To,                

Chief Commissioner, Central Consumer Protection Authority: CCPA, via AWBI.

Subject: Cruel transportation of animals to slaughter, isn’t halal, instead haram.

Reference: AWBI for inspection as per Slaughter House Rules, 2010: Compliance

Strict compliance of article 51 A of Indian Constitution, as fundamental duties –

Cruelty towards animals, including in their transportation, goes against the principles of ethical treatment in Islam. In Islamic teachings, the concept of "halal" (permissible) and "haram" (forbidden) extends beyond just food and encompasses ethical treatment of animals. Practices that cause unnecessary harm, stress, or cruelty to animals are considered contrary to Islamic values.

The mistreatment of animals during transportation, such as overcrowding, lack of proper ventilation, and rough handling leading to injury or suffering, would likely be considered haram in Islam due to the principle of kindness and compassion towards all creatures. Islamic teachings emphasize the importance of treating animals with care, mercy, and respect.

Efforts to ensure the well-being and humane treatment of animals during transportation align with the broader principles of Islamic ethics and compassion towards all living beings.

1.     AWBI communication, bearing No. 9-5/2023-24/0007/PCA, dated 26-6-2023.

2.     National Green Tribunal OA 214 of 2021, orders passed on the compliance of Inspection Reports: E.A. No. 10/2023.

3.     Delhi Police standing order No. 31 of 2022.

4.     All functional 11 DSPCA in Delhi, along with Infirmaries.

5.     Central Motor Vehicle (Eleventh Amendments) Rules, 2015.

6.     Rule 3 of the Veterinary Council of India Standard of Professional Conduct, Etiquette and Code of Ethics, for Veterinary Practitioners Regulations, 1992.

7.     Hon’ble Supreme Court of India, verdict on 5 freedoms for animal, SLP (C) No.11686 of 2007, read with WP (C) No. 23 of 2016:

Chapter 7.1.2 of the guidelines of OIE, recognizes five internationally recognized freedoms for animals, such as:
(i) freedom from hunger, thirst and malnutrition.
(ii) freedom from fear and distress.
(iii) freedom from physical and thermal discomfort.
(iv) freedom from pain, injury and disease and
(v) freedom to express normal patterns of behaviour.

8.     Animal are being defined as living creature under IPC 47 and section 2 of Prevention of Cruelty to Animals Act, 1960, but discrimination and contradiction in the Carriage by Road Act, 2007, which defined under section 2, goods include animals and livestock.

9.     Hon’ble Delhi High Court verdict in W.P.(C) 2316/2017.

10. Hon’ble Supreme Court of India, direction in CWP No. 309 of 2003, on dated 27-8-2013, read with the Compendium prepared.

11. Verdict of Hon’ble Delhi High Court in W.P.(C) 2045/2022, related to Camels of BSF, from Rajasthan to Delhi and back, shifted in goods transport vehicle, instead special vehicles, duly approved by RTAs.

12.  Foreign Exchange Management Act, 1999 / Prevention of Money Laundering Act, 2002 / Fugitive Economic Offenders Act, 2018.

13.  DOAHD-E-2022-00861 Appeal DOAHD-E-A-23-0000018, read with AWBI reference No. 9-3/2023-24/270/PCA, dated 20-11-2023.

14.  Prevention of Cruelty to Animals (Slaughter House) Rules, 2001.

15.  Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011.

16.  Food Safety and Standards Act, 2006.

17.  National Accreditation Board for Certification Bodies - NABCB.

18.  Streamlining of Halal Certification Process for Meat and Meat Products.

19.  Guidelines on Access to Biological Resources and Associated Knowledge and Benefits Sharing Regulations, 2014, under the Biological Diversity Act, 2002.

20. Veterinary Council of India Standard of Professional Conduct, Etiquette and Code of Ethics, for Veterinary Practitioners Regulations, 1992.

21. The Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011 under the Food Safety and Standards Act, 2006, wherein definition of animals is given, and approved.

As per sub-regulation 2.5.1 (a)"animal" means an animal belonging to any of the species specified below: 

(i)              Ovines (sheep). 

