What did the Supreme Court decide in AWBI v. A. Nagaraja?

The Court banned using bulls and bullocks for entertainment like Jallikattu and bullock-cart races, holding such practices violate the PCA Act.

Which PCA Act sections were central to the case?

Section 3 (duties to ensure welfare and prevent unnecessary suffering) and Section 11 (penal provision against cruelty) were central.

What are the Five Freedoms the Court emphasized?

Freedom from hunger/thirst, discomfort, fear/distress, pain/injury/disease, and freedom to express normal behaviour.

Could the government de-list bulls as performing animals?

Yes. The Court upheld the notification removing bulls from the performing animals list, prohibiting their training and exhibition.

Did international animal welfare principles matter?

Yes. The Court read animal welfare in line with global principles and India’s constitutional values protecting life and dignity.

Animal Welfare Board of India v. A. Nagaraja (2014)

PUBLISH_DATE: 31 Oct 2025 AUTHOR_NAME: Gulzar Hashmi LOCATION: India PRIMARY_KEYWORDS: Jallikattu ban, PCA Act, Five Freedoms, Animal rights SECONDARY_KEYWORDS: Section 3, Section 11, Performing animals, MoEF notification 2011, Bullock-cart races, Tamil Nadu, Maharashtra, AWBI

Quick Summary

The Supreme Court examined whether Jallikattu and bullock-cart races violate the Prevention of Cruelty to Animals Act, 1960. The Court focused on animal welfare duties and “unnecessary suffering.”

It banned using bulls/bullocks for entertainment, upheld the de-listing of bulls as performing animals, and directed protection of the Five Freedoms of animals.

Issues

Do Jallikattu and bullock-cart races violate the PCA Act?
Could the Animal Welfare Board/Government exclude “bulls” from the performing animals list?
Do these practices violate international animal welfare principles and rights-based standards?

Rules

PCA Act — Section 3

Two duties: ensure animal well-being and prevent unnecessary pain/suffering by taking reasonable measures.

“Unnecessary Suffering” Test

Ask: could suffering be avoided/reduced? Was conduct law-compliant? Was there a legitimate purpose?

Facts (Timeline)

Timeline graphic for AWBI v. A. Nagaraja

AWBI reports/photos: Showed torture and cruelty to bulls during Jallikattu and races—tail twisting, poking, deprivation, injuries, deaths.

2006: Ban sought before Madras High Court; AWBI moved to bar bulls as performing animals.

11 Jul 2011: MoEF notification removed bulls from performing animals list—banning their training and exhibition.

Post-2011: Notification and related writ petitions were challenged in High Courts; matters were clubbed and decided here.

Arguments

Appellant (AWBI)

Events cause unnecessary suffering, violating Sections 3 and 11.
Bulls are unsuitable for such performances; injury and distress are inherent.
Global welfare norms and Five Freedoms must guide Indian law.

Respondents (Organisers/States)

Claimed tradition and cultural value; argued for regulation instead of ban.
Maintained that proper safety measures could reduce harm.
Questioned scope of de-listing bulls as performing animals.

Judgment (Held)

Judgment illustration for AWBI v. A. Nagaraja

Animals must not be used for entertainment that causes suffering; Jallikattu and bullock-cart races were banned.
Bulls shall not be used in races, fights, or performances; de-listing as performing animals is valid.
Duties under Section 3 were breached; practices caused immense cruelty.
Section 11 is a beneficial, penal provision; “unnecessary pain or suffering” and the phrase “or otherwise” are to be read broadly.
Authorities must protect the Five Freedoms of animals; welfare aligns with the broader understanding of Article 21 values.

Ratio Decidendi

Welfare over spectacle: When performance inherently inflicts avoidable pain, the PCA Act requires prevention, not mere regulation. Bulls/bullocks cannot be used for entertainment events.

Why It Matters

Sets a strong precedent on animal rights and dignity.
Affirms broad reading of unnecessary suffering and state duties.
Aligns Indian law with global welfare standards and Five Freedoms.

Key Takeaways

No bulls for entertainment: ban stands.

Sections 3 & 11 read widely to curb cruelty.

Five Freedoms guide policy and enforcement.

MoEF de-listing of bulls as performing animals upheld.

Mnemonic + 3-Step Hook

Mnemonic: “Pain? Not Entertainment.”

Spot the suffering — avoidable pain is unlawful.
Shield with Sections 3 & 11 — read them broadly.
Secure Five Freedoms — welfare over spectacle.

IRAC Outline

Issue

Whether Jallikattu and bullock-cart races violate the PCA Act and if bulls can be excluded as performing animals.

Rule

Section 3 duties + Section 11 cruelty prohibition; “unnecessary suffering” interpreted broadly with welfare focus.

Application

Evidence showed systematic cruelty; safeguards couldn’t remove inherent suffering in such events.

Conclusion

Ban upheld; bulls de-listed; authorities to ensure Five Freedoms and strict PCA enforcement.

Glossary

PCA Act, 1960: India’s main animal welfare law that prevents cruelty and sets duties for care.
Performing Animal: An animal trained/exhibited for shows; bulls were removed from this list in 2011.
Five Freedoms: Core welfare standard: free from hunger/thirst, discomfort, fear/distress, pain/injury/disease; free to express normal behaviour.