1

BEFORE THE HON’BLE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION

PUBLIC INTEREST LITIGATION

WRIT PETITION (CIVIL) NO. 9819 OF 2024

IN THE MATTER OF:

CENTRE FOR ALL

ANIMALS, INDIA ……PETITIONER
Versus

UNION OF INDIA & ORS. ……RESPONDENTS

PAPER BOOK

(FOR INDEX KINDLY SEE INSIDE)

ADVOCATE FOR THE PETITIONER:

Ms. Ishika Hinduja

 2

RECORD OF PROCEEDINGS

S. DATE OF RECORD OF PROCEEDINGS PAGES

NO
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
 3

INDEX

S.N PARTICULARS PAGE

O NO
1. COURT FEE 4
2. SYNOPSIS 6
3. LIST OF DATES 8
4. WRIT PETITION ALONG WITH 10
SUPPORTING AFFIDAVIT
5. ANNEXURE P-1: True copies of the Adhaar 24
Card and the PAN Card of Mr. Sunil Hinduja,
the Director of the Petitioner.
6. ANNEXURE P-2: A CITIZENS’ REPORT 25
DEMANDING RIGHTS FOR ANIMALS IN
INDIA by Federation of Indian Animal
Protection Organization.
7. ANNEXURE P-3: True copies of compiled 27
newspaper reports of the narrated incidents of
Animal Cruelty.
8. VAKALATNAMA 29
 4

BEFORE THE HON’BLE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION

PUBLIC INTEREST LITIGATION

WRIT PETITION (CIVIL) NO. 9819 OF 2024

IN THE MATTER OF:

CENTRE FOR ALL

ANIMALS, INDIA ……PETITIONER
Versus

UNION OF INDIA & ORS. ……RESPONDENTS

COURT FEE

1. Public Interest Litigation under Article 32 of the Constitution of

India Rs. 500

Total Rs. 500

Centre for All Animals, India

Though its Director

Mr. Sunil Hinduja

PETITIONER

THROUGH

Ms. Ishika Hinduja

Advocate

235, New Lawyers Chambers,

Supreme Court of India.

 5

NEW DELHI

DATE: 18/10/24
 6

SYNOPSIS AND LIST OF DATES

The present writ petition is being filed in public interest under

Article 32 of the Constitution of India, read with Article 21 read
with Article 51A(g). The petitioner is seeking, inter alia, the
immediate intervention of this Hon’ble Court to address the rising
instances of barbaric animal cruelty. The facts that lead to the cause
of action for the present Petition is the polarity between the
alarming number of instances of animal cruelty within India in
comparison to the number of people convicted and fined for
offences under the Prevention of Cruelty Against Animals Act,
1960. This is indication of poor implementation of the legislation,
thereby requiring more holistic updated provision to tackle this issue
in 2024 as well higher penalties and bail sums, that act as a deterrent
against such crimes in India.

Recent cases of animal cruelty in India being barbaric and gruesome

in nature have brought to light the insufficiency of enforcement of
the existing legal provisions in protecting animals from abuse and
the requirement for stringent and effective laws. A few recent
incidents of animal cuelty include a man from Vile Parle, Mumbai
brutally trashing a street dog with an iron rod causing the dog to die
on the spot, two teenage boys cruelly tying and mercilessly
drowning a dog for fun in Ujjain, Madhya Pradesh, a pet cat found
unconscious, poisoned and dismembered by her owner in Mumbai,
and a leopard was captured and brutally beaten to death by villagers
in Fatasil Reserve Forest in Guwahati, Assam after which they
chopped off its body parts for their satisfaction. According to the
divisional forest officer, the residents had claimed that the leopard
was killing goats and poultry and was also attacking village dogs.

The provisions under the Prevention of Cruelty to Animals Act,

1960 have not been revised in 60 years to keep up with the times
and even today the only punishment for such dastardly acts is an
outdated amount of merely 200 Rupees fine with no imprisonment
and has proven to be ineffective in deterring animal cruelty.

