Introduction:

In a significant public interest ruling aimed at balancing urban safety, public health, and environmental concerns, the Madhya Pradesh High Court directed the Indore Municipal Corporation to identify prominent public and tourist places in the city and undertake a top-priority drive for the removal of stray dogs from such locations. The order was passed by a Division Bench comprising Justice Vijay Kumar Shukla and Justice Binod Kumar Dwivedi while hearing a long-pending Public Interest Litigation titled Doing Needful Association of a Young People Plantation Group [WP No. 15275 of 2019]. The petition primarily sought directions for the removal of livestock such as cattle, sheep, and goats from city limits to protect urban greenery and ensure public safety, but the issue of the growing menace of stray dogs was also squarely raised during the proceedings. Referring to the Supreme Court’s suo motu decision titled “City Hounded by Strays, Kids Pay Price”, the High Court underscored that civic authorities cannot remain passive in the face of rising incidents of dog bites and threats to public safety, especially in crowded public spaces and tourist hubs like Chhappan Dukan and Sarafa. The Court not only mandated immediate action but also imposed accountability mechanisms, including filing of affidavits and the possibility of the Commissioner’s personal appearance, thereby elevating the issue to one of urgent municipal governance and constitutional responsibility.

Arguments on Behalf of the Petitioners and Intervenors:

The petitioners, representing a social organisation concerned with environmental protection and urban order, argued that the unchecked presence of livestock and stray animals within city limits had severely affected greenery, road safety, and the quality of life of residents. While the original PIL focused on cattle, sheep, and goats roaming freely in the city, the intervenors forcefully highlighted the grave and growing menace posed by stray dogs. It was submitted that the entire city of Indore was facing serious problems due to aggressive and unsterilised stray dogs, with frequent incidents of dog bites being reported, including attacks on children, elderly persons, and morning walkers. The intervenors contended that despite repeated judicial directions and public outcry, the municipal authorities had failed to implement an effective and sustained sterilisation and relocation programme. They argued that public places, markets, and tourist destinations had become unsafe, adversely affecting not only residents but also visitors, thereby harming the city’s reputation as a clean and tourist-friendly destination. Emphasising the Supreme Court’s suo motu intervention on stray dog attacks, the intervenors submitted that compliance with apex court directions was mandatory and non-negotiable, and that selective or cosmetic measures would not suffice. They urged the High Court to issue strict directions with timelines and monitoring mechanisms to ensure that the Municipal Corporation discharges its statutory and constitutional duties.

Arguments on Behalf of the State and Municipal Corporation:

The State, through its counsel, submitted that the Indore Municipal Corporation had already undertaken several measures to address the issue of stray animals within city limits. It was contended that the Corporation regularly engages in the removal of stray cattle and had taken steps concerning stray dogs as well, including sterilisation drives and relocation efforts. The State attempted to reassure the Court that the civic body was conscious of its responsibilities and that action was being taken within administrative and logistical constraints. It was further submitted that managing stray animals in a large and populous city posed complex challenges, including availability of infrastructure, manpower, and coordination among departments. However, the submissions remained largely general in nature, without placing detailed data or concrete action plans before the Court, particularly regarding the extent of sterilisation of stray dogs or focused drives in sensitive public and tourist areas. This lack of specific information appeared to weigh with the Court while considering the necessity of issuing further directions.

Court’s Judgment:

After hearing the parties and considering the material on record, the Madhya Pradesh High Court expressed clear dissatisfaction with the absence of a structured, transparent, and accountable action plan to address the menace of stray dogs. The Division Bench placed strong reliance on the Supreme Court’s suo motu decision in “City Hounded by Strays, Kids Pay Price”, reiterating that directions issued by the apex court are binding and must be implemented in both letter and spirit. The Court directed the Indore Municipal Corporation to comply with all directions previously issued by the Supreme Court as well as those reproduced in the High Court’s earlier order dated 25.11.2025. To ensure meaningful compliance, the Bench ordered that the Commissioner of the Municipal Corporation must convene a meeting of all concerned officers within 10 days, and prepare a comprehensive action plan addressing the issue of stray dogs. Importantly, the Court specifically instructed the Corporation to identify prominent public and tourist places, including Chhappan Dukan and Sarafa, and to conduct a top-priority drive for the removal of stray dogs from these areas. The Court further directed the Corporation to file a detailed action report before the next date of hearing, including data relating to sterilisation of stray dogs, which must be supported by an affidavit of a senior officer of the Corporation. In a strong warning aimed at ensuring accountability, the Bench observed that if the action report was found unsatisfactory, it would not hesitate to direct the personal appearance of the Commissioner, Municipal Corporation, Indore. By doing so, the Court made it clear that civic apathy or half-hearted compliance would not be tolerated where public safety and welfare are at stake. The matter was listed for further consideration on 13 January 2026, keeping the issue under close judicial scrutiny.