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EXAMINING THE PREVENTION OF CRUELTY TO ANIMALS ACT: CHALLENGES AND OPPORTUNITIES IN STRENGTHENING ANIMAL WELFARE LAWS IN INDIA

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ANUSHA VENUGOPAL
Journal IJLRA
ISSN 2582-6433
Published 2025/03/22
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EXAMINING THE PREVENTION OF CRUELTY TO ANIMALS ACT: CHALLENGES AND OPPORTUNITIES IN STRENGTHENING ANIMAL WELFARE LAWS IN INDIA
 
AUTHORED BY - ANUSHA VENUGOPAL
3rd year BA.LL.B
Christ (Deemed to be University), Bengaluru
 
 
ABSTRACT
This paper explores the current landscape of the animal welfare legislation in India, highlighting significant gaps and challenges in its implementation. Despite India's deep-rooted cultural tradition of respecting and worshipping animals, the Prevention of Cruelty to Animals Act of 1960 and related laws have fallen short in addressing modern animal welfare concerns. The study examines key weaknesses in the legal framework, such as outdated penalties and enforcement challenges. Through case studies and a comparative analysis of international standards, this research proposes targeted reforms to strengthen India's animal welfare laws. These include stricter penalties, more effective enforcement mechanisms, expanded legal protections for all species, and improved coordination between state and central regulations. Additionally, the paper discusses the social, economic, and ethical implications of improving animal welfare standards, emphasizing that modernized legislation would not only safeguard animals but also uphold India's constitutional principles and cultural heritage.
 
Keywords: animal welfare, the prevention of cruelty to animals Act 1960, targeted reforms, stricter penalties
 
                                                                                                                                I.          INTRODUCTION
India has a rich and complex history of animal protection and welfare. From ancient texts advocating compassion for all creatures to contemporary legal frameworks, that are still evolving. The nation's dedication to animal rights has undergone significant evolution over the years. Animal welfare in India is deeply rooted in history, with its origins found in ancient texts like the Vedas, Upanishads, Buddhist and Jain scriptures. These teachings strongly advocated for non-violence (Ahimsa) and the compassionate treatment of all living beings. One of the earliest instances of formalized animal protection can be seen in the policies of Emperor Ashoka in the 3rd century BCE, where he enacted some of the first-known wildlife conservation laws, banning the killing of certain species and promoting veterinary care.[1] Hindu deities are often associated with animals, further reinforcing their sacred status in Indian society. Despite these cultural values, contemporary issues such as animal cruelty, and exploitation in industries like dairy, entertainment, and testing continue to pose serious threats to animal welfare. Addressing these challenges requires a legal framework that is both reflective of India’s historical ethos and responsive to modern concerns.[2]
 
The British colonial administration introduced several laws that indirectly addressed animal welfare, mainly through regulations on transportation, slaughter, and treatment of working animals. However, these were primarily designed for economic and administrative purposes rather than ethical considerations. The first major legal step came with the enactment of the Prevention of Cruelty to Animals Act, 1960 (PCA Act)[3], which remains the cornerstone of India’s animal protection laws today. The PCA Act established the Animal Welfare Board of India (AWBI) and laid out broad protections against cruelty to animals. However, despite its progressive intent, the law has remained largely unchanged for over six decades. Many of its provisions, including penalties for violations, are outdated and insufficient to deter cruelty.
 
While constitutional provisions, i.e. the fundamental duty enshrined in Article 51A(g)[4] of the Indian Constitution mandate compassion toward animals, incidents of cruelty in industries such as dairy farming, entertainment, and animal testing continue to persist. Additionally, rapid urbanization and industrial expansion have further exacerbated the challenges in implementing animal protection laws.
This study aims to:
  1. Examine the historical evolution of animal welfare in India and its cultural significance.
  2. Analyze the gaps and challenges in the current legal framework governing animal welfare.
  3. Compare India's animal protection laws with international standards and best practices.
  4. Propose specific reforms to strengthen animal welfare laws, including stricter penalties, improved enforcement mechanisms, and enhanced legal protections for all species.
Thesis Statement:
India’s existing animal welfare laws, despite their strong historical and cultural foundations, are inadequate in addressing contemporary challenges due to weak enforcement, outdated penalties, and legal inconsistencies. Strengthening these laws through stricter penalties, improved regulatory mechanisms, and alignment with global best practices is essential to ensuring effective animal protection while upholding India’s constitutional and ethical commitments.
 
