[Vol 3/ Issue 2/ March 2018] [ISSN 2394-9295]

Shivani Jain

B.Com. LL.B(H)

Email id:


“Jallikattu- from a necessity to a sport and business”

With the beginning of up-to-date agricultural tools, the usage of Bull throughout the course of farming has come down. Contemporary tractors and cultivating machines do the work more efficiently as they are run by energy and motor power. But this old age custom of taming the Bull did not end. In the olden times, Jallikattu Bulls were not as violent as we see nowadays.

In the olden days, the Bull was unwilling to come back and work therefore, it would be at ease to encourage the Bull. Nowadays, as the ‘custom’ became commercial, more violent the Bull you train, more cash you get. To level up the fierceness of the Bulls, public started feeding liquor and other sedative drugs. Animals are susceptible, defenceless and are controlled by persons. For persons who overlook the animal welfare must need to be held accountable for breaching the regulations of animal rights. 

This paper will talk about the recent judgment on Jallikattu along with various other judgments on Animal welfare. Similarly, in this paper an attempt is made to find out the areas where there is a need of animal welfare and the defects in the government schemes for animals. As our main idea is to protect and safeguard animals, the mindset of society towards animals needs to be amended. As Human shaped our human rights and it is only us that practices this notion. Humans needs to have the duty to set parameters for animal rights. The growth of rights for our animals should be an actual and a conceivable idea that can lawfully be observed at.

Keywords– Jallikattu, animal welfare, Judgements, Ban, Defects.


The Jallikattu judgment (Animal Welfare Board of India v. A. Nagaraja and Ors) is a historic point late judgment where the Supreme Court of India held for the privileges of the animals breaking all the religious, conventional boundaries and restricted the substantial scaled routine with regards to bull cart racing in the southern territory of India i.e. Tamil Nadu in spite of the repugnance ( i.e. in struggle or contrary with) on the concerned issue between arrangements of the State Act i.e. the TNRJ Act (Tamil Nadu Regulation of Jallikattu Act, 2009) and the Central Act i.e. the PCA Act. Furthermore, this judgment was valued by numerous animal welfare associations everywhere throughout the world. This was an extraordinary noteworthy judgment mirroring the still, small voice of the legal of India and lawful framework toward the issues of animal welfare.

“Justice Radhakrishnan stressed the point that until now the rights that we as a nation bestowed upon animals were merely statutory rights and the time had come for animal rights to be elevated to the status of fundamental rights in the Indian constitution. All animals, all living beings have the right to five freedoms:

1. Freedom from hunger, thirst and malnutrition;

2. Freedom from fear and distress;

3. Freedom from physical and thermal discomfort;

4. Freedom from pain, injury and disease; and

5. Freedom to express normal patterns of behavior”[2]

These five freedoms, as indicated, are the fundamental principles of animal welfare.[3] This judgment had given again before the entire country that there are needs that are required for the welfare of animals. This judgment can be said to be having the capacity to be the wellspring of a merciful society.

“The court spoke of how this uncivilized event violates the Prevention of Cruelty to Animals Act (PCA) and militates the constitutional duty of treating animals with compassion, art 51 A (g). It also reiterated the expansive reading it had given in the past, to art 21 (Right to Life), which prohibits any disturbance to the environment, including animals, considered essential for human life. And the apex court went well beyond and delivered a judgment that essentially upholds the right to a dignified life for all animals. Any law that attempts to reverse this carefully evolved jurisprudence cannot stand the test of constitutional propriety”[4]

“Even bulls have rights against torture, the Supreme Court observed on Wednesday as it banned ‘Jallikattu’ (bull fighting) and bullock cart racing in Tamil Nadu. The court also banned bullock cart racing in Maharashtra. A Bench of Justices K.S. Radhakrishnan and Pinaki Chandra Misra said, “Forcing a bull and keeping it in the waiting area for hours and subjecting it to the scorching sun is not for the animal’s well-being. Forcing and pulling the bull by a nose rope into the narrow, closed enclosure or ‘vadi vassal’ (entry point), subjecting it to all forms of torture, fear, pain and suffering by forcing it to go the arena and over-powering it in the arena by bull tamers, are not for the well-being of the animal.”[5]

