To,
The Member Secretary
Committee for Control and Supervision of Experiments on Animals (CCSEA)
Government of India

Subject: Objections to the Draft Prevention of Cruelty to Animals (Control and Supervision of Experiment, Breeding and Trading of Laboratory Animals) Rules, 2026

Respected Sir/Madam,

I wish to formally submit my objections to the proposed rules governing the use of animals in experiments, with particular concern for animal welfare, ethical oversight, and the prevention of unnecessary suffering.

I respectfully request that the following concerns be carefully considered before the proposed rules are finalised:

1. Independent Ethical Oversight

Effective and independent oversight must be maintained for experiments involving animals. Granting institutions greater authority to approve experiments through their own Institutional Animal Ethics Committees (IAECs) may create potential conflicts of interest. Appropriate independent scrutiny and accountability must be ensured.

2. Sourcing of Animals for Experiments

Provisions that may permit animals to be procured from open markets or unregistered sources under certain circumstances should be reconsidered. Strict safeguards, traceability, and independent authorisation must be mandatory to prevent illegal procurement, cruelty, and exploitation.

3. Use of Stray or Free-Ranging Animals

Any provision permitting exceptions for the use of stray or free-ranging animals in experiments must be strictly limited. No such permission should be granted without rigorous scrutiny, clear legal safeguards, and adequate protection of animal welfare.

4. Priority for Alternatives to Animal Testing

Where scientific objectives can be achieved through validated alternatives, such as cell-based methods, computer modelling, or other non-animal approaches, these alternatives should be given priority. The use of live animals should be reduced wherever scientifically feasible.

5. Stronger Protection Against Pain and Suffering

The rules should establish clear and enforceable safeguards to minimise pain, distress, injury, and long-term harm to animals. Compliance monitoring, transparent reporting, and accountability mechanisms should be strengthened.

In view of the above, I respectfully request the Government of India to:

- Re-examine the proposed rules in light of these concerns.

- Retain strong, independent ethical oversight of animal experiments.

- Reconsider provisions that may permit the procurement of animals from open markets or unregistered sources.

- Ensure strict safeguards concerning the use of stray and free-ranging animals.

- Prioritise scientifically validated alternatives to animal experimentation.

- Consider objections and suggestions received from citizens and animal-welfare organisations before finalising the rules.

Animal welfare is a matter of compassion, responsibility, and ethical scientific conduct. Regulatory reforms should strengthen the protection of animals rather than weaken existing safeguards.

I therefore urge the competent authorities to review these provisions carefully and ensure that the final rules uphold the highest practicable standards of animal welfare and ethical accountability.

Thank you for your consideration.

Yours faithfully,