To

The Registrar
Supreme Court of Delhi
New Delhi

Subject: Urgent Petition under Article 226 of the Constitution of India for Interim Stay on Implementation of the Supreme Court’s Order Dated 11/08/2025 Directing Removal of All Stray Dogs in Delhi

Respected Sir/Madam,

We write this letter as a deeply concerned citizen, moved by the recent directive of the Hon’ble Delhi High Court dated Aug 11, 2025, We, On behalf of Indrani Foundation, the Petitioner herein, am filing the present urgent petition seeking an immediate stay on the implementation of the Hon’ble Supreme Court’s order dated 11/08/2025, which directs the rounding up and permanent removal of all stray dogs from the streets of Delhi to shelters/pounds. With utmost respect, I appeal to the Government and this Hon’ble Court to reconsider any policy that would forcibly remove community dogs from the neighborhoods they call home.

These dogs are not a menace.

They are guardians. They are companions. They are family.

Across Delhi, community dogs play a silent yet powerful role in our lives. They watch over our streets at night, often alerting residents of intruders long before humans can react. In a city where security is a constant concern, these dogs are the first line of defense in countless colonies.

But their contribution is not limited to safety alone. These animals are Chief Joy Officers of our neighborhoods — loved by children, cherished by the elderly, and comforters to the lonely. In times of distress, it is often these four-legged friends who offer unconditional love and companionship. Their wagging tails greet us when we return home. Their presence teaches our children empathy. Their loyalty reminds us daily of what it means to care.

To remove them from our streets is not just a logistical or legal action — it is an act that will wound the emotional fabric of our communities. For many of us, these dogs are not "strays." They are named, known, and nurtured. They have lived among us for years, forming deep bonds that no policy can measure or quantify.

While we understand the complexities of governance and urban planning, we firmly believe that there must be space for compassion in policy. Any action that forcibly uproots these animals, irrespective of intent, will cause not only psychological distress to the dogs but also to the residents who consider them as vital as any neighbor.

We therefore make a humble yet firm appeal:

"Let community dogs remain where they are known, loved, and protected.
Let their presence be recognized not as a problem, but as a source of joy, security, and emotional well-being.

Let the law reflect the values of compassion, coexistence, and respect for life."

Also, let us be clear: this is not merely a compassionate appeal. It is also a firm legal position.

Should any forced removal, relocation, or encampment of community dogs be initiated in any form, we will consider it:

A violation of our fundamental rights to life, dignity, and emotional well-being under Article 21 of the Constitution, A breach of the principles enshrined in Article 51A(g) which mandates compassion toward all living creatures, A contravention of several prevailing animal welfare laws and Supreme Court rulings protecting community animals in their natural environment.

1. Grounds for Urgent Relief
Conflict with Statutory Rules – The order is contrary to the Animal Birth Control Rules, 2023 (framed under the Prevention of Cruelty to Animals Act, 1960), which mandate capture, sterilisation, vaccination, and return to the same location rather than permanent confinement.
Impossibility of Compliance – Delhi lacks the shelter infrastructure required to house all stray dogs; the order is physically impossible to implement without causing undue cruelty and public health hazards in shelters.
Violation of Fundamental Rights – The order infringes:

Article 21 – Right to life and dignity (including protection from arbitrary cruelty).
Article 14 – Arbitrary and unequal treatment compared to other municipalities following ABC Rules.
Public Health Risk – Overcrowded, under-equipped shelters will lead to spread of disease, poor hygiene, and potential public health disasters.
Lack of Stakeholder Consultation – No hearing was given to animal welfare boards, NGOs, or local bodies before passing such a sweeping order.
 
2. Reliefs Sought
a. Immediate stay on implementation of the Hon’ble Supreme Court’s order dated [insert date], to the extent it mandates permanent removal of all stray dogs in Delhi.
b. Direction to maintain status quo and follow the Animal Birth Control Rules, 2023 until final disposal of the petition.
c. Liberty to approach the Hon’ble Supreme Court by way of a Review Petition under Article 137.

 
3. Interim Prayer
Pending final disposal, the Hon’ble Court may kindly restrain the Respondents (GNCTD, MCD, Police) from undertaking any removal action inconsistent with the ABC Rules, 2023.

We are fully prepared to pursue all legal remedies available, including filing petitions for injunctive relief, compensation, and contempt, should any action be taken to remove or harm the dogs who live peacefully in our neighborhoods.

We respectfully urge the Government and this Hon’ble Court to reconsider any such policy and to instead promote a framework based on coexistence, protection, and dignity for all living beings.

Let Delhi be remembered not for cruelty disguised as order, but for a model of humane, lawful, and inclusive urban living.

Yours sincerely,

Poornima Vardhan & Taponeel Mukherjee

On Behalf of Indrani Foundation

11th Aug 2025