(ii)            Caprines (goats or goat-antelopes). 

(iii)          Suillines (pig family).

(iv)           Bovines (ox and cow including buffalo).

(v)            Domestic Rabbits (Oryctolagus cuniculus) and includes poultry and fish. 

Ritual Slaughter: Meat of Camel, not hygienic for human consumption as food-

Ritual slaughter is slaughter done according to the religious requirements of either the Jewish (sachet) or Muslim (Halal) and Hindu (Jhatka) religious faith. The animal is slaughtered, with / without being stunned, with a razor-sharp knife. When the cut is done correctly, the animal appears not to feel it. From an animal welfare standpoint, the major concerns during ritual slaughter are the stressful and cruel methods of restraint (holding) that are used in some plants. Progressive slaughter plants use devices to hold the animal in a comfortable, upright position. For both humane and safety reasons, plants which conduct ritual slaughter should install modern upright restraining equipment.

The census of livestock in Delhi or any region is typically conducted for administrative and statistical purposes to understand the population, demographics, and overall management of animals. It doesn't directly relate to the permission or regulations regarding animal slaughtering for domestic consumption or export.

In India, regulations concerning the slaughter of animals for meat consumption and export are governed by various laws and regulations, including state-specific rules and national legislation like the Prevention of Cruelty to Animals Act, 1960, and the Food Safety and Standards Act, 2006.

Each state in India might have its own regulations regarding the slaughter of animals for consumption and export. Additionally, regulations concerning the export of meat products outside India also involve compliance with international standards and agreements.

The slaughtering of animals for domestic consumption or export, especially for commercial gain and profit, is subject to specific rules, licenses, and compliance with animal welfare and food safety standards. These regulations aim to ensure humane treatment of animals, hygienic slaughtering practices, and compliance with export requirements.

The permissions and legality of slaughtering animals for consumption and export can be complex and subject to various regulations, so it's essential to consult the specific laws and regulations in Delhi or the concerned region for accurate and detailed information.

                         INDEX

S. No -               Particulars  -                                                       Page
1.                     Complaint                                                            1-10
2.     Trade Mark 5 freedoms – 5 basic principles of Gandhi Ji     11-12
3.     UP FSSAI banned Halal certified products in UP                      13
4.  FIR No. 0332, dated 17-11-2023 with Hazratganj PS, Lucknow  14-18
5. Streamlining of Halal Certification Process for Meat and Meat Products
                                                                                                        19-22
6. DOAHD/E/2023/0000008, to APEDA – AWBI, by DC Trade             23
7. APPEDA on Jamiat Ulma-E-Maharashtra: Self-styled Halal certification
                                                                                                            24
8.  AWBI to AH on Halal process of slaughtering: RTI                         25
9. DOCOM/E/23/0000159, 0000042, 0000049, 0000098, 0000164     26-30
10.  DOCOM/E/A/23/0000178, DOCOM/E/A/22/0000105              31-32
11. FSSAI replied RTI on many queries                                              33-35
12.  DOCOM/E/2022/03241 to exclude Cow under term Bovine          36
13. APEDA: To cancel registration of Jamiat Ulma-E-Maharashtra       37
14. APEDA on many issues including Halal process of slaughtering  38-39
15. APEDA clarification on animal transportation: DOCOM/E/2017/00429
                                                                                                  40-41
16. PRSEC/E/2011/14172: Establishment of Slaughterhouse for 3 shifts  42
17. AWBI to District Magistrate with Animal Husbandry, for transportation-                                                                                     43
18. Communications of Gazipur Slaughter House by Administration  44-47
19. Govt. of India, endorsing 5 freedoms for animals                   48-50
20. Communication of installation of Animal scanner on each toll plaza -                                                                                                        51-52
21. Central Motor Vehicles (Eleventh Amendment) Rules, 2015        53-57
22.  NHAI on animal transportation in special vehicles                       58-59
23. Communication of Rajya Sabha on animal shifting as Goods       60-61
24.  AWBI – AH of Govt. of India, on animal shifting to Rajya Sabha   62-67
25.  Duties and functions of public servants, holding berth in AWBI  68-71

