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A LEGAL ANALYSIS ON THE FEASIBILITY OF GRANTING ANIMAL RIGHTS CONSTITUTIONAL PROTECTION IN INDIA
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A LEGAL ANALYSIS ON THE FEASIBILITY
OF GRANTING ANIMAL RIGHTS CONSTITUTIONAL PROTECTION IN INDIA
AUTHORED BY - NIKARA FERNANDEZ
1. Introduction
Over time, many arguments have been made for and
against the issue of granting nonhuman animals legal personality. This requires
a shift from the ‘property status’ to a legal status that grants them inherent
and independent rights by virtue of the fact that they too share similarities
with humans such as sentience and decision-making capabilities. Currently,
animals are subject to various kinds of cruelty which will be discussed
throughout the paper. Despite India having various kinds of legislation to
protect animals, still the atrocities towards them continues. There is an
urgent need to provide them a suitable legal protection so that their
conditions and existence dose not deteriorate and become extinct one day. By
elevating their rights to a fundamental constitutionally protected level, they
will avail of justice more efficiently and wrongdoers/perpetrators will not be
able to circumvent the law as the Constitutional fundamental rights reign
supreme over the current statutory laws aimed at protecting the welfare of
nonhuman animals.
2. Evolution of animal protection in
India
A. Indian Philosophy
(i) Ancient period
The evolution of the relationship
between man and beast has seen significant changes over the history of
civilization. In India especially, animals hold an almost sacred position under
various religious texts. In the Dashavatara of Lord Vishnu, four of his ten
primary avatars are animals; these are Matasya (fish), Kuruma (turtle), Varaha
(boar) and Narsimha (half lion, half man). Similarly, numerous depictions of
Hindu Gods include animals by their side. Examples of the same would be Garuda,
the eagle of Lord Vishnu and Nandi, the bull of Lord Shiva. Certain Indian
mythological Gods themselves are depicted in the form of animals like Lord
Ganesha (elephant) and Lord Hanuman (monkey). Ancient Indian texts such as the
Vedas, Upanishads and Puranas all share the common essence of animals being
linked with Gods and Goddesses and hence they recognised animal rights to
co-exist with that of man. Animals, both domestic as well as wildlife were
worshipped by people and any cruelty meted out to them was severely punished.
The Manusmriti condemned hunting as a heinous act and directed the kings and
kshatriyas to forbear from the same. The Shlokas reflected the same ideal by
holding the caretaker of the animal responsible for the harm that happens to
any animal during the period it is in his care. The Isha Upanishad stated the
‘No creature is superior to any other. Human beings should not be above nature
and no species was to encroach over the rights and privileges of other species.’
The Indian ideal of ahimsa or
non-violence in thought and deed are reflected in the Vedas with respect to
animals. The Rig Veda condemned all forms of killing of animals, even for food.
The Yajur Veda stated that service to animals leads to heaven and the Atharva
Veda stated that the earth was created for the enjoyment of human beings and
creatures of all kinds alike. Jainism also believes strongly in the ideal of
non-violence as being a guide to all of morality. Jains looked after sick an
injured animals thousands of years before the idea of animal shelters were
thought of in countries abroad. The Epics such as the Ramayana, Mahabharata and
Bhagvad Gita all emphasize on the importance of showing mercy and sympathy to
all living things and avoiding cruelty to men and animals. However, these texts
did provide certain exceptions by permitting the killing of animals for
religious purposes.
(ii) Medieval period
The most prominent of the rulers of
Medieval India who took great measures to protect animals was the Mauryan ruler
Ashoka. The protection of elephants in particular was held in high regard by
him. He embraced Buddhism and protected many birds and animals and gave up the
tradition of the royal hunt. He also prohibited the killing of certain species
of animals such as parrots, rhinoceros, ruddy goose, etc. Medical facilities
for animals were also developed during his reign even in territories beyond his
own empire.
There was a change in heart during
the Mughal regime wherein hunting was once again adopted as a great sport.
Thus, there was a sharp decline in the wildlife population during this period
due to the lack of legal control on hunting.
(iii) British period
The early British period further led
to the exploitation of animals wherein people were rewarded for killing
animals. In the Presidency town of Madras for example, collectors paid 25
rupees for each specimen. The Maharaja of Kota in Rajasthan awarded anyone who
killed a lion with a prize of 25 rupees and as a result of the same, by 1920, the
lion was extinct in British India. Similarly, the cheetah population was
already in serious decline and is now extinct in India. There was a demand for
animal products as well such as goods made of tusks, skin and horns of the
animals.