“The Bench said the Animal Welfare Board of India had given details on the way the bull fight was conducted across Tamil Nadu. It said the torture and cruelty meted out to the bulls was unimaginable. “Being dumb and helpless, they suffer in silence. We notice that the situation is the same in Maharashtra too.”[6]

Tamil Nadu assembly passed the bill that overturned the Supreme Court ban on bull-taming sport Jallikattu as week-long demonstrations turned violent in Chennai.[7] The Reason behind such act was to control the situation of Chaos in Tamil Nadu. People of started protesting and setting fire to vehicles. Actor Kamal Haasan came out in support of the protesters, saying “aggressive police action on students’ passive resistance will not bear good results” and urged protesters not to resort to violence.[8]



Humane Society International/India lists judgements passed by India’s courts that strengthened animal law and mitigated animal abuse and suffering.

  1. People for Ethical Treatment of Animals Vs. Union of India

A film wishing to use an animal needs to obtain a No Objection Certificate from the Animal Welfare Board of India as pre-requisite for certification from the Central Board for Film Certification: Bombay High Court.

In 2006, the Bombay High Court passed an important ruling, wherein any film meant for public viewing, in which an animal is used and/or filmed, has to obtain a certificate from the Animal Welfare Board of India, stating that the provisions of the Performing Animals (Registration) Rules, 2001 have been duly met. This ruling safeguard animal from being exploited or ill-treated during the period of film making, which can extend across several hours. The ruling prevents animals from, among other abuses, being exposed to loud, strange sounds, beaten or kept without food and water

  1. State of U.P Vs. Mustakeem and Ors

Custody of animals, in cases of cruelty, shall not be given to the accused but to the nearest gaushala or pinjrapole, until the conclusion of the trial: Supreme Court

In the state of Uttar Pradesh, in a case where goats were found to be transported for slaughter in a cruel manner (they were tightly bound to each other, which was against the provisions of the Prevention of Cruelty to Animals Act, 1960), an FIR was filed against the owner. However, the UP High Court returned custody of the animals to the owner while the matter was under litigation. On appeal, the Hon’ble Supreme Court declared that the animals were supposed to be confiscated from the owner and housed in a gaushala, under the care of the state government who was given their charge for the duration of the case. With this ruling, the Court made it amply clear that once an animal was removed from a person’s care on grounds of cruelty to his/her charge, the animal would not be returned until the case was resolved.

  1. GauriMaulekhi Vs. Union of India and Ors

Strict implementation of prohibition of cattle smuggling across the border for Gadhimai animal sacrifice in Nepal. Additionally, several welfare recommendations shall be adopted: Supreme Court

In 2014, the Hon’be Supreme Court banned the illegal transport of cattle to Nepal for the Gadhimai festival, which played an important role in bringing down the number of animals sacrificed that year. Prior to this, the SahastraSeemaBal worked with the petitioner to draft a set of regulations related to animal markets, cattle markets and creating infrastructure for cattle, thus creating a set of recommendations that the court certified. In passing the order, the Supreme Court declared that these recommendations would have to be adopted.

  1. Nair, N.R. and Ors. Vs. Union of India and Ors

Bears, monkeys, tigers, panthers and lions shall not be trained or exhibited as performing animals: Kerala High Court

The Kerala High Court upheld a notification by the Ministry of Environment and Forests stating that bears, monkeys, tigers, panthers and lions shall not be exhibited or trained as performing animals. When the notification was challenged in the Supreme Court, the court declared that animals suffer cruelty as they are abused and caged to make them perform, and therefore, this contravenes the PCA Act, 1960. It also dismissed the argument that the petitioners’ right to carry out any trade or business under art 19(g) of the Indian Constitution was violated as those activities that caused pain and suffering to the animals would not be allowed.