Greetings,

Being an active part of Community Policing as man of many achievements and distinctions: Voice for voiceless: Fighter by spirit: Jat by birth: Philanthropist by profession: Activist by mission: Cobbler by qualification: Scouting by passion: Humanitarian by choice: Gandhian by vision and action, habitual khadi wearers and speaking truth, performing fundamental duties, as social reformer, compassionate citizen, and unpaid labour for flora and fauna, with our mission: Conservation beyond imagination, during the Golden Jubilee years of activism, nothing for gain and profit, Whistleblower for community service, it is humbly submitted that:

1. I am a senior citizen of India, performing my fundamental duties, without gain and profit, only to safeguard flora and fauna, in the interest of the public at large.
2. I am a Master Trainer in Animal Welfare, decorated by the Govt. of India, retired as Commissioner, Bharat Scouts and Guides, Haryana, along with Member of State Committee for Slaughter Houses (Department of Urban Local Bodies - Govt. of Haryana).
3. Lifetime working as Chief National Commissioner, Scouts and Guides for Animal and Birds, along with National Authority for Animal Welfare, OIPA: Indian People for Animals.
4. I had been CPCSEA nominee, Nodal Inspecting Authority for Haryana and adjoining Rajasthan, for Animal Welfare Division (Govt. of India) and Inspecting Authority for Animal Welfare Board of India, for Haryana and Punjab, as per item No. 3 of 39th AGM of AWBI, keeping in view the recommendations of Screening Committee of AWBI.

5. I had been volunteers of Wildlife Crime Control Bureau, and Convener of Animal Welfare Party, political wing for flora and fauna. 

6. International Union for Conservation of Nature: IUCN - 2021-2025:

1. Member, Commission on Education and Communication.

2. Member, CEC Nature for all Network 

3. Member, CEC Reimagine Conservation Network

4. Member, CEC Nature Education for Sustainability Network

5. Member, CEC Youth Engagement, and Intergenerational Partnerships

Fundamental duties: It shall be the duty of every citizen of India:

(a) to abide by the Constitution and respect its ideals and institutions, the National Flag, and the National Anthem.

(b) to cherish and follow the noble ideals which inspired our national struggle for freedom.

(c) to uphold and protect the sovereignty, unity, and integrity of India.

(d) to defend the country and render national service when called upon to do so.

(e) to promote harmony and the spirit of common brotherhood amongst all the people of India transcending religious, linguistic, and regional or sectional diversities, to renounce practices derogatory to the dignity of women.

(f) to value and preserve the rich heritage of our composite culture.

(g) to protect and improve the natural environment including forests, lakes, rivers and wildlife, and to have compassion for living creatures.

(h) to develop the scientific temper, humanism and the spirit of inquiry and reform.

(i) to safeguard public property and to abjure violence.

(j) to strive towards excellence in all spheres of individual and collective activity so that the nation constantly rises to higher levels of endeavour and achievement.

(k) who is a parent or guardian to provide opportunities for education to his child or, as the case may be, ward between the age of six and fourteen years.

Streamlining of Halal Certification Process for Meat and Meat Products:

"Halal" and "haram" are terms used in Islam to classify what is permissible (halal) and what is forbidden or prohibited (haram) according to Islamic law (Sharia).

Halal: 

This term refers to things or actions that are permissible or lawful according to Islamic teachings. It encompasses various aspects of life, including food, behavior, and business dealings. For example, halal food adheres to specific guidelines, such as the avoidance of pork and alcohol, and the use of humane methods in animal slaughter.

Haram: 

Haram, on the other hand, denotes what is forbidden or prohibited in Islam. Actions or items labeled as haram are considered sinful or unlawful according to Islamic teachings. This can include actions like consuming alcohol, eating pork, engaging in dishonest business practices, or engaging in certain behaviors or relationships that are prohibited by Islamic law.

The Food Safety and Standards Authority of India (FSSAI) oversees food regulations in India. The Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011, are part of the legal framework governing food businesses in the country. However, these regulations primarily focus on food safety and hygiene standards rather than religious or cultural practices related to animal slaughter.