                                                                                     II.            CURRENT LEGAL FRAMEWORK
A.    Overview of the Prevention of Cruelty to Animals Act, 1960
The Prevention of Cruelty to Animals Act, 1960 (PCA Act) is India's primary legislation aimed at preventing cruelty to animals and ensuring their welfare. It was enacted to replace colonial-era laws and align animal protection with India's evolving ethical, social, and legal values. The Act established the legal foundation for safeguarding animals from unnecessary suffering and has been central to animal welfare regulations in India for over six decades. Experts and activists in the current century believe that this legislation may have aligned to the cultural values years back, but fails to align with the current animal welfare concerns.
 
B.     Other relevant legislations
1.      Bharatiya Nyaya Sanhita, 2023
o    Section 325: Criminalizes killing or maiming animals, prescribing imprisonment and fines. 
 
C.    Constitutional Provisions Related to Animal Welfare
The Indian Constitution recognizes the importance of animal welfare through various provisions:
o    Article 48: Directs the State to organize agriculture and animal husbandry on modern scientific lines and prohibit the slaughter of cows, calves, and other milch and draught cattle.
o   Article 51A (g): Establishes a fundamental duty for Indian citizens to show compassion toward animals.
o   Entry 17 (Concurrent List, Seventh Schedule): Allows both central and state governments to legislate on issues related to animal welfare.
 
D.    Recent Judicial Interpretations and Landmark Cases
Indian courts have played a crucial role in interpreting animal welfare laws and expanding protections through progressive judgments. Some landmark cases include:
1.      Animal Welfare Board of India v. A. Nagaraja (2014)[5] – Jallikattu Ban Case
 
FACTS:
The case addresses two primary sets of legal challenges related to Jallikattu and bullock-cart races. The first set involves the Division Bench Judgment of the Madras High Court, which upheld the validity of the Tamil Nadu Regulation of Jallikattu Act (TNRJ Act) and dismissed various writ petitions questioning the Ministry of Environment and Forest's (MoEF) Notification dated 11.07.2011. The appeal for a ban on Jallikattu dates back to 2006 when a petition was filed before the Madras High Court seeking permission to conduct the event. While the single bench initially banned Jallikattu, citing cruelty to animals, the Division Bench later overturned this decision, allowing the event under specific conditions. However, these conditions were often disregarded, prompting the Animal Welfare Board, a statutory body under Section 4 of the Prevention of Cruelty to Animals (PCA) Act, to issue a notification prohibiting the use of bulls as "performing animals."
 
The second set of cases involves challenges to the Division Bench Judgment of the Bombay High Court dated 12.03.2012, which upheld the MoEF Notification and the Maharashtra Government’s corrigendum that prohibited bullock-cart races, games, training, and exhibitions. In these cases, the petitioners approached the Supreme Court, seeking enforcement of the notification. The respondents, on the other hand, argued against a ban, citing cultural and traditional grounds to justify the continuation of Jallikattu and similar events.
 
ISSUES:
1.   Whether the events that are being conducted in the States of Tamil Nadu and Maharashtra are in violation of Sections 3, 11(1)(a) & (m), 21 and 22 of the PCA Act read with Articles 51A(g) and (h) of the Constitution.
2.      Whether provisions of the TNRJ Act, which is a State Act, is repugnant to the PCA Act, which is a Central Act, since both the Acts fall under Entry No. 17 in the Concurrent List.
 
JUDGEMENT:
The Court upheld the Animal Welfare Board of India’s (AWBI) stance that events like Jallikattu and bullock-cart races inherently violate Sections 3, 11(1)(a), and 11(1)(m)(ii) of the Prevention of Cruelty to Animals (PCA) Act. Consequently, the Central Government’s notification dated 11.07.2011 was upheld, barring the use of bulls as performing animals in such events across Tamil Nadu, Maharashtra, and the rest of India. The Court affirmed that the rights guaranteed to animals under Sections 3 and 11 of the PCA Act, read with Articles 51A(g) of the Constitution.
 
