Abstract
In 2024, over 37 Lakh incidents of Dog Bites in India were reported, primarily due to stray dogs with the result that 54 persons died from rabies. Surely this is a public health crisis. The Municipality’s fragile health infrastructure and its failure to provide a prompt and appropriate medical responses has aggravated ethical tension between animal rights and human safety issues and exposed the inadequacies in the system. The present Article analyses India’s medico-legal framework for dog bite cases from various perspectives, including ethical, statutory and judicial. The present Article also looks at the legal framework, comprising the Prevention of Cruelty to Animals Act 1960, the National Guidelines for Rabies Prophylaxis, 2019, the Animal Birth Control Rules, 2023 and the Bharatiya Nyaya Sanhita (BNS) 2023. Relying on government data and scientific research, this article considers the management of dog bite cases and compares them and with global best practices, for example, the Netherlands’ CNVR policy on the management of stray dogs in the area of public health.
Introduction
A stray dog recently bit a 7-year-old girl, who died from rabies even though she had been vaccinated. 1 In another case, Indian Kabaddi player- Brijesh Solanki was infected with rabies by a puppy’s scratches when he was rescued from a drain on 28th May 2025. He had died by the end of June 2025. 2 Nobody was held accountable. Is there, a looming public health disaster in India? In June 2025, in Kozhikode (Kerala), more than 50 stray dogs, suspected of having been bitten earlier by stray dogs infected with rabies, were put under observation at the Animal Birth Control (ABC) Centre. It was also suspected that stray dog(s) had bitten 19 people on June 24, 2025. In 2024, 3,715,713 dog bite cases were reported in India with 54 rabies-infected deaths. 3 Rabies is a preventable disease. Despite having National Guidelines for Rabies Prophylaxis, 2019, and comprehensive Animal Birth Control Rules (ABCR) 2023 in place, India is responsible for 36% of global rabies deaths. 4
The medico-legal issues concern pre-emptive justice, the responsibility and accountability of the municipalities concerned, the role and safety of health care workers and hospitals. Complicated public health initiatives (NRCP), 5 have made it challenging to control dog bite cases; there is unstructured civic engagement and no enforceable duties on municipalities who should provide (i) urgent medical attention and (ii) raise public awareness. The regulatory vacuum and institutional neglect need to be examined with the assistance of three analytical lenses, that is, (i) medical preparedness, (ii) legal responsibility to ensure accountability in ‘dog bite incidents’ and (iii) ethical responsibility, based on best global practices, and, judicial pronouncements.
Epidemiology of dog bites in India
The growing number of cases of dog bites challenges India’s goal of becoming rabies-free by 2030 (NAPRE). 6 The Lancet, in 2024, noted that India accounts for 35% of all human deaths from rabies, which is the highest in Asia (59.9%), 7 with vaccination rate for dogs only 79.6%.
Mumbai’s (India) KEM Hospital’s research recorded firstly that most dog bite victims are from the lower strata of society. Secondly, 56% of dog bite cases involved children under 15. Thirdly, 30% of patients medical care was delayed by more than 24 hours. Fourthly, victims have inadequate access to the rabies post-exposure prophylaxis (PEP), a chronic problem, affecting the efficacy of government-run hospitals. 8 Dog attacks also cause various types of physical injuries, such as (a) deep lacerations, (b) nerve damage and (c) severe infections, which often need urgent hospitalisation and frequently result in multiple surgeries. Long-term psychological trauma has also been reported, including (a) post-traumatic stress disorder (PTSD) (b) anxiety and (c) depression (mostly in vulnerable victims, such as, women, children and people with disabilities (PwDs)). These epidemiological patterns indicate that firstly, failure to provide a prompt medical response and effective treatment to the victims of dog bites, and, secondly, to systemic governance failure, both in controlling and preventing rabies.
Legal framework in bridging public health by tackling dog bites and animal rights
Civil and criminal provisions
Sections 117 (Negligent act likely to spread infection of disease dangerous to life) and 118 (Malignant act likely to spread infection) of the Bharatiya Nyaya Sanhita 2023 cover the offences of spreading the infection of disease, with minimal scope. It remains unambiguous as to how ‘knowledge’ or ‘malignancy’ would be proved in cases of death by rabies.