Regarding stunning before animal slaughtering, while the FSSAI regulations emphasize standards for the hygiene and safety of food processing, they might not specifically mandate stunning before slaughter. The regulations primarily focus on ensuring that food businesses maintain hygienic conditions, follow good manufacturing practices, and meet safety standards during various stages of food processing, including animal slaughter.

However, specific requirements or regulations related to stunning before animal slaughtering might exist at the state or local level, and these could potentially conflict with traditional halal practices. In such cases, there might be discussions or debates between religious practices and food safety regulations.

It's essential to review both the FSSAI regulations and any additional local or state regulations that might specifically address stunning before animal slaughter to get a comprehensive understanding of the legal requirements and their implications on religious or cultural practices related to animal slaughter in India.

Prevention of Cruelty to Animals (Slaughter House) Rules, 2001, which were amended in 2010, include provisions that mandate stunning before animal slaughtering in India. These rules were put in place to ensure the humane treatment of animals during slaughter and are aimed at improving animal welfare standards in slaughterhouses.

The amended rules include guidelines for the proper handling and slaughter of animals in registered slaughterhouses. Among the provisions is the requirement for stunning animals before slaughter to minimize suffering and ensure a more humane process.

However, these regulations might conflict with traditional halal methods that emphasize specific religious practices during animal slaughter, where stunning before slaughter is not part of the process.

This requirement has led to debates and discussions within religious communities, particularly among those following Islamic dietary laws, as stunning before slaughter might not align with their religious practices.

The implementation and adherence to these rules can vary across regions and slaughterhouses in India. While the rules aim to improve animal welfare, they can pose challenges for communities that follow specific religious guidelines for animal slaughter.

As per Food Safety and Standards Act, 2006:

Section 29: Authorities responsible for enforcement of Act. 

(1) The Food Authority and the State Food Safety Authorities shall be responsible for the enforcement of this Act. 

(2) The Food Authority and the State Food Safety Authorities shall monitor and verify that the relevant requirements of law are fulfilled by food business operators at all stages of food business. 

(3) The authorities shall maintain a system of control and other activities as appropriate to the circumstances, including public communication on food safety and risk, food safety surveillance and other monitoring activities covering all stages of food business. 

(4) The Food Safety Officers shall enforce and execute within their area the provisions of this Act with respect to which the duty is not imposed expressly or by necessary implication on some other authority. 

(5) The regulations under this Act shall specify which of the Food Safety Officers are to enforce and execute them, either generally or in relation to cases of a particular description or a particular area, and any such regulations or orders may provide for the giving of assistance and information by any authority concerned in 11the administration of the regulations or orders, or of any provisions of this Act, to any other authority so concerned, for the purposes of their respective duties under them. 

(6) The Commissioner of Food Safety and Designated Officer shall exercise the same powers as are conferred on the Food Safety Officer and follow the same procedure specified in this Act.

Section 89: Overriding effect of this Act over all other food related laws-                      The provisions of this Act shall have effect notwithstanding anything inconsistent therewith contained in any other law for the time being in force or in any instrument having effect by virtue of any law other than this Act.

Prevention of Cruelty to Animals (Slaughter House) Rules, 2001, amended 2010:

Rule 6. Slaughter – 

(1) No animal shall be slaughtered in a slaughter house in sight of other animals

(2) No animal shall be administered any chemical, drug or hormone before slaughter except drug for its treatment for any specific disease or ailment.

(3) The slaughter halls in a slaughter house shall provide separate sections of adequate dimensions sufficient for slaughter of individual animals to ensure that the animal to be slaughtered is not within the sight of other animals.

(4) Every slaughter house as soon as possible shall provide a separate space for stunning of animals prior to slaughter, bleeding and dressing of the carcasses

(5) Knocking section in slaughter house may be so planned as to suit the animal and particularly the ritual slaughter; if any and such knocking section and dry landing area associated with it shall be so built that escape from this section can be easily carried out by an operator without allowing the animal to pass the escape barrier.

(6) A curbed-in bleeding area of adequate size as specified by the Central Government shall be provided in a slaughter house and it shall be so located that the blood could not be splashed on other animals being slaughtered or on the carcass being skinned.