The Court emphasized the importance of protecting the “five freedoms” of animals within Sections 3 and 11 of the PCA Act. It directed the AWBI, central and state governments, and union territories to ensure the well-being of animals and prevent unnecessary pain and suffering. Officials in charge of animal care were mandated to follow measures that safeguard animals’ rights, including prohibiting their incitement to fight with humans or other animals, as outlined in Section 11(1)(m)(ii). Even in cases covered under Section 11(3), the Court directed that scientific methods should be adopted to avoid unnecessary harm to animals. Further, the AWBI and governments were instructed to educate the public about humane treatment of animals, in line with Section 9(k) of the PCA Act and Articles 51A(g) and (h). Parliament was urged to amend the PCA Act to strengthen penalties and elevate animal rights to constitutional status, as seen in other countries, ensuring their dignity and honor. Disciplinary measures were directed for officials failing to comply with the PCA Act and the Court’s declarations. The Tamil Nadu Regulation of Jallikattu (TNRJ) Act was deemed repugnant to the PCA Act and held constitutionally invalid under Article 254(1) of the Constitution, as previously observed in Vijay Kumar Sharma v. State of Karnataka. AWBI was directed to collaborate with the Society for Prevention of Cruelty to Animals (SPCA) to enforce the PCA Act effectively, submit periodic reports, and ensure appropriate follow-up actions to remedy violations. The judgment underscored the legislative and executive responsibilities in upholding animal welfare.
2.      People for Ethical Treatment of Animals (PETA) India v. Union of India (2016)[6] – Ban on Circus Animals
FACTS:
Article 51 (a)(g) of the constitution of India encompasses a fundamental duty on all citizens to show compassion towards living beings. The Performing Animals (Registration) Rules, 2001 was incorporated under the Prevention of crueltyCruelty to animalsAnimals Act,1960 and these rules were provided to safeguard performing animals from any kind of abuse and also to improve their conditions of training and expression. The Petitioner alleged that the mandatory provisions provided in these rules were being violated in the realm of cinematography which also included commercial advertisements. They pledged to the Union of India, To provide for a NO-OBJECTION CERTIFICATE from the Animal Welfare Board of India. They pledged to the Union of India, to implement the compulsory compliance of a no-objection certificate from the Animal Welfare Board of India in consonance with the censor board for depiction of animals in any cinematographic film.
 
ISSUES:
Whether the mandatory provisions of the Performing Animals (Registration) Rules, 2001, are being observed in the depiction of animals in cinematographic films, and whether the certification rules framed under the Cinematographic Act, 1952, must be harmonized with the Performing Animals (Registration) Rules, 2001, to protect the welfare of animals.
 
LAW:
Rule 3,7,8 and 16 of the Performing Animals (Registration) Rules, 2001 provide for the application of registration for hiring or lending performing animals used in the shooting of a cinematographic movie in India.
 
JUDGEMENT:
The Supreme Court, as reiterated in multiple landmark judgements held that the welfare of animals is a stated constitutional goal and the Performing Animals (Registration) Rules, 2001 must be adhered to with strict compliance and must be in harmonization with the certification rules to achieve the ultimate goal of ensuring welfare for animals. The court directed the Union of India and the Censor Board of India to obtain a No Objection Certificate from the Animal Welfare board of India certifying compliance with the Rules before certifying films for public exhibition. The Court also directed films for public exhibition to obtain a declaration that no cruelty was caused to the animals during the shooting of a film produced in India.
 
While India has a strong legal and constitutional framework for animal protection, weak enforcement, outdated penalties, and jurisdictional conflicts continue to undermine its effectiveness. The judiciary has played an active role in strengthening animal rights, but legal reforms are necessary to modernize existing laws and ensure stronger protections for all species.
 
CRITICAL ANALYSIS OF THE PREVENTION OF CRUELTY TO ANIMALS ACT, 1960
1.      Outdated Penalties:
      The Prevention of Cruelty to Animals Act, 1960 being an age-old tradition has outdated penalties, as low as twenty five rupees which significantly undermine its effectiveness. For perspective, when the Act was passed in 1960, Rs. 50 represented a significant sum; today, it is inconsequential for most offenders, particularly commercial establishments or businesses profiting from animal exploitation. This gap between the severity of animal cruelty offenses and their punishment creates a system where violators often view fines as merely a minor cost of doing business.
 
2.      Enforcement Challenges and Institutional Weaknesses
      This act faces significant implementation challenges due to limited capacity of enforcing such laws. The AWBI established under the Act, remains underfunded and understaffed relative to its nationwide mandate. Police officials, who are primarily responsible for enforcing the Act, often lack specialized training in animal welfare laws and may assign lower priority to animal cruelty cases compared to other crimes. Furthermore, the Act grants only limited authority to animal welfare organizations and inspectors, hindering their ability to effectively address cases of cruelty. The lack of a specialized enforcement unit dedicated to animal welfare violations exacerbates these difficulties.
 
