The recent directions of the Supreme Court of India concerning the management of stray dogs have generated intense discourse across the country. The operative concern has centred on safeguarding citizens, particularly children and the elderly, from dog-bite incidents and rabies-related fatalities. In “In Re: City Hounded by Strays, Kids Pay Price”, the Court exercised its extraordinary jurisdiction to examine the nationwide implications of unchecked stray dog populations, issuing wide-ranging interim directions. The order dated: 22 August, 2025 clarified that sterilised and vaccinated dogs must ordinarily be released back into their areas, while aggressive or rabies-suspected dogs must be segregated in dedicated shelters. Furthermore, all States and Union Territories have been directed to report their compliance levels with the Animal Birth Control Rules 2023.
While the judicial intent has been to harmonise public safety with humane treatment, the impact of such directions varies across regions. Goa, with its distinctive demographic, spatial and ecological attributes, faces a different reality from metropolitan environments where dog-bite incidents are significantly higher and stray populations more concentrated. Any regulatory mechanism imposed within Goa would have to respect constitutional equality under Article 14 and the mandate under Article 48A to protect the environment and its biodiversity.
Goa’s ecological setting
Goa’s settlement patterns differ considerably from the dense urban agglomerations that motivated the Supreme Court’s original intervention. The State is characterised by mixed rural–urban land use, interspersed ecological corridors, and large tracts of tree cover within residential settlements. Human habitation has historically coexisted with free-roaming cats, dogs, pigeons, squirrels, crows, monitor lizards, mongooses, and occasional rat snakes.
Rapid urbanisation, however, has driven major alterations in land patterns. Construction-led habitat destruction has displaced numerous species, pushing them into human-dominated zones. To view the issue solely through the lens of canine management would overlook the broader ecological pressures that contribute to shifts in animal behaviour.
Goa’s governance structure
The existing Supreme Court directions emphasise municipal responsibility for feeding zones, dog pounds, sterilisation infrastructure, and helplines. Yet, Goa’s governance structure includes both Municipal Councils and Village Panchayats operating across diverse geographic scales. Many inhabited areas with high animal–human interaction fall under Panchayat jurisdiction where municipal-style infrastructure is absent. A uniform mandate requiring dog pounds or sterilisation vans at municipal levels may therefore be impracticable without State-level augmentation.
Further, Goa’s population density varies starkly high in urban pockets like Margao, Vasco and Panaji, but significantly lower in villages such as Loliem, Korgao or Verna. A stray animal management strategy for Goa must be calibrated to such variations. Areas of high human footfall markets, beaches, school zones, bus stands and tourist hubs require buffer mechanisms different from those in low-density or forest-adjacent zones.
Constitutional duties
The constitutional scheme requires equilibrium. Article 21 protects the right to life and personal safety for all citizens; however, the Supreme Court has consistently held that animals are entitled to dignified treatment. Decisions such as Animal Welfare Board of India v. A. Nagaraja recognised animals’ intrinsic value, emphasising the obligation of the State under Articles 48A and 51A(g). Therefore, any State-devised framework must avoid cruelty to animals while ensuring citizen safety.
Stray dogs, cats, cows, pigs, monkeys and other free-roaming species in Goa constitute part of an intricate ecological interplay. Goa’s strategy must therefore integrate broader animal-management SOPs instead of regulating dogs in isolation. Exclusive dog-centric policymaking, without accounting for associated species, would fail the constitutional requirement of non-arbitrariness under Article 14.
Scientific SOPs needed
Goa requires a comprehensive State-specific Standard Operating Procedure (SOP) that addresses:
1. Population assessment of all free-roaming species, not limited to dogs.
2. Identification of high-footfall zones such as beaches, school routes, temples, markets and hospitals.
3. Buffer zones in tourist-heavy regions to reduce human–animal conflict.
4. Habitat impact analysis, including deforestation and construction-driven displacement.
5. Panchayat–municipal coordination, to align responsibilities across jurisdictions.
6. Feeding regulation, ensuring that animal caretakers act within safe, designated areas.
7. Sterilisation logistics, which must account for Goa’s smaller but widespread settlements.
8. Non-cruel segregation for aggressive or rabies-suspected animals, as mandated by the Supreme Court.
Such an SOP must be anchored in data, science, biodiversity norms and constitutional duties, not mere replication of urban models unsuited for Goa’s social geography.
Supreme Court’s clarifications
The Supreme Court’s August 2025 directions, later supplemented by the orders reported on 7 November, 2025, recognise that sterilisation and vaccination must remain the principal long-term solution, and that municipal bodies must prepare compliance reports detailing infrastructure and personnel. The clarification that treated dogs must ordinarily be released back into their locality except when aggressive or infected indicates judicial awareness of ecological continuity and logistic practicality.
However, the nationwide application of these directions necessitates State-wise contextualisation. The order expressly calls for each State to submit detailed data on compliance with ABC Rules, thereby leaving scope for region-specific models that accommodate differing demographic, ecological and infrastructural realities.