(iv) Post-independence period
In the post-independence era, the
state of the wildlife population in India was bleak and people began to
recognise the urgent need to conserve and preserve the same. People needed to
be reminded of their duty towards the nonhuman animals and to treat them with
compassion and kindness. Mahatma Gandhi, stated that ‘the greatness of a nation
and its moral progress can be judged by the way its animals are treated’, this
appealed to the inner conscience of the people to take accountability for their
actions and stop treating animals with cruelty.
B. Western philosophy
However, over time, nonhuman animals,
rather than being respected for their inherent worth, started being looked at
as the property of man. In other words, animals were being used as a means to
an end. A strong propounder of this belief was the philosopher Immanuel Kant
who argued that since animals were neither rational nor autonomous, their lives
were not ends in themselves.[1]
Therefore, the duties that man had towards animals were merely indirect duties
they had towards humanity; treating animals with kindness was seen as a means
to strengthen the disposition of being kind to humans. Rene Descartes supported
the process of vivisection with the argument that animals were like clocks or
robots- machines that moved and made sounds but had no feelings.
A slight change in this outlook was
brought about by the philosopher Jeremy Bentham who posed the question of
whether animals could suffer[2].
This brought in the idea of animals being sentient beings, having the capacity
to feel pain and pleasure. Peter Singer, an Australian Philosopher, further
proposed[3]
various theories to further buttress the argument posed by Bentham that the
difference between animals and man was one of degree, rather than kind.
Hierocles, a Neoplatonist philosopher of Greece put forward his theory of the
Circles of Compassion wherein he stated that man lived in a series of
concentric circles. The innermost circle was believed to be the body and the
outermost one was to be the universe. To move these circles inwards was
believed to be the continuous task of moral development. Singer extended this
metaphor to back his theory of animal rights by stating that one must
explicitly extend the circle of his/her own concern beyond the boundary of
his/her species to include animals and the environment as well.
The strongest theory that has been
propounded which can be used as an argument in favour of granting animals legal
rights is Martha Nussbaum’s capabilities approach which will be elaborated upon
later in this paper.
3. Constitutional provisions
Although the Constitution of India
contains certain provisions that aim towards animal welfare, these provisions
are merely guidelines that cannot be enforced against any individual. This is
the issue that needs to be fixed by introducing provisions that can actually be
implemented and put into effect rather than merely act as words on a piece of
paper. A majority of these provisions are in the form of Directive Principles
of State Policy which are the duties imposed upon the State. Article 48[4]
deals with the organization of agriculture and animal husbandry. It states that
such organization must be based on modern and scientific lines and that the
State should take measures to preserve and improve the existing breeds and
prohibit the slaughter of cows, calves and other milch and draught cattle.
In one of the Constituent assembly
debates[5] it
was argued by Pandit Thakur Das Bhargava, Seth Govind Das and R.V. Dhulekar
that the provisions prohibiting cow slaughter should be included within the
ambit of Fundamental Rights however the same was rejected by Dr. B.R. Ambedkar
on the grounds that Fundamental Rights dealt only with human beings and not
animals. Article 48A[6]
deals with the duty of the State to protect and improve the environment and
safeguard the forests and wildlife of the country.
Article 51A(g)[7]
forms a part of the fundamental duties of an individual. According to this
Article, it is the duty of every citizen of India to protect and improve the
natural environment including the forests, lakes, rivers and wildlife and to
have compassion for living creatures. The aspect of humanism which forms a part
of Article 51A(h)[8]
indicates an inclusive sensibility for our species as it involves feelings of
benevolence, compassion and mercy. Humanism also includes the duty of man to
look after the welfare and well-being of animals and to prevent the infliction
of pain or suffering on them. There have been numerous case laws that have
dealt with these two articles which will be discussed further in the paper.
Article 246 of the Constitution[9] is
known as the 7th schedule of the Constitution and it specifies the
three lists which divide the powers of governance between the Union and the
States. Item 17 and 17B of the Concurrent list deal with the prevention of
cruelty to animals and the protection of wild animals and birds respectively.