3.      Lack of Explicit Recognition of Animal Sentience 
      The Act was enacted before significant scientific advancements in understanding animal cognition and sentience. Although it emphasizes preventing unnecessary pain and suffering, it does not explicitly acknowledge animals as sentient beings with emotions and intrinsic value. This conceptual gap influences how the Act is interpreted and applied, potentially limiting its effectiveness in safeguarding animals when their psychological well-being, rather than just their physical state, is at risk.[7]
 
4.      Challenges in Accessing Justice 
      The legal framework for addressing animal cruelty under the Act poses considerable obstacles to effective enforcement. Registering cases, collecting evidence, and pursuing prosecution are often time-consuming and complex.[8] The responsibility of proving cruelty typically falls on animal welfare organizations or concerned individuals, who may lack sufficient resources. Additionally, the Act does not mandate expedited hearings for such cases, leading to prolonged legal proceedings. As a result, animals involved may continue to suffer or, in many instances, perish before a resolution is achieved.
 
5.      Insufficient Alignment with Global Standards 
      India’s Prevention of Cruelty to Animals Act does not fully align with modern international best practices in animal welfare. Although it was considered progressive when enacted in 1960, it has not been comprehensively updated to reflect global advancements in animal protection. Key areas where the Act falls behind include regulations on farm animal welfare, the promotion of alternatives to animal testing, detailed guidelines for the transportation of animals, and standardized requirements for animal housing and care across different settings.
 
III.            A COMPARATIVE PERSPECTIVE ON ANIMAL WELFARE LAWS: INDIA VS. OTHER NATIONS
The Prevention of Cruelty to Animals Act, 1960 (PCA Act) was an important milestone in India’s animal welfare legislation at the time of its enactment. However, it has not been comprehensively revised to align with evolving global standards on animal protection. In contrast, several other countries have recognized animal sentience, increased penalties for cruelty, and established specialized enforcement agencies, highlighting the gaps in India’s regulatory framework.
 
A major distinction between India’s PCA Act and international laws is the legal acknowledgment of animal sentience. The Treaty of Lisbon (2009) of the European Union (EU) explicitly defines animals as sentient beings, requiring member states to integrate animal welfare considerations into policy decisions.[9] Similarly, New Zealand’s Animal Welfare Act (1999) affirms that animals can experience pain and distress, thus mandating legal protection for their mental well-being. Countries such as Canada and Australia have also integrated scientific findings on animal cognition into their legal frameworks. Conversely, the PCA Act lacks explicit recognition of animal sentience, which narrows the scope of legal protection against cases of neglect, psychological distress, and confinement.
 
Another critical shortcoming of India’s animal welfare law is its inadequate penalties for cruelty. For instance, the United Kingdom’s Animal Welfare Act (2006) imposes up to five years of imprisonment and unlimited fines for severe cruelty.[10] (Animal Welfare Act 2006, c. 45 (U.K.)). In Germany, penalties for animal abuse can reach €25,000, and courts may impose lifelong bans on animal ownership for offenders.[11] The United States strengthened its laws in 2019 with the Preventing Animal Cruelty and Torture Act (PACT Act), making extreme acts of animal cruelty a federal felony punishable by up to seven years in prison.[12]  In stark contrast, Section 11 of India’s PCA Act sets a maximum fine of ?50 for first-time offenses and ?100 for repeat offenses, which is insufficient to serve as a deterrent.[13] 
 
Another area where India falls behind is the enforcement of animal cruelty laws. Many nations, including the United States, United Kingdom, and Australia, have dedicated animal welfare enforcement agencies, with trained officers to investigate and prosecute cases. In India, however, enforcement responsibilities fall under the general police force, which often lacks the specialized training required to handle animal cruelty cases. Moreover, there is no dedicated department or authority specifically focused on animal welfare violations, resulting in delays in investigation, poor case resolution, and a low conviction rate. Without proper enforcement, even existing animal protection laws remain largely ineffective.
 
Finally, India’s approach to animal testing regulations remains outdated. Countries such as the EU, Norway, and Israel have completely banned cosmetic testing on animals, promoting cruelty-free alternatives. While India has prohibited cosmetic testing on animals, it does not have a comprehensive framework to encourage alternatives in pharmaceutical and industrial chemical testing. This regulatory gap results in continued animal suffering in research facilities, whereas international laws have progressively shifted toward humane testing methods.
 