(7) The blood drain and collection in a slaughter house shall be immediate and proper

(8) A floor wash point shall be provided in a slaughter house for intermittent cleaning and a hand-wash basin and knife sterilizer shall also be provided for the sticker to sterilize knife and wash his hands periodically.

(9) Dressing of carcasses in a slaughter house shall not be done on floor and adequate means and tools for dehiding or belting of the animals shall be provided in a slaughter house with means for immediate disposal of hides or skins;

(10) Hides or skins shall be immediately transported from a slaughter house either in a closed wheelbarrow or by a chute provided with self-closing door and in no case, such hides or skins shall be spread on slaughter floor for inspection

(11) Floor wash point and adequate number of hand wash basins with sterlizer shall be provided in a dressing area of a slaughter house with means for immediate disposal of legs, horns, hooves and other parts of animals through spring load floor chutes or sidewall doors or closed wheelbarrows and in case wheelbarrows or trucks are used in a slaughter house, care shall be taken that no point wheelbarrow or truck has to ply under the dressing rails and a clear passage is provided for movement of the trucks.

12. Adequate space and suitable and properly located facilities shall be provided sufficient for inspection of the viscera of the various types of animals slaughtered in a slaughter house and it shall have adequate facilities for hand washing, tool sterilisation and floor washing and contrivances for immediate separation and disposal of condemned material.

13. Adequate arrangements shall be made in a slaughter house by its owner for identification, inspection and correlation of carcass, viscera and head.

14. In a slaughter house, a curbed and separately drained area or an area of sufficient size, sloped 33 mm per metre to a floor drain, where the carcasses may be washed with a jet of water, shall be provided by the owner of such slaughter house.

Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011:

Rule 4.0 Slaughter: 

Animals are slaughtered by being first stunned and then exsanguinated (bled out). Stunning can be affected through asphyxiating the animals with carbon dioxide, shooting them with a gun or a captive bolt pistol, or shocking them with electric current.

Rule 4.1. Stunning:

Stunning before slaughter should be mandatory. By inducing unconsciousness and insensibility, stunning can avoid and minimise reactions of fear and anxiety as well as pain, suffering and distress among the animals concerned. Stunning methods induce temporary loss of consciousness and rely on prompt and accurate sticking procedures to cause death. 

It is important that the equipment utilized for stunning and slaughter is maintained in good working condition and that all operators involved are well trained and have a positive attitude towards the welfare of animals. 

Electrical stunning consists of passing electricity through the brain to produce instantaneous insensibility.

Veterinary Council of India Standard of Professional Conduct, Etiquette and Code of Ethics, for Veterinary Practitioners Regulations, 1992:

Rule 3: Declaration and oath by a veterinarian: Being admitted to the profession of veterinary medicine:

I solemnly swear to use my scientific knowledge and skills for the benefit of society through the protection of animal health, the relief of animal suffering, the conservation of livestock resources, the promotion of public health, and the advancement of knowledge in veterinary science.
I shall practice my profession conscientiously, with dignity, and in keeping with the principles of veterinary medical ethics.
I accept as a lifelong obligation the continuous improvement of my professional knowledge and competence.
FIR may be lodged against the operators and promoters of the Ghazipur Slaughter House, owned by Municipal Corporation of Delhi, for the violation of many legislations, breaching public trust, for gain and profit. STOP 3rd shift for Export.

Whereas, Jamiat Ulama-i-Hind Halal Trust, their website: jamiathalaltrust.org

Stunning of Animals prior to Slaughtering:

Due to possibilities of causing grievous injuries to the animal before slaughtering and the requirements of Islamic Shariah which orders to apply methods which cause least amount of pain stunning of animals is not recommended. Most of the Islamic countries don't accept stunning.

Whereas, National Accreditation Board for Certification Bodies, granted Accreditation No. PC 034, overruling legal mechanism of animal slaughtering.

Confiscate all objectionable materials, freezing all transactions, bank accounts, movable and immovable assets, including passports.
Ban all materials on internet, including website, if any.
Restoration of five freedoms for animals, preventing halal certification, and export.