Item 15 of the State list deals with the preservation, protection and
improvement of livestock and the prevention of animal diseases. It also
includes the acts of veterinary training and practice. Item 15 of the 12th
Schedule also deals with the prevention of cruelty to animals.
4. Common law remedies
The Indian Penal Code[10]
has certain provisions that aim at protecting animal welfare. Section 47 of the
Code provides a definition for the word ‘animal’ to mean any living creature
other than a human being. Killing of such animals in public places amounts to
public nuisance under Section 268 of the Code as it can be deemed to cause
common injury, danger, or annoyance to the public/people in general who occupy
property or dwell in the vicinity. Section 428 of the Code provides a penalty
of a maximum of two years imprisonment/fine/both for those people who cause
mischief by killing/maiming/poisoning/rendering useless animals of the value of
Rs.10. Similarly, Section 429 of the Act provides a penalty of a maximum of
five years imprisonment/fine/both for those individuals who cause mischief by
killing/maiming certain specified cattle and animals of any value or any animal
of the value of Rs.50. These two provisions essentially make it a punishable
offence to kill or injure any animal including strays. It is therefore the duty
of every civil person to take all responsible measures to ensure the well-being
of animals and prevent cruelty towards them.
Section 503 of the Code deals with
criminal intimidation which can be applied in such cases where animals are seen
as the property of man. The remedy for the same is found under Section 506 of
the Code.
Following the above authorities,
several Acts and rules have been made by the legislature and executive to
specifically address problems of exploitation and cruelty towards animals but
these too provide numerous exceptions and are not adequately implemented and
enforced. Examples of the same would be the Prevention of Cruelty to Animals
Act[11],
the Wildlife (Protection) Act[12],
the Drugs and Cosmetics Act[13]
(regarding the use of animals in cosmetic testing), the Slaughterhouse Rules
2001, etc. Discussing the shortcomings of the same is beyond the scope of this
paper but it is clear that they have fallen short of their objectives as
instances of cruelty towards animals with complete disregard of their rights
continue to take place unabated.
5. The Capabilities Approach
The Capabilities Approach is a unique
proposition which poses a logical explanation as to how nonhuman animals
deserve legally protected rights as they possess several similar
characteristics (which she terms as ‘capabilities’) to human beings who are
granted these same legal rights and personality. Nussbaum proposed the same in
her book titled ‘The Quality of Life[14]’
in 1993 wherein she defined capabilities as ‘universal objective norms,
rejecting cultural relativism and the charge that all universals are bound to
be insensitive to regional and cultural specificity’. She proposes ten capabilities,
nine of which are applicable to nonhuman animals. Several Indian case laws that
have been decided by the judiciary over the years relating to the prevention of
cruelty and exploitation to animals reflect the principles put forward in the
capabilities approach. For example, in the case of N.R. Nair v. Union of India
and Ors[15].,
there was a notification issued by the Central Government on the 2nd of March,
1991 under Section 22 of the PCA Act banning the training and exhibition of
bears, monkeys, tigers, panthers and dogs. The Indian Circus Federation
challenged this notification by which dogs were excluded from the list. An
order was then issued in 1997 by the Delhi High Court requiring the Government
of India to have a fresh look into the notification. The Committee prohibited
this notification. The present petitioners thus stated that this order was
arbitrary and that the Central Government had no right to issue such
notifications banning the exhibition and training of any animal. The Court
however, affirmed the order of the High Court in banning the appellants from
training or exhibiting the animals in keeping with the aims and objectives of
the PCA. In short, the capabilities are as follows:
i)
The
capability to continue one’s life whether they take a conscious interest in the
same or not. This parameter puts a particular pressure on the meat industry to
reform its practices of killing nonhuman animals for human consumption. It also
stirs up the debate of whether one is justified in following a non-vegetarian
diet when it has scientifically been proven that it is indeed possible for man
to life a healthy life to the fullest and derive their source of protein from
alternate sources and dietary supplements. This also indicates the problematic
nature of killing animals for sport and fur and in general any activity that
causes harm to the life of a nonhuman animal in order to bring about some human
benefit.
ii)
The
capability of an animal to have their bodily health protected. This can be
respected by banning cruel treatment of animals and neglect as well as the
confinement and ill-treatment of animals in their use in industries.