                                                                                   IV.            IMPLEMENTATION STRATEGIES
A.    Phased Approach to Reform 
Strengthening animal welfare laws in India, particularly the Prevention of Cruelty to Animals (PCA) Act, necessitates a gradual and structured implementation strategy. The process should begin with a detailed evaluation of the current enforcement landscape across different states, identifying regional inconsistencies and pinpointing specific obstacles. This initial phase would involve gathering data on how effectively laws are being enforced, analyzing case resolution rates, and identifying procedural delays or inefficiencies. Following this assessment, a pilot initiative could be launched in selected districts that reflect varied geographical and socio-economic conditions to test revised protocols and enforcement mechanisms. 
In the second stage, successful strategies from the pilot program should be expanded to a broader scale, incorporating insights gained from the initial implementation. Adjustments should be made based on regional feedback, ensuring that the approach remains adaptable to local challenges. During this phase, legal frameworks should be gradually revised to eliminate loopholes and address emerging concerns. The final stage would involve nationwide standardization, establishing a uniform set of enforcement protocols while allowing for some flexibility to accommodate region-specific needs. Throughout this process, regular performance assessments and strategic refinements would ensure that the reforms remain effective and responsive to evolving circumstances. 
B.     Capacity Building for Enforcement Agencies 
For the successful implementation of animal welfare laws, enforcement authorities must undergo significant capacity enhancement. This should start with specialized training for police personnel, veterinarians, and members of the judiciary on legal provisions related to animal welfare, proper procedures for gathering evidence in cruelty cases, and ethical handling of rescued animals. These training programs must blend theoretical knowledge of the legal framework with practical, scenario-based exercises to enhance real-world application. 
Additionally, infrastructure improvements are crucial. Dedicated animal welfare units should be established within police departments in key districts, equipped with essential resources such as transport vehicles for animals, temporary shelter facilities, and forensic tools for evidence collection in cruelty cases. Moreover, the technological capacity of enforcement agencies should be strengthened through digital case management systems and advanced forensic analysis methods. Collaboration among agencies—including law enforcement, veterinary services, animal welfare boards, and NGOs—must be streamlined through formal coordination mechanisms, ensuring clear procedures for reporting, investigating, and prosecuting cases of animal cruelty. 
 C.  Stakeholder Engagement and Public Awareness 
Broad stakeholder participation and public awareness campaigns play a vital role in the effective enforcement of animal welfare laws. It is essential to establish formal consultative platforms that include government bodies, animal welfare groups, veterinary associations, farming communities, and local representatives. These platforms would provide a space for ongoing discussions on implementation challenges and the development of practical, balanced solutions that account for multiple perspectives. 
To enhance public awareness, targeted campaigns should be designed to reach diverse audiences through appropriate communication channels. While social media and digital outreach can be effective in urban areas, community-driven initiatives such as local workshops and village meetings should be prioritized in rural settings. Integrating educational content on animal welfare into school curricula can instill compassion for animals from an early age. Additionally, establishing community-based reporting systems, such as mobile apps, dedicated helplines, and trained volunteer networks, would empower citizens to actively report and intervene in cases of animal cruelty. Engaging religious and cultural leaders is also important, as they can promote traditional values of compassion toward animals while discouraging harmful practices under the guise of culture or tradition. 
D. Monitoring and Evaluation Frameworks 
A strong monitoring and evaluation system is essential to ensure that animal welfare laws are effectively enforced and consistently improved. This requires the development of clear performance indicators that assess both procedural efficiency (e.g., number of cases filed, speed of investigations, and conviction rates) and overall impact (e.g., reductions in cruelty incidents and improvements in animal health standards). To ensure consistency in reporting, standardized data collection protocols should be adopted across all jurisdictions. 
Regular independent audits by multidisciplinary teams—including legal experts, animal welfare advocates, and public policy specialists—should be conducted to evaluate implementation quality and identify systemic gaps. These evaluations should feed into a continuous improvement framework, where policy refinements and procedural enhancements are directly informed by audit findings. Furthermore, stakeholder feedback loops should be integrated into the monitoring system, allowing frontline enforcement officers, NGOs, and community members to share their experiences and suggest improvements. Leveraging technology-driven tracking systems can significantly enhance oversight by providing real-time data on case progress, resource allocation, and geographical trends in animal welfare violations.
 
