DAMODARAM SANJIVAYYA, NATIONAL LAW UNIVERSITY

SABBAVARAM, VISAKHAPATNAM, A.P., INDIA

PROJECT TITLE:

CASE ANALYSIS: -----

Animal Welfare Board of India v. A. Nagaraja 2014 7 SCC 547

SUBJECT:

Legal Language and Writing

NAME OF THE FACULTY:

Dr. Narasinga Rao Barnika

SUBMITTED BY:

Siddhi Vinayak

ROLL NUMBER:

22LLB133 Semester: II

Page | 1
 ACKNOWLEDGMENT

First and foremost, I Siddhi vinayak thank the almighty God for the kindness and grace,
which enabled me to complete this project despite several problems. It is a happy
responsibility on my part to express my heartfelt appreciation to my family members who
have always provided me with inspiration, direction, and support during this project's
preparation. Words cannot describe my gratitude to my professor Dr. Narasinga Rao
Barnika, Damodaram Sanjivayya National Law University, Visakhapatnam for his
meticulous direction, insights, constructive criticism, inspiration, and moral support in
completing this project task. His thorough dedication and well-organized work style have
greatly aided in the execution of my project. With his distinctive good humor, he was always
there to cheer me up. This project is being submitted not only to earn good scores, but also to
increase my topic understanding and writing skills. I tried my utmost to acquire proper and
relevant information on the subject so that I could present a clear picture of the project's
topic. Any errors in my project are entirely my own.

Page | 2
 TABLE OF CONTENTS

ACKNOWLEDGMENT................................................................................................................. 2

TABLE OF CONTENTS................................................................................................................ 3
ABSTRACT.................................................................................................................................... 4
SYNOPSIS...................................................................................................................................... 5
INTRODUCTION .......................................................................................................................... 7
BACKGROUND ............................................................................................................................ 9

FACTS & ISSUES.............................................................................................................................. 11

PETITIONER&RESPONDENTARGUMENTS................................................................................... 12
EVALUATION............................................................................................................................. 13
INTERNATIONAL PERSPECTIVE:.......................................................................................................... 13

LEGAL & CONSTITUTIONAL ASPECT:................................................................................................. 14

JUDGEMENT............................................................................................................................... 16
CONCLUSION............................................................................................................................. 18
BIBLIOGRAPHY......................................................................................................................... 19

Page | 3
 ABSTRACT

Jallikattu, also known as “yeru thazhuvuthal” (grabbing the bull) or “manju virattu” (chasing
the bull), is a two-thousand-year-old Tamil Nadu bull-taming sport held during the harvest
festival Pongal. The sport gets its name from the terms ‘calli’ and ‘kattu,’ which mean ‘coins’
and ‘package,’ respectively, and refers to a daring attitude in which men grasp the bull's
hump in an attempt to conquer it by bringing the bull to a halt and claiming the prize. Several
animal rights advocates and environmentalists have applauded the Indian Supreme Court's
recent ruling outlawing Jallikattu, bullock cart races, and “other comparable activities.” The
judgement incorporates ecocentric (“term used by environmental philosophers and ecologists
to denote a nature-centered”), ideas into Indian law in order to acknowledge animals'
"intrinsic value," based on many international accords and accepted legal positions on animal
care in other countries. The case-note examines the judgement in light of prior Supreme
Court and Madras High Court rulings on the subject.

Keywords: Jallikattu, Ecocentrism, Yeru thazhuvuthal, Manju virattu

Page | 4
 SYNOPSIS

Objective of the Study:

In this Project, the researchers’ objective is to give the reader a complete analysis of the case

Animal Welfare Board of India v. A. Nagaraja 2014 7 SCC 547.

Significance of the Study:

After reading this project work, the reader will get a complete analysis of the respective case.
So, this is the significance of this study.

Scope of the Study:

The scope of this study is limited only to the particular case.

Literature Review:

SC judgement: http://envlawportal.in/wp-content/uploads/2021/04/41513-Jallikattu.pdf

GRANTING ANIMALS RIGHTS UNDER THE CONSTITUTION: A MISPLACED

APPROACH? AN ANALYSIS IN LIGHT OF ANIMAL WELFARE BOARD OF
INDIA V. A NAGARAJA: This is a journal written by Jessamine Therese Mathew & Ira
Chadha-Sridhar and published by NUJS Law Review. The researcher has used this journal to
get a basic idea of the case and to identify the elements involved in this case. Apart from it,
the researcher has read some web articles and SC Judgement on this case to get a proper
understanding of the topic and used the data given in those to give a comprehensive
understanding to the reader.