It would be pertinent to mention here that:

Animals are being brought to Gazipur Slaughter House, violating the surplus census of animals, as shifting in non-approved goods transport vehicles.

1.     The census of animals, never allow their slaughtering, keeping in view, their 5 freedoms, right to life.

2.     Rule 3 of the Veterinary Council of India Standard of Professional Conduct, Etiquette and Code of Ethics, for Veterinary Practitioners Regulations, 1992, never allow veterinarian to issue transport permit and fit to slaughter.

3.     All 11 DSPCA are non-functional.

4.     Stunning process before slaughtering, Gazipur claim is wrong as per Halal certification, keeping in view Ritual slaughtering process.

5.     Compendium prepared but never followed, keeping in view, standing orders of Delhi Police, bearing No. 31 of 2022, read with orders passed by the Hon’ble Supreme Court and Delhi High Court, related to animal transportation.

6.     Gazipur Slaughter House meant for domestic consumption then why 3rd shift of slaughtering, keeping in view demand and supply of local consumption?

7.     Animals are being abused during their shifting towards slaughterhouses, adopting cruel methods, their meat can’t be treated as Halal, because:

 

Section 11 of the Prevention of Cruelty to Animals Act, 1960: Treating animals cruelly, If any person-

(a) beats, kicks, over-rides, over-drives, over-loads, tortures or otherwise treats any animal so as to subject it to unnecessary pain or suffering or causes or, being the owner permits, any animal to be so treated.

(b) employs in any work or labour or for any purpose any animal which, by reason of its age or any disease, infirmity, wound, sore or other cause, is unfit to be so employed or, being the owner, permits any such unfit animal to be so employed.

(c) willfully and unreasonably administers any injurious drug or injurious substance to any animal or willfully and unreasonably causes or attempts to cause any such drug or substance to be taken by any animal.

(d) conveys or carries, whether in or upon any vehicle or not, any animal in such a manner or position as to subject it to unnecessary pain or suffering

(e) keeps or confines any animal in any cage or other receptacle which does not measure sufficiently in height, length and breadth to permit the animal a reasonable opportunity for movement

(f) keeps for an unreasonable time any animal chained or tethered upon an unreasonably short or unreasonably heavy chain or cord

(g) being the owner, neglects to exercise or cause to be exercised reasonably any dog habitually chained up or kept in close confinement

(h) being the owner of any animal fails to provide such animal with sufficient food, drink or shelter

(i) without reasonable cause, abandons any animal in circumstances which render it likely that it will suffer pain by reason of starvation or thirst

(j) willfully permits any animal, of which he is the owner, to go at large in any street while the animal is affected with contagious or infectious disease or, without reasonable excuse permits any diseased or disabled animal, of which he is the owner, to die in any street

(k) offers for sale or, without reasonable cause, has in his possession any animal which is suffering pain by reason of mutilation, starvation, thirst, overcrowding or other ill-treatment

(l) multilates any animal or kills any animal, including stray dogs by using the method of strychnine injections in the heart or in any other unnecessarily cruel manner

(m) solely with a view to providing entertainment-

(i) confines or causes to be confined any animal, including tying of an animal as a bait in a tiger or other sanctuary, so as to make it an object of prey for any other animal.

(ii) incites any animal to fight or bait any other animal

(n) organises, keeps, uses or acts in the management of, any place for animal fighting or for the purpose of baiting any animal or permits or offers any place to be so used or receives money for the admission of any other person to any place kept or used for any such purposes.

(o) promotes or takes part in any shooting match or competition wherein animals are released from captivity for the purpose of such shooting.

 With scouting spirits ………… 

Master Trainer in Animal Welfare to Govt. of India - Naresh Kadyan,

Chief National Commissioner, Scouts & Guides for Animals & Birds,

National Authority for Animal Welfare, OIPA: Indian People for Animals,

Retired Commissioner, Bharat Scouts and Guides, and Retired Member, State Committee for Slaughter Houses, Haryana, C- 38, Rose Apartment, Sector- 14, Rohini, Delhi -110085                          WhatsApp: 9813010595   Email: kadyan.ipfa@gmail.com