads with robust stray management - Bangalore Mirror, accessed on November 16, 2025, https://bangaloremirror.indiatimes.com/bangalore/others/bengaluru-leads-with-robust-stray-management/articleshow/123311876.cms

5. Bengaluru has nearly 3 lakh stray dogs, 10% lower than 2019: Survey, accessed on November 16, 2025, https://m.economictimes.com/news/bengaluru-news/bengaluru-has-nearly-3-lakh-stray-dogs-10-lower-than-2019-survey/articleshow/104188852.cms

6. Relocating stray dogs may cost Delhi's civic bodies ₹11 crore every day, ₹110 daily on each animal - Hindustan Times, accessed on November 16, 2025, https://www.hindustantimes.com/india-news/relocating-stray-dogs-may-cost-delhis-civic-bodies-rs-11-crore-every-day-101755130181469.html

7. Delhi Government Issues Strict Guidelines For Street Dog Management, Rabies Control And Safety - Swarajya, accessed on November 16, 2025, https://swarajyamag.com/news-brief/delhi-government-issues-strict-guidelines-for-street-dog-management-rabies-control-and-safety

8. After SC order: PMC to reassess stray dog management, feeders call for humane approach, accessed on November 16, 2025, https://indianexpress.com/article/cities/pune/after-sc-order-pmc-reassess-stray-dog-management-feeders-10364172/

9. Stray dog case hearing highlights: SC orders removal of stray dogs from schools, hospitals and other public institutions - The Hindu, accessed on November 16, 2025, https://www.thehindu.com/news/national/stray-dog-case-supreme-court-hearing-live-updates-november-7-2025/article70251255.ece

10. Karnataka amends KPME Act to mandate emergency care for dog ..., accessed on November 16, 2025, https://www.thehindu.com/news/national/karnataka/karnataka-amends-kpme-act-to-mandate-emergency-care-for-dog-snake-bite-victims/article70284596.ece

11. BBMP calls for tenders to feed 4000 stray dogs one meal a day in Bengaluru city, accessed on November 16, 2025, https://www.thehindu.com/news/cities/bangalore/bbmp-calls-for-tenders-to-feed-4000-stray-dogs-one-meal-a-day-in-bengaluru-city/article69797532.ece

12. BBMP launches Rs 2.88-cr plan to feed chicken, rice to 5k stray dogs - Deccan Herald, accessed on November 16, 2025, https://www.deccanherald.com/india/karnataka/bengaluru/bbmp-launches-rs-2-88-cr-plan-to-feed-chicken-rice-to-5k-stray-dogs-3625080

13. GCC delays action on stray dog menace despite complaints, accessed on November 16, 2025, https://timesofindia.indiatimes.com/city/chennai/gcc-delays-action-on-stray-dog-menace-despite-complaints/articleshow/125281596.cms

14. Animal Law Handbook For Urban Local Bodies, accessed on November 16, 2025, https://awbi.gov.in/uploads/regulations/174073563011ULB_HandBook.pdf

15. Supreme Court's latest order keeps stray dog issue on a short leash, accessed on November 16, 2025, https://www.scobserver.in/journal/supreme-courts-latest-order-keeps-stray-dog-issue-on-a-short-leash/

16. SC's stray dog relocation plan sparks debate, activists warn of challenges in implementing directive | Guwahati News - The Times of India, accessed on November 16, 2025, https://timesofindia.indiatimes.com/city/guwahati/scs-stray-dog-relocation-plan-sparks-debate-activists-warn-of-challenges-in-implementing-directive/articleshow/125190819.cms

17. Rules of Practice - Supreme Court of Ohio, accessed on November 16, 2025, https://www.supremecourt.ohio.gov/docs/LegalResources/Rules/practice/rulesofpractice.pdf

18. Guide to Filing IFP Cases - Supreme Court, accessed on November 16, 2025, https://www.supremecourt.gov/casehand/guideforIFPcases2019.pdf