Various initiatives taken by government, animal activists, NGOs etc. have resulted in prohibition of cruel practices towards animals. It indeed feels proud to know that India is South Asia’s first “Cruelty-Free Zone”. From banning the import of animal-tested cosmetics to stopping the use of dolphins for entertainment, India is indeed blazing the trail by setting an example for other countries to follow.[10]

Following are some of them-

  1. Ban on Captive Dolphin Shows[i]

In May 2013, India’s Ministry of Environment and Forests took a strong step by forbidding the capture and use of dolphins for entertainment across the country.

The ministry issued a policy statement instructing all state governments to deny giving permissions for setting up a dolphnarium “by any person / persons, organizations, government agencies, private or public enterprises that involves import, capture of cetacean species to establish for commercial entertainment, private or public exhibition and interaction purposes whatsoever.”

  1. Ban on shipment of shark fins by Jet airways in its carriers-

Jet Airways, after taking Humane Society International/India’s appeal into consideration, banned shipment of shark fins on its carriers to protect the declining population of sharks worldwide.[ii]It is noteworthy that during 1981-2002, India was responsible for 9% of the global catch of various shark species and was ranked third worldwide in the list. Every year, hundreds of sharks are targeted and killed to meet the demand for shark fin soup, an East Asian dish. After removing the fins, the sharks are thrown back into the sea to die.

  1. Ban on illegal movement of animals to Nepal-

On November 04, 2014, the Ministry of Home Affairs ordered the paramilitary SashastraSeemaBal to stop illegal movement of animals to Nepal and prevent cattle transport without license.[iii]

The decision was announced just a few weeks before the Gadhimai festival n which over 500,000 animals were to be sacrificed in Nepal. The festival takes place once every five years and involves brutal slaughter of lakhs of innocent animals including cattle, pigs, goats, ducks, rats, etc.

According to an estimation 70 percent of the animals brought for slaughtering in Gandhimai festival come from the states of Uttarakhand, Sikkim, Jharkhand, Assam, Bihar, Uttar Pradesh etc.

  1. Nationwide Restriction on Slaughter of Buffaloes, Camels and Cows[iv]

The environment ministry on May 23, 2017 notified the stringent ‘Prevention of Cruelty to Animals (Regulation of Livestock Markets) Rules, 2017‘, issued under the Prevention of Cruelty to Animals Act. The new rules define ‘cattle’ to include “a bovine animal including bulls, cows, buffalos, steers, heifers and calves and includes camels.”[v]

  1. Other provisions under these rules[vi]

These also bar people from lifting an animal off the ground, other than poultry for weighing propose, dragging it along the ground, suspending it clear of the ground or tie up or muzzle any calf among others.

According to the notification, the member secretary of an animal market committee will have to ensure that no person brings a young animal to the animal market. “No person shall bring some cattle to an animal market unless upon arrival he has furnished a written declaration signed by the owner of the cattle – stating the name and address of the owner of the cattle, with a copy of the photo identification proof.

“Giving details of the identification of the cattle and stating that the cattle has not been brought to market for sale for slaughter,” the notification said under the point ‘Restrictions on sale of cattle’. In the past, rumours of cow slaughter and the sale of beef have triggered violence in parts of the country.

The rules envisage the constitution of district animal market monitoring committee and an animal market committee. “Cruel and harmful practices shall be prohibited, namely animal identification methods such as hot branding and cold branding, shearing and painting of horns, bishoping in horses and ear cutting in buffaloes. “Casting animals on hard ground without adequate bedding, forcing animals to perform any unnatural acts, such as dancing, putting any ornaments or decorative materials on animals, use of any type of muzzle to prevent animals from suckling or eating food and others,” the notification said.