Research Methodology:

In this project work, the researcher will adhere to the doctrinal type of research. The
researcher has used analytical, descriptive and explanatory approach to explain the study.

Page | 5
Mode of the Citation:

OSCOLA (Oxford Style of Citation), 4th edition.

Research Questions:

1. What is the case all about?

2. What is the impact of this case over all ?

Page | 6
 INTRODUCTION

India is a “nation with a wide range of customs and practises, the majority of which have a
direct impact on the environment. Customs are seen as important sources of law, albeit not all
customs are recognized by the law, and some may even be immoral. The government and
courts must take steps to eliminate such behaviors from society. This is one of the instances
when the government and the court have taken efforts to control and limit such behavior.
Certainly, one cannot take a blind step, fully ignoring the public’s emotional bonds, since this
might lead to social instability. The decision has proven to be a watershed moment in the
preservation of culture and animal welfare. The case involves a challenge to the Madras High
Court's decision recognizing the Tamil Nadu Regulation of Jallikattu Act (hereafter TNRJ
Act), as well as a challenge to the Bombay High Court's decision validating the 2011
notification adding bulls to the list of prohibited performing” animals.

On the 7th of May, 2014, “the Supreme Court of India issued a landmark verdict in the case
‘Animal Welfare Board of India vs. A. Nagaraja & Ors. (Civil Appeal No. 5387 of 2014) 1 in
the Supreme Court of India’ and related appeals and petitions. Bulls and bullocks were
prohibited from being used in exhibits such as Jallikattu, bullock cart racing, and so forth.
Bulls and other animals were exploited in physically and psychologically torturous ways for
human pleasure and delight during festivals in the states of Tamil Nadu and Maharashtra.

The Animal Welfare Board of India (AWBI) moved the matter to the Supreme Court, which
is contemplating an inside and out boycott of Jallikattu as a consequence of the cruelty to
animals and the danger to open security. Villagers throw themselves on top of the frightened
animals in an effort to agree with them and claim the” reward. 2 There were two sets of cases
in this case. One case challenges the Madras High Court's Division Bench Judgment
upholding the Tamil Nadu Registration of Jallikattu Act,3 as well as a few writ petitions
challenging the Ministry of Environment and Forests’ and other case challenges the

1
Animal Welfare Board of India v. A. Nagaraja & Ors., Civil Appeal No. 5387 of 2014.

2
Renuka Sara Abraham, “Case Comment on Animal Welfare Board of India v. A. Nagaraja & Ors. (The
Jallikattu Judgment)” (Academike 16 Nov 2015) https://www.lawctopus.com/academike/jallikattu-verdict-
supreme-court/ accessed 01 Apr 2022.
3
Tamil Nadu Regulation of Jallikattu Act 2009, 27

Page | 7
Bombay High Court’s Division Bench Judgment upholding the MoEF Notification. The
Supreme Court has outlawed hundreds of years ancient Jallikattu-bullfights and bullock-cart
racing activities amid celebrations in Tamil Nadu and adjacent states, citing the “untold
coldbloodedness” that the bovines are subjected to.

Overall, the bench led by Justice K.S. Radhakrishnan supported elevating animal rights to
“constitutional rights.” “It is natural for the Parliament to elevate animal privileges to
protected rights, as many other countries have done to guarantee their dignity and honor,” the
seat said. “All living species, including animals, have intrinsic dignity and a right to live
peacefully and to preserve their well-being,” the court said, ordering governments and the
AWBI to take efforts to avoid the imposition of undue pain or suffering on animals.

This “ruling not only outlawed the game, but also strengthened the rights guaranteed by
Sections 3 and 11 of the Prevention of Cruelty to Animals Act 4 (hereafter PCA Act) and
Articles 51A (g) and (h),5 as well as instructing the government to safeguard and protect
animal freedoms and follow the procedure outlined in Section 22 of the PCA Act. The TNRJ
Act was challenged under Article 32 of the constitution once it went into effect. The Supreme
Court upheld the judgement of the Bombay High Court, which validated the Ministry of
Environment and Forest notification of 2011 adding bulls in the list of animals forbidden
from becoming trained, and set aside the judgement of the Madras High Court, which
validated the Amended TNRJ Act, 2009 and kept the Act unconstitutional and in violation of
the PCA Act. In 2016, the issue was revisited for a” second time