The Court in Bibhuti Charan Mohanty’s 9 held Pune municipality liable and directed them to pay rupees ten lakh for a child’s death caused by a stray dog’s attack, as they were negligent in providing the required degree of care and caution. In Anupam Tripathi, 10 case, the Supreme Court examined the provisions of (i) Prevention of Cruelty to Animals Act, 1960 (PCA) and (ii) Animal Birth Control (Dogs) Rules, 2001 and, constituted a committee to maintain, (i) dog-bite complaints (nature and gravity of injuries), (ii) availability of medicines in hospitals, (iii) the treatment administered to such patients, (iv) the failure of such treatments, (v) list of cured victims and (vi) the list of fatal cases and reasons for their death. The Orissa High Court broadened the scope of institutional negligence in the Jaladhar Jena 11 case by referring to Anupam Tripathi’s case. It held that institutions such as schools and municipalities are accountable for inaction and delay in treating injuries. The case also asks for a robust medical response, besides strengthening the compensatory jurisprudence in India, and it has also developed higher accountability by addressing the need for ‘medical protocols’, ‘mandatory training’ and the ‘faster medical referral systems’ at the hospitals.
Dog bite jurisprudence and the paralytic municipal governance
India is committed to ‘animal protection’, which is codified in various statutes including the PCAA 1960 and the Animal Birth Control (Dogs) Rules (ABCR, 2023). The Catch–Neuter–Vaccinate–Release (CNVR) model is provided under Rules 3, 8 and 9 of the ABCR 2023, which legally provide for, controlling and managing the ‘community dog’ population, and for ensuring (i) rabies immunisation, and (ii) sterilisation, by establishing monitoring committees at the local level, but, all these programmes are underfunded and inadequately monitored.
Medico-legal ethical tensions: Standard of care and bio-medical ethics and difficult boundaries
Medical practice (bioethical principles)
The medical practice revolves around the bioethical principles of (i) beneficence, (ii) non-maleficence, (iii) justice and (iv) autonomy. In case of animal bites, the beneficence principle demands an urgent medical intervention, which is inclusive of, firstly, wound debridement, secondly, tetanus toxoid administration and thirdly, rabies post-exposure prophylaxis (PEP). Similarly, the principle of Non-maleficence is essential, as it is a norm, for avoiding the causation of harm, 12 but at present, most health infrastructure facilities lack, (most importantly), intradermal or intramuscular rabies vaccines, which leads to delayed and incomplete immunisation of dog bite victims. Medical practitioners have to choose between the competing treatment options and governments implementing public health measures, specifically when they affect vulnerable populations. Concept of justice is central whenever it comes to vulnerable persons (women, children, PwDs, etc.), who struggle to access even the category I or II medical care in cases of animal bite (dog) protocols (prepared as per the WHO Rabies Exposure Guidelines). In India, hospitals lack the logistical support for maintaining the mandatory ‘cold chain protocols’, resulting in the loss of vaccine’s efficiency. The medicine ‘polyvalent anti-rabies immunoglobulin (RIG)’, also known as, ‘rabies immune globulin’ is often not available in the major district hospitals of India, despite it being termed as necessary for the category III bites, which involve (i) transdermal skin breaches (ii) bites to the face, hands and neck or (iii) bleeding. A survey conducted at 467 public health centres, the Community Health Centres, district hospitals and the medical colleges of the states, across the 60 districts in the 15 states of India by the Indian Council of Medical Research (ICMR) – National Institute of Epidemiology (ICMR-NIE), it found that only 20% stocked RIG. 13 Medical professionals also face ethical challenges when certifying the risk of rabies, particularly when the stray dog is untraceable or its vaccination history is missing. India, which has adopted the National Guidelines for Rabies Prophylaxis, 2019, suffers from, poor ground-level implementation, unequal access to vaccines and inadequate integration with public health and animal control laws, which compromises their effectiveness. The respect for autonomy, in dog bite management, requires victims to be medically counselled, to make ‘informed choices’ regarding the PEP.