  1. Blind Elephant prevented from parading in Ernakulam

The elephant is banned from parading as it is partially blind and as per the elephant parade rules, it is unlawful to parade blind elephants.[vii]

  1. UGC bans use of animals for research in laboratories

Based on the Prevention of Cruelty to Animals Act (1960), the Ministry of Environment and Forest (MoEF) has issued guidelines to the University Grants Commission, ministry of health and family welfare, Pharmacy Council of India and the Medical Council of India to discontinue dissection and experiments with live animals in universities, colleges, research institutes, hospitals, laboratories and instead use alternatives like computer simulation.[viii]

  1. Ban of testing cosmetics on animals[ix]

Any cosmetic product which carries out animal testing will face action as per provisions of the Drugs and Cosmetics Act and the Animal Cruelty Act. Violation of the Drugs and Cosmetics Act by any person or corporate manager or owner is liable for punishment for a term which may extend from 3-10 years and shall also be liable to fine which could be Rs.500 to Rs. 10,000, or with both.

The use of modern non-animal alternative tests also becomes mandatory, replacing invasive tests on animals. This means that any manufacturer interested in testing new cosmetic ingredients or finished products must first seek the approval from India’s regulator Central Drug Standards Control Organisation. A manufacturer will be given approval to test only after complying with the BIS non-animal standards.

  1. Ban Sale of Cows for Slaughter Across India[x]

The Centre has now introduced a special clause in the Prevention of Cruelty to Animals Act of 1960 which says that cows can now only be sold to farm land owners.

Cows can be only sold for agricultural purposes and not for slaughter. The new law also stipulates that young, or old unfit cows cannot be sold.

This means that farmers won’t be able to sell cows that are old. Most states in India have a ban on cow slaughter.

  1. Rehabilitation instead of euthanasia for retired Army dogs[xi]

but the government is also working on a policy to stop their mercy killing after retirement. Though the policy is yet to be adopted, the Army has stopped the killing of ageing animals serving in the Army. Except for the ones who are suffering from incurable, terminal diseases.

  1. Animal testing on soaps and detergents [xii]

Indian government has asked soap and detergent manufacturers to restrain from product testing on animals. The Committee for Control and Supervision of Experiments on Animals (CPCSEA), under the ministry of environment, forests and climate change, had issued a circular to manufactures and industry associations, recently


Despite the various initiatives, guidelines, policies etc. animal cruelty is still in practice at some places in India. The reasons may include wilful disobedience of order of Court, lack of awareness, improper implementation, non-stringent guidelines on violation of laws etc. Often, positive efforts to address animal concerns are undermined by lack of political will and governance failures.

Defiance of Law

  1. Poultry injected with growth hormone[i]

Despite a ban imposed by the Union agriculture ministry on using growth hormones, poultry are being fed the same. An estimated 10,000 birds have died in the 25 authorized centres.

  1. Wired cages in poultry farms[ii]

In 2012, the AWBI issued an advisory and recommended the Union environment ministry adopt the draft Prevention of Cruelty to Animals (egg laying hen) Rules and phase out battery cages for egg-laying hens by January 2017.

A survey of 20 poultry farms on the outskirts of Mumbai and Pune in Maharashtra, Hyderabad and Haryana by between August and December 2016 revealed confining hens in such cages not only leads to many deaths, but also leaves them bleeding, with sores, cracked and deformed feet owing to the wired floor of the cages.

  1. Why ban meat of only cows, bulls? Why not goats too?[iii]

Maharashtra government should explain why it had banned the slaughter and consumption of the meat of only cows, bulls and bullocks, and no other animals such as goats. On the contrary Maharashtra’s DGP two weeks head of Eid 2016 has directed police in the state to ensure gaurakshasa don’t carry out suomoto raids.

  1. Ban on Jallikattu removed[iv]

Tamil Nadu assembly passed a bill overturning the Supreme Court ban on Jallikattu. This shows that legislature is superior to Judiciary. All attempts to end cruelty to bulls are in vain. Sad but true that cruelty to animals is not governed by laws but by political interference and influence. Animals are animals whether cow or bull. We know that India is a secular country with different cultural and religious practices but animal wears no identification of culture. How can animal cruelty be validated in one state by passing a bill even if law extends to whole of India?