4
Prevention of Cruelty to Animals Act 1960, § 3 & 11.
5
Constitution of India 1950, art. 51(A).

Page | 8
 BACKGROUND

During this era, the name Jallikattu was coined. The silver or gold coins affixed to the bulls’
horns were known as ‘Jalli’. In Jallikattu, wounds and even murders occur. In 2004, no less
than 5 people were found dead and a few hundred were injured in various places. Over the
previous two decades, two hundred people have died. The bull is not killed, unlike in Spanish
bullfighting. The bulls only lose a small percentage of the time. 6Each year, a few animal
advocates oppose this dangerous distraction, but these demonstrations have so far proved
ineffective.7 In India, the “Prevention of Cruelty to Animals Act, 1960” governs how brutally
torturing against animals must be avoided, and the Tamil Nadu government has passed the
Tamil Nadu Regulation of Jallikattu Act, 2009 on the grounds that Tamil Nadu had expressed
apprehension about the idea of banning the amusement, claiming that slants of local
sentiments would be harmed. The Supreme Court had earlier prohibited the practice in
January 2008, but four days later changed its decision, ruling that the sport might be
permitted provided certain standards were followed. On 2.3.1991, “the MoEF issued a notice
under Section 22 of the PCA Act8 prohibiting the preparation and display of bears, monkeys,
tigers, and dogs, which had been opposed by the Indian Circus Organization in the Delhi
High Court, but subsequently a corrigendum was issued, removing dogs from the
notification. The enforceability of the notice was challenged in N. R. Nair Others vs. Union
of India and Others,9 which sustained the notification, based on the ruling provided by the
Delhi High Court. A Committee was formed and, based on its recommendation, a warning
dated 14.10.1998 was issued restricting dogs from its domain.” Later, on 11.7.2011, the
MoEF issued a fresh notice specifically prohibiting the display or training of bulls as
performance animals.

6
T. Saravanan & A. Shrikumar, ‘Buzzing with bull talk’ (The Hindu 13 May 2016)
https://www.thehindu.com/features/metroplus/society/buzzing-with-bull-talk/article5553456.ece
accessed 02 Apr 2022.
7
PETA founder held in India over bullfight protest’ (Reuters 18 Jan 2008) accessed 02 Apr 2022
8
Prevention (n 4) § 22.
9
N. R. Nair Others v. Union of India and Others (2001) 6 SCC 84.

Page | 9
However, in January 2016, the Centre government issued a notice revoking the prohibition on
Jallikattu, which PETA and AWBI opposed. The supreme court issued the stay after
challenging the government's decision to issue such a notice and adding that “India cannot
import roman gladiator type sport.” Hundreds of people protested the ban on Jallikattu at
Marina Beach in Chennai on January 8, 2017, and the Governor of Tamil Nadu issued a new
ordinance as a 'State amendment' to the Central Act – Prevention of Cruelty to Animals Act
(1960) with the President's assent, exempting Jallikattu from the PCA Act 1960. The Tamil
Nadu Assembly enacted this ordinance as Amendment Bill 2017, making bull-taming
permissible once again. The Supreme Court referred all such applications to a Constitutional
Bench in February 2018 after PETA (People for the Ethical Treatment of Animals) and
AWBI (Animal Welfare Board of India) challenged the pronouncement.10

10
Haya Wakil, ‘Jallikattu: History, Court Rulings, and Controversy’ (Clear IAS 11 Feb 2017) <Jallikattu:
History,
Court Rulings, and Controversy - Clear IAS> accessed 02 Apr 2022

Page | 10
 FACTS & ISSUES

Facts: The 2006 and 2014 petitions were at first filed as a writ of Mandamus under Art 226
in Madras High Court, and in 2007, a division bench reversed the previous judgement,
against which several SLPs were filed in Supreme Court under Art 136[3], Art 133[4], Art
142[5], and Art 32[6], and the bench headed by Justice KS Radhakrishnan. In this case, the
petitioner obviously revealed the inherent cruelty to bulls during Jallikattu, which results in
widespread breaches of PCA Act sections 3, 11, and 22. The TNRJ Act of 2009 was also
challenged as being unconstitutional since it violated Article 254(1) of the constitution, which
exempted Jallikattu from the PCA Act.