Industries, especially circuses mete harsh and cruel treatment to the working
animals by making them perform trivial acts that go against their natural
tendencies. This parameter is also applicable in the regulation of zoos and
demands that zoos maintain adequate nutrition and space for their animals.
iii)
The
capability of maintaining one’s bodily integrity. This is applicable to the
prohibition of declawing and tail docking which is done to nonhuman animals in
order to make them more attractively appealing for humans. These processes
cause immense pain to the animals, both mentally and physically. An Indian case
law that dealt with the same was that of KCI v. UOI[16]
wherein The petitioner was alleged to be subjecting puppies of certain breeds
such as Doberman, Cocker Spaniel, Great Danes and Boxers among others to
unnecessary and avoidable cruel cosmetic surgeries such as tail docking and
cropping of their ears on request of the dog owners. This was alleged to be
against the law as it was causing immense pain, suffering and discomfort to the
animals which amounted to cruelty under the PCA Act, 1960 which is a punishable
offence. The Court held that Section 11(3) of the PCA Act provided for certain
situations wherein the provisions of the Act are inapplicable. Applying this
Section to the tail docking and ear cropping of dogs, the same cannot be
brought under the ambit of cruelty provided it was being done in a safe manner,
as prescribed by the law.
iv)
The
capability of recognising ones senses, imagination and thought. This mandates
that nonhuman animals should have free access to sources of pleasure to their
being and should be allowed to move freely in an environment in such a manner
as to please their senses.
v)
The
capability of feeling emotions and being entitled to lives where they can have
attachment to others which are not controlled by some human external force
putting them in a position of isolation or fear. This is applicable to farm and
zoo animals that are confined in cages away from others of their kind who form
the objects of their natural affection.
vi)
The
capability to practically exercise their sense of reason and frame goals and
projects to plan their lives. This is not entirely applicable to nonhuman
animals but can be extended to giving them adequate room to move around and
opportunity for activity wherever the animal is capable of doing so.
vii)
The
capability of forming affiliations that are rewarding rather than tyrannical in
nature and live in a place of public culture that respects these nonhuman
animals and treats them as dignified beings.
viii)
The
capability of living in an interdependent world where all species therein
cooperate and form mutually supportive relations with one another.
ix)
The
capability to play which is central to the lives of sentient animals. They
require space, light, sensory stimulation and the presence of other members.
x)
The
capability of controlling ones own environment wherein nonhuman animals are
treated with respect and justice and can be represented in a Court of law.
Nussbaum however recognises that this
switch from using nonhuman animals as a means to an end cannot happen overnight
and they will have to be exploited for some necessities. There should thus be a
balance that is struck wherein these animals are only used for food and
research. While these exceptions can be permitted, it is essential that the
treatment of these animals is improved during their life and to ensure that
they are killed in the least painful manner. In research as well, it should be
ensured that their living conditions are improved and such research is carried
out only when absolutely necessary on less complexly sentient animals and this
process is shifted to computerised methods. There thus needs to be shift from
the approach of ‘freedom from’ to ‘freedom to’.
The current Indian laws lack adequate
and stringent punishment for instances of cruelty and exploitation for these
nonhuman animals and even where provisions for punishment exist, they are
measly and can be easily bypassed through loopholes in the law. In order to
provide absolute protection to these nonhuman animals, they need to be awarded
legal personality and given rights in the supreme law of the land namely the
Indian Constitution. This would require a shift from the property status of
animals to one of personhood. The capabilities approach suggests the inclusion
of a commitment to recognise animals as subjects of political justice as well
as a commitment that they will be treated with dignity in every nation’s
Constitution. The mere inclusion of animal recognition in constitutional provisions
is not adequate in itself to enshrine the extensive protection for animals[17]
6. International measures
A. The European Convention for the
Protection of Animals during International Transport (1968)
This was an important step taken at
the international level to ensure that the right of animals to humane
treatment, consistent with the modern conceptions of animal welfare is
guaranteed to animals even during their transport across borders. It focused on
the importance of international cooperation and detailed rules for the same
have also been established for the transport of these nonhuman animals by rail,
road, water and air. What is lacking however are studies as to the specific
welfare requirements for each animal as these studies have not yet been
completed. Some of the essential welfare requirements laid down in this
Convention are that the animals must be proven to be fit for transportation,
given adequate rest both before as well as after the journey, given adequate
space, ventilation and supply of food and water. An Indian judgement that dealt
with similar instances is that of Gauri Maulekhi v. State of Haryana and Ors[18].
wherein camels were being brought into the State of Haryana illegally. The
transportation of these animals was being done in a cruel manner as a result of
which some of them would succumb to suffocation, over-crowding and injuries
that were inflicted upon them by their handlers. These animals who did not die
on route would be slaughtered soon after reaching the destination which is in
violation of the law, namely the Prevention of Cruelty to Animals Act, 1960.