Improper Implementation of Laws

  1. Smuggling of animals- In India illegal wildlife trade has emerged as an organised Crime. It includes diverse products like mongoose hair; snake skins; Rhino horn; Tiger and Leopard claws, bones, skins, whiskers; Elephant tusks; deer antlers etc. A large part of this trade is meant for the international market and has no direct demand in India.
  2. Maltreatment- Children’s amusement turns into agony for poor animals. During the festival of Diwali children tie crackers in the tail of dogs etc. causing serious burns and even amputation. During Holi animals are unnecessarily showered with synthetic colours. Its sad that even educated people have apathy for them. There was a case where a dog was thrown from the terrace of a building in Chennai.
  3. Exploitation- Animals are over exploited for the needs of man such as food, leather, leisure, and for even entertainment purposes. Alternatives are clearly available for the afore said things yet man chooses to torture animals
  4. Others-Unaccounted killings in the form of shooting, trading or because of sterilization go unnoticed and are not penalized. So, a lot more needs to be done in these spheres to protect animals from such atrocities.


  1. Lack of Effective penalties

As of now examined before the irrelevant punishments of the PCA Act and some other creature welfare laws are posturing major issues for successful execution of the targets of these laws. “Penalty for violation of those rights are insignificant, since laws are made by humans. Punishment prescribed in Section 11(1) is not commensurate with the gravity of the offence, hence being violated with impunity defeating the very object and purpose of the Act, hence the necessity of taking disciplinary action against those officers who fail to discharge their duties to safeguard the statutory rights of animals under the PCA Act.”[i]

“G. Dowlath Khan, an inspector with SPCA (Society for Prevention of Cruelty to Animals) for the past 33 years, said outdated legal provisions, the abysmally low fine amount and a shortage of inspectors had resulted in increased cruelty towards animals of late”[ii]


  1. Lack of Public Awareness

It is just possible to avoid creature savagery (animal cruelty) with the help of overall population and after all paying little heed to its reality just when an issue is of incredible enthusiasm among people in general then just the government officials take the essential measures towards such issues. Furthermore, for that reason, the general population must know about reality the issues of creature savagery as well as with those occurrences which they may confront in everyday life yet know about. They ought to know about a portion of the general laws.

A person should be aware about the acts that causes a crime or te acts that will lead to suffering and pain to animals. Therefore, the Rule 56 specifically provides for precautions including having one attendant for every six cattle and also padding around the sides should be used and anti-slippery material should be used. People should be aware of some principles laid down by the courts in some of the judgments in order to broaden their thinking like how courts have observed that that birds have right to fly.[iii]

Likewise, laws identifying with slaughter houses which are additionally identified with occurrences that they may likewise confront in day by day life. “Like as per the provision of Prevention of Cruelty to Animals (Slaughter House) Rules, 2001, an animal cannot be slaughtered except in recognized or licensed houses”[iv] (which are only very few in each state at present) for the purpose but still a slaughtering in non-recognized and non-licensed is going on at an large scale and also it prescribes how an animal can’t be slaughtered in a slaughter house in front of the sight of other animals52 being also an ignored incident mostly.[v]


The police experts and individuals related to the exercises, (for example, transportation, and so on.) including animals must know about the different laws. Mindfulness among the police authorities is essential for the usage of these laws. These laws are should have been taken after and executed entirely, however, there is an absence of such information at introducing these laws. “In India, where there are such paltry penalties for cruelty to animals, most police are not familiar with laws designed to protect animals and refuse to even register complaints of animal abuse”[vi]

In an occurrence where some truck transporting animals illicitly was discovered after realities were watched “As per prescribed norms for transporting cattle, water and food should be provided to them while in transit. But none of the trucks intercepted had followed this, Mr. Prasanna said. Another glaring violation is the absence of a certificate from a veterinarian before the cattle are transported from one place to another.”[vii]