The petitioners stated that the sport is not an inevitable activity that may justify the pain and
suffering given to animals. Meanwhile, the Ministry of Environment and Forests (MOEF)
issued a statement prohibiting the use of bulls as performance animals, reiterating the
AWBI’s legal position. Despite the respondents' emphasis on the event's ritualistic
significance, the Supreme Court issued a landmark decision on 7 May 2014, upholding the
validity of the aforementioned notification and the rights guaranteed to bulls under the PCA
Act, which prohibits traditional bull-taming sports and bullock-cart races (Rekla) held during
harvest celebrations in Tamil Nadu and Maharashtra. However, following a series of legal
battles between the state government and animal welfare organizations in the apex court in
2016-17, as well as a massive state-wide protest by Tamilians against the ban, the state
legislature, with the consent of the President, passed the State Amendment bill, which, for the
most part, protected Jallikattu from legal challenges.

The case has now been submitted for judicial review to a constitutional bench.

Issue: Whether the activities taking place in Tamil Nadu and Maharashtra violate Sections 3,
11(1)(a) & (m), 21, and 22 of the PCA Act, as well as Articles 51A(g) and (h) of the
Constitution and the notification on 11.7.2011.

Bench: Justice K.S. Radhakrishnan, Justice Pinaki Chandra Ghose.

Page | 11
 Petitioner & Respondent Arguments

Petitioner’s Argument:

a. Jallikattu bulls are exposed to significant pain and suffering as a result of being compelled
to compete in the race, which fundamentally breaches sections 3, 11(1)(a) & (m) and 22 of
the PCA Act, as well as Article 51A(g) and Article 21 of the Indian Constitution.

b. It is unreasonable to hold the event in the name of protecting traditional and cultural rights
as defined by Article 29(1) of the Constitution while causing agony on the animal.

c. According to a notice issued by the Ministry of Environment and Forests on 11.7.2011,

bulls used in Jallikattu, Bullock-cart races, and other similar events are properly excluded
from the categories of performing animals under Sections 21 and 22 of the PCA Act.

d. Because it breaches Article 254(1) of the Indian Constitution, the TNRJ Act, 2009 is
contrary to the spirit of the PCA Act, 1960.

e. According to AWBI statistics, 43 people died and over a thousand were injured throughout
the occurrence from 2008 to 2014, demonstrating a disdain for human life.

Respondent’s Argument:

a. The prohibition violates Article 29 of the Constitution, which provides a cultural minority
the freedom to preserve its particular culture.

b. If the sport is outlawed, farmers will be compelled to stop rearing the indigenous bull
breed.

c. The sport has been practiced in Tamil culture for thousand years and does not include any
cruelty or injury to the animals participating in the event.

d. The sport is a significant source of cash for the state, drawing a huge number of people
who are willing to pay to see it.

e. Such sports activities cannot be prohibited; instead, they must be governed by state
authorities in accordance with the terms of the TNRJ Act 2009.

f. Section 22 of the PCA Act would not apply because the activity does not include the selling
of tickets

Page | 12
 EVALUATION

International Perspective: Sadly, there is no international agreement in place to assure

animal care and protection. Even internationally renowned entities such as the United Nations
have protected solely human rights, ignoring the reality that many animals, especially
bovines, are also risking their lives to alleviate human misery and provide food for human
consumption. Though there has been a significant shift in International Environmental Law,
Animal Welfare Laws, and other areas from an anthropocentric to a more ecocentric
approach, the ethos in which the new legislations are interpreted should be consistent with the
principles of valuing pure animal welfare, whether for agricultural purposes, dairy
production, or any other reasonable purpose.

Certain “countries have acknowledged animal rights based on eco-centric ideas. For example,
the German Constitution guarantees animal protection through an amendment to Article 3 of
the German Animal Welfare Law in 2002,11 which provides far-reaching protections for
animals, including protections from animal fights and other activities that may cause pain,
suffering, or harm to the animals. Animal welfare law has also been adopted in countries such
as Switzerland, Austria, and Slovenia, in order to balance the basic rights of animal owners to
property with the animals' genuine interest in freedom from undue suffering, pain, harm, and
fear. The Animal Welfare Act of 2006 (United Kingdom) 12 also provides significant
protection to animals from pain and suffering.

Humans have obligations to their fellow species, according to the Austrian Federal Animal
Protection Act. The Norwegian Animal Welfare Act of 201013 declares that animals” have
inherent value, regardless of whether or not they are useful to humans. The Universal
Declaration of Animal Welfare (UDAW) includes India as a member state, with the goal of
gaining universal recognition for animal welfare ideals. It’s worth noting that the five
freedoms mentioned in the UDAW are identical to the PCA Act of 1960. 14 Likewise, the
World

11
Animal Welfare Law 2002, art. 3 (Ger)
12
Animal Welfare Act 2006 (UK).
13
Animal Welfare Act 2010 (Norway).
14
Universal Declaration on Animal Welfare’ (Wikipedia)
<https://en.wikipedia.org/wiki/
Universal_Declaration_on_Animal_Welfare#Overview_of_the_proposed_declaration accessed 03 Apr 2022.