The legal and psychological impact on victims
Dog bite victims receive compensation only sporadically, and even fewer cases result in a criminal prosecution. The victim’s physical wounds range from (i) avulsion injuries and (ii) muscle laceration, to (iii) fractures and (iv) nerve injuries, and often require a prolonged period for rehabilitation and frequently, may need plastic surgery or reconstructive grafting. Besides this, there are psychological injuries, such as (i) trauma-induced anxiety, (ii) phobia and nightmares and sometimes it may also lead to depression, whereas such psychiatric disabilities are not subject to compensatable harm, which further marginalises these victims. The proliferation of stray dogs is checked through sterilisation, but this is well below the 70% threshold.
Global best practices
The Netherlands has a global ‘zero stray dog’ tag by simply following the CNVR model. Their key legal innovation includes, (1) stringent anti-abandonment laws, with huge penalties (up to €16,750) and imprisonment, (2) mandatory registration of dogs with microchips to identify ownership, (3) imposing heavy taxes on dog breeders and huge subsidies on adopting the dogs and (4) developing a tailor-made ‘veterinary infrastructure’ to enable timely sterilisation and vaccination. There is a centralised regulatory regime to achieve (i) municipal enforcement, (ii) partnership and active engagement with civil societies and (iii) legal deterrence. This way, dogs’ dignity will not be compromised, which aligns with the European Convention for the Protection of Pet Animals, 1987. The principles of municipal accountability and disincentivising over breeding of dogs can be adopted as a policy measure based on the Netherlands Dog Policy, to assist with developing transparency in dog control practices, as this is consistent with Articles 243W, 47 and 48A of the Indian Constitution.
Since 1990, Sri Lanka has reduced its annual rabies death rate by 95% by initiating the ‘National Rabies Control Programme’ whereby mass dog vaccination was done and weekly sterilisation camps were established. An innovative and proactive school education programme was also launched on the basis of legal mandates for the animal birth control integrated with the public health law. Unlike India’s decentralised ABC Rules 2023 model, Sri Lanka employed a single-agency vertical structure, which allows for (i) consistent implementation and (ii) data monitoring.
Conclusion and suggestions
A proactive legal-medical-policy is needed to ensure (i) constitutional morality, (ii) bio-medical ethics and (iii) enforceable obligations.
Dedicated central legislation
India can legislate by passing the constitutional imprimatur of Article 21 (Right to Life), Article 47 (Public Health), Article 48A (Environment Protection) and Article 243W (Municipal Functions) of the Indian Constitution, by firstly, harmonising the municipal laws with the constitutional duties prescribed under Articles 47 and 243W of the Indian Constitution and secondly, by carrying out mandatory digital registration of all stray dogs by using microchips and also by issuing customised legal ID tags for all their feeders in the public places. Thirdly, a ‘National Rabies Compensation Fund’ should be established, similar to Sri Lanka’s Dog Bite Victim Scheme. Fourthly, dog abandonment can be formed as a separate cognizable offence under the BNS, 2023; it is essential to ensure minimum standards for the upkeep of (i) dog shelters and (ii) the sterilisation centres.
Strengthening the medical response protocol
India has already adopted the ‘National Guidelines for Rabies Prophylaxis’, by integrating it with the WHO’s 2023 guidelines. It is essential that private medical practitioners should first adopt mandatory medico-legal reporting training for dog bite management. Secondly, there has to be a provision for maintaining the digital tools for inter-hospital data sharing on the PEP delivery and immunoglobulin stock, coupled with (i) funding for cold chain maintenance, (ii) rural vaccine access and (iii) community awareness campaigns on early wound management. A dog bite registry should be established and include (i) Compensation for the inverse disbursal and (ii) Medical response timelines. This would mirror the Maternal Death Surveillance and Response (MDSR) system, reframing dog bite deaths as a preventable public health concern, not to be regarded as fate or neglect, but as a statutory mandate.
India can become rabies-free by 2030, but to achieve this goal, as envisioned in the National Action Plan, the judiciary, legislature and medical community must act together. The bite of injustice must be neutralised through constitutional compassion, medico-legal clarity and ethical resolve.
Footnotes
Declaration of conflicting interests
The author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.
Funding
The author received no financial support for the research, authorship, and/or publication of this article.
Ethical considerations
This article does not contain any studies with human or animal participants.