Much the same as a medication for an ailment can be sought just when the specialists and scientists work a great deal in that field, same with respect to the improving and execution of laws for anticipation of mercilessness towards animals the help of Advocates, Lawyers and other individuals identified with the field of law is required. “G. Dowlath Khan, an inspector with SPCA (Society for Prevention of Cruelty to Animals) for the past 33 years, said that though there are provisions in the Prevention of Cruelties to Animals Act to punish offenders, a complainant also has to include provisions of the Indian Penal Code for severe action to be taken against an offender. However, since there is little awareness or interest amongst law enforcers, there is hardly any implementation of the law, he said.”[viii]



The Animal Welfare Board of India has drafted a Draft Animal Welfare Act which has secured most of the important amendment that is to be made in the present PCA Act, 1960, in this way it ought to be brought into drive by the parliament set up of the PCA Act as quickly as time permits. As of now the punishment for cold-bloodedness to creatures is between Rs 10 to 50 for the main offence, which may go up to Rs 100 for an ensuing offence or up to three months in jail. The draft Bill, if go in its present shape, would bring about the punishment for remorselessness to creatures being between Rs 10,000 and 25,000 or detainment for up to two years – or both – for a first offence. For a consequent offence, the punishment would be between 50,000 rupees and one lakh rupees and detainment for one to three years. It likewise perceives different privileges of the creatures. It likewise has an arrangement with respect to the foundation of state creature welfare board which would very helpful in the execution and authorization of the laws made in this draft. Its Section-14 peruses Each State Animal Welfare Board should guarantee that the Act and the Rules encircled under this Act are given far reaching reputation in the State and that due and sufficient preparing is given to all administration officers who are required to authorize the arrangements of this Act and the Rules made there under. However, some may state that there is uncertainty identifying with experimentation of animals, I surmise that this draft charge is the need of the time which ought to be ordered at the soonest with no further a due.



I think India as a national has perceived the significance of the issue and has picked to find a way to anticipate such acts. When we will take a gander at the Constitution of India, at that point one may decipher how creatures must be shielded from any cold-bloodedness and insurance of them from it is our obligation. As of now said there are plenty of laws which have been established by the council for creature welfare which mirrors their accommodation or acknowledgment to the reality of the issue. Therefore, one may state that in contrast with the a large portion of the nations the remain of the ‘Lawful System’ in India is solid against any mercilessness to creatures and advances creature welfare. Furthermore, in the situations where there truly has been savagery to creatures the Indian legal has heard and held for the privileges of the creatures. Be that as it may, the genuine and real issues exist in the execution and a few deformities in these laws as respects the present time. However, there are many cases which do emerge yet the legal might have the capacity to hear a case and the laws and lawful arrangements for creature welfare would just be compelling when a case is at any rate documented or raised. As of now examined before the ignorance of the laws on the issue among the dormant masses and additionally concerned experts and police are the real explanation behind the non-usage of these laws. This issue needs to address as quickly as time permits. Such non-execution is the greatest hindrances that India is confronting at this moment with respects guaranteeing creature welfare. There is likewise need of alteration of a few arrangements of the laws as be successful with the changed time bolster for which is getting to be noticeably obvious. Yet, finally one may state that despite the fact that there are provisos rights now exhibit in the ‘Indian Legal System’ as to this issue however with its present stand and if the different proposals and issues are given the merited thought and proper strides are brought as per them or some other measures which may take care of the accompanying aforementioned issues at that point steps one may close by saying that there will be an expectation for a superior future for non-people to carry on with an existence with respect, similar to the merit.