  V.            IMPLICATIONS ON THE EFFECTIVE IMPLEMENTATIONS OF BETTER LAWS IN THE PREVENTION OF CRUELTLY TO ANIMALS ACT
The effective enforcement of strengthened animal welfare laws reflects a commitment to evolving ethical perspectives while upholding India’s deep-rooted cultural traditions of compassion for animals. Ancient Indian philosophical schools, including Hinduism, Buddhism, and Jainism, emphasize ahimsa (non-violence) and the intrinsic value of all living beings. Modern reforms to the Prevention of Cruelty to Animals (PCA) Act, when implemented effectively, would integrate these age-old ethical principles with contemporary scientific insights into animal sentience and cognitive abilities, recognizing animals as sentient beings capable of suffering rather than mere property.
 
This ethical shift has wider societal implications. Studies indicate a link between animal cruelty and interpersonal violence, highlighting how institutionalizing compassion toward animals contributes to broader social harmony. The rigorous enforcement of animal protection laws reinforces collective moral responsibility toward vulnerable beings, setting a standard for ethical treatment. Furthermore, these legal advancements align with the growing ethical consciousness of younger generations, who are increasingly factoring animal welfare into their lifestyle and consumer decisions. By strengthening animal protection measures through effective law enforcement, India not only reinforces its historical commitment to compassionate values but also positions itself as a global leader in the progressive ethical discourse surrounding animal rights.
 
                                                                                                                                VI.            CONCLUSION
The strengthening and effective enforcement of animal welfare laws in India, particularly the Prevention of Cruelty to Animals Act, marks a pivotal moment in the country’s legal, social, and ethical evolution. This study has highlighted that enhancing these laws goes beyond just safeguarding animals—it also intersects with public health, environmental sustainability, economic growth, and ethical progress. The phased approach to reform outlined in this discussion offers a practical and adaptable strategy, ensuring that improvements account for India’s diverse socioeconomic landscape while setting the foundation for long-term advancements. Recognizing that legal provisions alone are insufficient, this research underscores the importance of capacity-building measures such as training programs, infrastructure development, and interagency collaboration. These enhancements will help translate legal mandates into actionable protections. Additionally, broad stakeholder engagement and public awareness initiatives play a crucial role in shifting cultural attitudes toward greater acknowledgment of animal sentience and welfare needs. 
 
As India progresses on its development path, the way it addresses animal welfare will serve as a reflection of its broader commitment to sustainability, compassion, and justice. As Mahatma Gandhi famously said, "The greatness of a nation and its moral progress can be judged by the way its animals are treated." Strengthening the Prevention of Cruelty to Animals Act presents an opportunity to position India as a leader in animal welfare governance, striking a balance between tradition and progress, economic priorities and ethical considerations, human interests and the protection of vulnerable animals. Through well-structured reforms and committed enforcement, India can build a model framework that both honours its rich cultural heritage and meets evolving global standards for animal welfare.


[1] Chandrashekar, U., SFM. (n.d.). WILD LIFE PROTECTION
[2] V, J. (2019). The Sacred Animals of Hinduism. Hinduwebsite.com. https://www.hinduwebsite.com/hinduism/essays/sacred-animals-of-hinduism.asp
[4] Gov’t of India, The Constitution of India, art. 51A(g) (1950),
[5] Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India)
[6] People for Ethical Treatment of Animals (PETA) India v. Union of India, (2016) 14 S.C.C. 142 (India).
[7] David J. Mellor, Updating Animal Welfare Thinking: Moving Beyond the "Five Freedoms" Towards "A Life Worth Living", 6 Animals 21 (2016), https://www.mdpi.com/2076-2615/6/3/21.
[8] Animal Welfare Board of India, Annual Report on Animal Cruelty Cases in India (2021), available at https://awbi.gov.in.
[9] Treaty on the Functioning of the European Union art. 13, Feb. 7, 1992, 2012 O.J. (C 326) 47, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A12012E%2FTXT
[10] Animal Welfare Act 2006, c. 45 (U.K.)
[11] Tierschutzgesetz [Animal Welfare Act], § 17 (2006) (Ger.)
[12] Preventing Animal Cruelty and Torture Act, 18 U.S.C. § 48 (2019)
[13] Prevention of Cruelty to Animals Act, No. 59 of 1960, § 11 (India)

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