The Court held that according to the Foreign Trade (Development and Regulation)
Act, 1992, live cattle and buffalo fell under the scope of animals that cannot
be exported without the exporter having a license to export them. The Court
also held that transporting the cattle in such manner was subjecting them to
unnecessary pain and suffering and hence fell under the definition of Cruelty
under the PCA Act. The case of Mrs. Gauri Maulekhi v. State of Uttarakhand and
Another[19]
dealt with the housing facilities for hens which prior to the case were carried
out in a deplorable condition in battery cages which the petitioner alleged was
illegal as it amounted to subjecting the hens to unnecessary torture.
B. International Constitutions
A Constitutions all over the world such as the Basic law for the
Federal Republic of Germany[20],
the Swiss Constitution[21],
the Civil Code of Austria[22],
the Constitution of the State of Salzburg[23]
and the Constitution of Slovenia[24]
have included provisions that indicate their commitment towards animal welfare.
However there needs to be a shift from the focus of animal welfare to animal
rights as the latter hold more water in protecting animals than the former.
Gillespie[25]
aptly stated that the international treaties as well (for example the ICPA[26],
the International Convention for the Regulation of Whaling (1946), CITES[27]
and CMS[28])
focus on conserving the nonhuman animals and preventing them from becoming
extinct as a species rather than extending justice to them in recognition each
individual animal can experience pain and pleasure. David Favre writes[29]
that on an international level, although ‘the
environmental perspective of the importance of
wildlife as part of ecosystems is well accepted, the conditions of life and death of individual animals at the
hands of humans around the world are not yet a
focus of legal drafting’.
C. The Universal Declaration on Animal Welfare (2000) (UDAW)
This was a campaign conceived and proposed by a
group of prominent animal welfare organisations all around the world in order
to get the same adopted by the United Nations to universally recognise that
animals are sentient and that animal welfare must be protected by all member
states to aid in the achievement of globally important goals (the SDGs).
Although it has not yet been adopted by the United Nations General Assembly, it
contains important provisions that aim at improving the welfare of nonhuman
animals. There have however been sceptical arguments against this declaration
as it might not be all that effective in reality as it focuses on a
welfare-based approach rather than a rights based one. Additionally, a
declaration is an unenforceable object against any of its signatories as they
have no binding effect on its member States to do or stop doing anything. At
best, this would create a general affirmation that animal welfare issues are
important to the global community[30].
The UDAW is being led by the World Society for the Protection of Animals which
is premised on the Universal Declaration of Human Rights (1948). What is also
hoped is that just as how the UDHR became the basis for subsequent enforceable
international conventions, the UDAW would do the same for animals which will
also urge nations to adopt a rights-based approach towards animals in their
Constitutions.
D. The Animal Rights Movement
The animal rights movement which is also
referred to as the abolition movement sees man’s use of animals as the key
problem behind the exploitation of nonhuman animals. This movement seeks to
challenge the property status of animals and instead secure for them
fundamental rights that are absolutely protected and cannot be sacrificed under
any circumstances to a higher human need. Tom Regan[31]
calls this movement one that seeks ‘no cages’ for animals. Gary Francione in
one of his articles[32]
provided a set of criteria for measuring whether any law actually recognises
that animals have more than a mere extrinsic value and this is an incremental
step towards making laws that completely abolish the property status of
animals.
7. Important judgements
A landmark judgement in the international sphere that aimed
at granting at least some nonhuman animals who have the capacity to possess
legal rights a common law status rather than the status of mere things was that
of Leo v. Stanley[33]
wherein the petitioner sought to grant the petition on be behalf of two adult male chimpanzees who
were held at a University in New York and used as research subjects in studies
on the locomotion of chimpanzees and other primates. The essence of this case
was to grant legal rights for chimpanzees and ultimately for other animals as
well. Unfortunately, Judge Barbara Jaffe issued notices stating that
chimpanzees are neither legal persons nor quasi-persons as personhood works in
an ‘all or nothing’ fashion.