  1. (2014) 7 SCC 547
  2. Uday Shankar, Do Animals Have A Right Under art 21 of the const of India? – Comment on Animal Welfare Board of India Case, Bharti Law Review, Oct. – Dec., (2014), at 67.
  3. Animal Welfare Board of India v. A. Nagaraja & Ors., CIVIL APPEAL NO. 5387 at *78, (SC May.7, 2014)
  4. Sruthisagar Yamunan, Taming bulls, maming rights, The Hindu, Available at (last accessed on July 29, 2017, 11:29 a.m.),
  5. J. Venkatesan, Supreme Court bans jallikattu in Tamil Nadu, The Hindu, Available at ((last accessed on July 29, 2017, 1:09 a.m.),
  6. Id
  7. KV Lakshmana and Aditya Iyer, Jallikattu protests: Bill passed, hurdles to sport removed, says Tamil Nadu CM, Hindustan Times, Available at (last accessed on July 29, 2017, 9:50 a.m.),
  8. Id
  9. Humane Society International (India), TBI BLOGS: 7 Landmark Judgements That Were Big Wins for Animal Welfare in India, The Better India, Available at (last accessed on July 29, 2017, 11:00 a.m.),
  10. Shreya Parek, 5 Laudable Initiatives By India To Stop Animal Cruelty That Will Make You Proud, The better India, Available at (last accessed on July 29, 2017, 11:59 a.m.),
  11. Id
  12. Id
  13. Id
  14. The Wire Staff, Centre Imposes Nationwide Restriction on Slaughter of Buffalos, Camels and Cows, The Wire, Available at (last accessed on July 30, 2017, 11:59 a.m.),
  15. Id
  16. Id
  17. PTI, Blind elephant banned from parading in festival in Ernakulam,, Available at (last accessed on July 30, 2017, 00:59 a.m.),
  18. Linah Baliga, Govt bans use of live animals for education, research, The Times of India, Available at (last accessed on July 30, 2017, 00:38 a.m.),
  19. Aarti Dhar, India bans testing of cosmetics on animals, The Hindu, Available at (last accessed on July 30, 2017, 00:39 a.m.),
  20. Rohini Chatterjee, Centre Introduces New Clause In Animal Protection Law To Ban Sale Of Cows For Slaughter Across India, HUFFPOST, Available at (last accessed on July 30, 2017, 00:42 a.m.),
  21. Soudhriti Bhabani, Now rehabilitation instead of euthanasia for retired Army dogs, India Today, Available at (last accessed on July 30, 2017, 00:45 a.m.),
  22. Animal testing on soaps and detergents banned in India: Some important facts you should know, India Today in Education,, Available at (last accessed on July 30, 2017, 00:45 a.m.),
  23. KANIZA GARARI, Poultry injected with growth hormone despite ban imposed by Centre, DECCAN CHRONICLE., Available at (last accessed on July 29, 2017, 05:06 p.m.),
  24. Badri Chatterjee, Wired cages in poultry farms killing hens in India, shows survey, Hindustan Times, Available at (last accessed on July 29, 2017, 05:10 p.m.),
  25. HC to Maharashtra: Why ban meat of only cows, bulls? Why not goats too, The Telegraph, Available at (last accessed on July 29, 2017, 05:15 p.m.),
  26. supra note 43
  27. Animal Welfare Board of India v. A. Nagaraja & Ors., CIVIL APPEAL NO. 5387 at *85, (SC May.7, 2014)
  28. P. Oppili, Cruelty to animals on the rise, The Hindu-Chennai, available at, (last accessed on July 29, 2017, 08:06 p.m.),
  29. Abdulkadar Mohamad Azam Sheikh v. State of Gujarat., SPECIAL CRIMINAL APPLICATION No. 1635 at *15, (Guj. May.12, 2011)
  30. The Prevention of Cruelty to Animals Act (Slaughter House) Rules, 2001, Section-3, (1960)
  31. The Prevention of Cruelty to Animals Act (Slaughter House) Rules, 2001, Section-6, cl. (1) (1960).
  32. Poorva Joshipuria, Delhi gang rape two years on: Shocking levels of animal abuse show India has failed to change, International Business Times, available at (last accessed on July 28, 2017, 09;43 p.m.)
  33. P. Oppili, Cruelty to animals on the rise, The Hindu-Chennai, Available at (last accessed on July 29, 2017, 08:06 p.m.)
  34. Id

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