Page | 13
Health Organization for Animal Health (OIE) is recognized as the international reference
organization for animal welfare, stating that an animal is in good health, comfort, well-
nourished, safe, capable of expressing innate behavior.

Legal & Constitutional Aspect:

• The PCA Act’s section 315 imposes a compulsory obligation on the person in charge of
animals to adopt all reasonable efforts to safeguard the animal’s well-being. By forcefully
dragging bulls into the tiny enclosure and then into the arena to be overwhelmed by the Bull
tamers, no twist of the imagination can be stated to be for the animal's well-being but for the
delight and entertainment of human people. Second, section 3 is a preventative measure that
grants the organizers just responsibilities and obligations rather than rights. It makes the
person in charge of animals responsible for preventing needless pain and suffering. The
organizers of the Jallikattu and Bullock-cart races are not avoiding undue pain or suffering,
rather they are inflicting pain and suffering on the bulls, something they are legally prohibited
from doing. As a result, the organizers of Jallikattu are robbing the bulls of their rights under
Section 3 of the PCA Act.

• Section 11(1)(a) is a good provision that is criminal in character and is legislated for the
well-being, care, and protection of animals. It stipulates that if an animal is beaten, kicked,
over-ridden, tortured, or otherwise handled in such a way that it suffers undue pain or
suffering, the owner is judged to have committed an infraction if he fails to exercise
reasonable care and supervision. Also, Section 11(1)(m) states that anybody who incites any
animal to fight only for the purpose of giving entertainment is subject to the proviso to
Section 11(1)(m) (1). In light of the petitioner's claims, the event of Jallikattu shamelessly
flouts these regulations.16

• It is also evaluated if exercises like Jallikattu are required under Section 11(3) of the PCA
Act, as was previously decided in Bhuri Nath and Others v. The State of Jammu and Kashmir
& Others (1997).17 The court decided that excitement, presentation, and

15
Prevention (n 4)
16
Jessamine Therese Mathew & Ira Chadha-Sridhar, ‘GRANTING ANIMALS RIGHTS UNDER THE
CONSTITUTION: A MISPLACED APPROACH? AN ANALYSIS IN LIGHT OF ANIMAL WELFARE
BOARD OF INDIA V. A NAGARAJA’ (2014) 7 NUJS L.REV. 349, 364.
17
Bhuri Nath and Others v. The State of Jammu and Kashmir & Others, (1997) 2 SCC 745.

Page | 14
entertainment do not fit within Section 11(3)’s exempted classes, and hence there was no
necessity.

• The PCA Act prohibits the display and training of performing animals under Section 22. On
11.7.2011, the MoEF, in exercising the authorities given by this section, issued a notice
prohibiting the display or training of any animal as a performance animal, including Bull.
Furthermore, by incorporating Article 51A(g) and Article 21 of the Constitution 18into the
provisions of the PCA Act, the government has reaffirmed and emphasized human beings’
fundamental responsibilities to all living creatures, as well as the dignity of animals’ right to
life and liberty, which clearly includes bulls.

• Another “point to consider is the repugnancy of the two provisions involved. This Court
held in ‘Jaya Gokul Educational Trust v. Commissioner & Secretary to Government Higher
Education Department, Thiruvananthapuram, Kerala State and Others’ 19
that repugnancy
may arise among two laws enacted, even if obedience to each of them is possible without
disobeying the other, if a competent legislature of superior efficacy, expressly or implicitly,
evinces by the State legislation a clear intention to cover the entire field, then the” enactment
would be void. The TNRJ Act of 2009 is anthropocentric, yet it mentions old culture and
custom, as well as the safety of animals, participants, and spectators. The PCA Act of 1960,
on the other hand, was designed to avoid the inflicting of undue pain or suffering on animals,
as well as to protect the animals' inherent instincts. As a result, this Act imposes not only
obligations on humans, but also rights on animals, which are revoked by the TNRJ Act,
which grants rights to organizers and bull tamers to practice Jallikattu. As a result, the TNRJ
Act is incompatible with the PCA Act, which is a welfare law, and has been ruled illegal and
invalid for violating Article 254(1) of the Indian Constitution.