A landmark Indian judgement that reflects the notions of
animal welfare is that of AWBI v. A. Nagaraja and Ors.[34]
wherein two issues were brought before the Supreme Court of India. One was
challenging the validity of the Tamil Nadu Regulation of Jallikattu Act, 2009
(TNRJ Act) and the other was challenging the Central Government notification
dated 11.7.2022 under Section 22(ii) of the Prevention of Cruelty to Animals
Act, 1960 (PCA Act). The plaintiff was a board that was established under
Section 4 of the PCA with the specific purpose of promoting animal welfare and
protecting animals from being subjected to unnecessary pain or suffering. It
brought this present petition to the Court as they alleged that the practice of
Jallikattu was violative of Sections 3, 11(1)(a) and (m) and Section 22 of the
PCA Act. It was alleged that the manner in which the practice of Jallikattu was
conducted subjected the bulls to physical and mental torture merely for human
pleasure and enjoyment. They asserted that the PCA Act, being a parliamentary
legislation an overriding effect over any historical, cultural or religious
practice. Moreover, bulls were not included under the ambit of ‘performing
animals’ under Sections 21 and 22 of the Act. The petitioners also alleged that
subjecting the bulls to such unnecessary pain and suffering went against
Articles 51A(g) and 21 of the Constitution of India. The Court held that animal
welfare laws were required to be interpreted while keeping in mind the welfare
of the best interest of the animals to just exceptions only out of human
necessity which have been enumerated under Sections 11(3) and 28 of the PCA
Act. Jallikattu did not fall under the protection of this provision as it was
an avoidable practice and hence cannot be permitted under law.
Another recent case that recognised nonhuman animals as
being legal personalities worthy of carrying rights was that or Karnail Singh
v. State of Haryana[35]
which dealt with the secret export of cows to Uttar Pradesh in a truck. The
police picketed the truck at the border and recovered the truck and the driver
as well as the conductor. The cows were packed in a cruel and brutal manner
without following the rules laid down by the State of Haryana regarding Motor
Vehicles. The Court stated that ‘The conferral of legal personality upon
rightless objects or beings carries with it legal recognition that those
objects of beings have ‘worth and dignity’ in their own right. The Court also
held that ‘The entire animal kingdom including avian and aquatic are declared
as legal entities having a distinct persona with corresponding rights, duties
and liabilities of a living person. All the citizens throughout the State of
Haryana are hereby declared persons in loco parentis as the human face for the
welfare/protection of animals.’ The Court concluded this judgement with the
adage, ‘Live and let live.’
8. Conclusion
It is therefore evident that the judiciary has already
taken steps to declare that nonhuman animals are indeed legal persons and are
capable of having legally enforceable rights. It is upto the legislature to put
pen to paper and include these rights within the ambit of fundamental rights so
that animal rights litigations can be efficiently handled and animals are given
the justice they inherently deserve. By giving animal rights the status of
fundamental rights, it will be easy for individuals to take up the cause of the
animals and represent them in a Court of law through the writ jurisdiction of
Courts under Articles 32 and 226 of the Constitution. This will bring numerous
other instances of animal exploitation that go unnoticed to the surface so that
the legislature can identify the gaps in the legislative framework and
amend/pass new laws to fix the same.
[1] Gail
Tulloch, Steven White, ‘A Global Justice Approach to Animal Law & Ethics’
[2011] 6 Austl. Animal Protection Law Journal 29
[2] Jeremy
Bentham, An introduction to the principles of morals and legislation,
(Dover Publications 2007)
[3] Peter
Singer, Animal Liberation: A New Ethics for Our Treatment of Animals,
(HarperCollins 1975)
[14] Nussbaum, Martha, and Amartya Sen
(eds), ‘The Quality of Life’ (1993)
Online edition, Nov. 2003), <https://doi.org/10.1093/0198287976.001.0001> accessed 28 Oct. 2022
[17] White, S.,
‘Into the Void: International Law and the Protection of Animal Welfare’ (2013)
Glob Policy, 4: 391-398
accessed 10 October 2022
[32] Francione,
Gary L. Rain without Thunder: The ideology of the animal rights movement
(Temple University Press 1996)
Article Information
A LEGAL ANALYSIS ON THE FEASIBILITY OF GRANTING ANIMAL RIGHTS CONSTITUTIONAL PROTECTION IN INDIA
Authors: NIKARA FERNANDEZ
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/04/26
- Volume 2
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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