18
Constitution of India 1950, art. 51(A)(g) & 21
19
Jaya Gokul Educational Trust v. Commissioner & Secretary to Government Higher Education Department,
Thiruvananthapuram, Kerala State and Another (2000), 5 SCC 231.

Page | 15
 JUDGEMENT

1. Except “under Sections 11(3) and 28 of the PCA Act, the court determined that the rights
provided to the Bulls by Sections 3 and 11 of the PCA Act, along with Articles 51A(g) and
(h), cannot be taken away or” reduced.

2. The five freedoms mentioned previously under Sections 3 and 11 of the PCA Act will be
maintained and secured by the States, Central Government, Union Territories, MoEF, and
AWBI.

3. The AWBI and governments were ordered to take adequate efforts to guarantee that those
in charge of animal care take reasonable steps to safeguard the animals' well-being.

4. Since their rights are statutorily protected by Sections 3 and 11 of the PCA Act, the AWBI
and governments have been required to take action to avoid the imposition of undue pain or
suffering on animals.

5. The AWBI is also tasked with ensuring that the terms of Section 11(1)(m)(ii) are strictly
adhered to, which means that the person in charge of the animal's care must not provoke any
animal to attack a human or another animal.

6. Even in circumstances where Section 11(3) was implicated, AWBI and the governments
were to ensure that the animals were not subjected to undue pain and suffering, and that
appropriate and scientific procedures were used to accomplish this.

7. In line with Section 9(k), the AWBI and the governments shall take initiatives to provide
education on the humane treatment of animals, instilling the spirit of Articles 51A(g) and (h)
of the Constitution.

8. Parliament was required to adopt appropriate amendments to the PCA Act to establish an
effective deterrence in order to fulfil the Act's goal and purpose, and appropriate fines and
punishments should be applied for violations of Section 11.

9. It was thought that Parliament will raise animal rights to constitutional rights, as many
other nations have done, in order to defend their dignity and honour.

Page | 16
10. If the “requirements of the PCA Act, as well as the declarations and directives issued by
this Court, are not properly and effectively followed, the governments will take disciplinary
action against the violating officials, ensuring that the PCA Act's purpose and aim are met

11. TNRJ Act was deemed to be incompatible with the PCA Act, which is a welfare law, and
so declared legally unconstitutional for violating Article” 254(1) of the Indian Constitution.20

12. AWBI was required to take effective and timely actions to execute the requirements of
the PCA Act, and to provide monthly reports to the governments, with the governments
taking necessary follow-up action if any violations are discovered. As a result, the Madras
High Court’s decision was overturned. The Bombay High Court’s decision and Central
Government’s notice dated 11.7.2011 was upheld.

20
Constitution of India 1950, art 254(1).

Page | 17
 CONCLUSION

Jallikattu has been termed intrinsically aggressive and harmful to animals by India's Animal
Welfare Board. PETA and other animal rights organizations have also spoken out against the
Jallikattu habit. It remains to be seen if Jallikattu will continue to be performed in Tamil
Nadu, since the topic of whether it should be conducted as a cultural right despite its flaws
has been referred to a special Constitutional Bench. The outcome of the case will determine
the destiny of the usual practise. The court will also examine whether a state assembly may
repeal a central statute while still claiming protection under constitutional provisions defining
the separation of powers between the federal government and the states.

However, we must accept that, regardless of whether culture or religion has sanctioned
animal cruelty, we cannot allow it to continue. Furthermore, with such a dense people and a
lack of security mechanisms, events like Jallikattu may be very hazardous and lethal. Our
feeling of social welfare, humanitarianism, and eco-sensitivity will help us to break free from
repressive conventional structures as time and consciousness pass. We may be more in touch
with the larger good of the universe if we are willing to alter and reconsider our traditions.

Page | 18
 BIBLIOGRAPHY

Case Judgement:

• http://envlawportal.in/wp-content/uploads/2021/04/41513-Jallikattu.pdf

Journal:

• GRANTING ANIMALS RIGHTS UNDER THE CONSTITUTION: A MISPLACED

APPROACH? AN ANALYSIS IN LIGHT OF ANIMAL WELFARE BOARD OF INDIA V.
A NAGARAJA written by Jessamine Therese Mathew & Ira Chadha-Sridhar.

Web Articles:

• https://lawtimesjournal.in/animal-welfare-board-of-india-vs-a-nagaraja/

• https://www.lawctopus.com/academike/jallikattu-verdict-supreme-court/

Page | 19