Section 11 of Prevention of Cruelty to Animals Act, 1960, beating,

kicking, overriding, overloading, overdriving, torturing or otherwise
 7

treating any animals so as to subject it to unnecessary pain amounts

to cruelty on animals. However, the section fails to provide different
grades of offences and treats all kinds of crimes against animals
equally, forcing all crimes to be remain bailable and non-cognisable.
This paradigm which fails to treat kicking a dog differently than
stoning a dog to death is an inherent flaw within the statutory
provisions.

Most cases of cruelty go unreported among law enforcement

authorities due to the lack of awareness, education and accessibility
of the Prevention of Cruelty to Animals Act and the police never
convert complaints under PCA Act 1960 into FIRs (First
Information Report) and in cases where the complaints are
entertained by Police, they are merely recorded as NCRs – non-
cognisable reports, as not all acts of cruelty under section 11 of the
Prevention of Cruelty Act are cognizable.

Article 21 of the Indian Constitution was expanded to include within

its scope application to all forms of life, including animals life, in
the case of Animal Welfare Board of India Vs. A. Nagaraja and
Others.

Article 51A(h) and Article 51A (G) imposes a duty of care on

citizens to develop the scientific temper, humanism and the spirit of
inquiry and reform and protect and improve the natural environment
and have compassion for all living creatures.

Since the PCA Act, 1960 has not been able to effectively provide
protection to animals, animal rights seek this Hon’ble Court’s
intervention in putting an end to this tyranny against the voiceless
animals that require for their rights to be fought for.
 8

LIST OF DATES AND EVENTS

1860 The Indian Penal Code, 1860 is enacted to cover

all substantive aspects of criminal law including
Section 428 for criminalising and punishing
mischief against animals.

26.12.1960 The Prevention of Cruelty to Animals Act, 1960

was enacted to prevent the infliction of
unnecessary pain or suffering on animals.

26.02.2008 The Supreme Court passes its judgement in State

of Gujarat v. Mirzapur Moti Kureshi Kassa Jamat,
with regard to the duty of citizens to show
compassion for living creatures, "humanism"
under Article 51A (h).

2011 A draft bill titled the Animal Welfare Act 2011

(‘Draft Act, 2011’) was introduced by the AWBI
in the Parliament to replace the present Act of
1960. The Draft Act sought to bring a shift from a
defensive position to a positive, welfare-driven
and well-being-oriented approach, by
strengthening animal welfare organisations.

07.05.2014 The Supreme Court of India passes a milestone

judgment Animal Welfare Board of India vs. A.
Nagaraja & Ors. banning the bulls and bullocks in
exhibitions, for example, Jallikattu, bullock cart
racing, and emphasized the need to urgently
 9

amend the PCA Act and expanding the scope of

Article 21 to include animals as well.

31.05.2019 Legal Status bestowed upon the animals in the

judgment, Karnail Singh and Others v. State of
Haryana by the Hon’ble Punjab and Haryana High
while also recognizing the application of the
doctrine of loco parentis on animals.

2020 Rise in the number of cases of Animal cruelty in

India.

2020 Release of Crimes against Animals Report by

Federation of Indian Animal Protection
Organisations

18.10.2024 Filing of the present petition before the Hon’ble

Supreme Court.
 10

BEFORE THE HON’BLE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION

PUBLIC INTEREST LITIGATION

WRIT PETITION (CIVIL) NO. 9819 OF 2024

IN THE MATTER OF:

1. CENTRE FOR ALL

ANIMALS, INDIA
Through its Director,
Mr. Sunil Hinduja,
122, Bandra (West),
Mumbai 400052. ……PETITIONER

Versus

1. UNION OF INDIA
through Chief Secretary,
Ministry of Home Affairs,
North Block,
Central Secretariat,
New Delhi– 110001.

2. MINISTRY OF LAW
AND JUSTICE,
through its Secretary,
Shashtri Bhawan,
New Delhi- 110001.

3. MINISTRY OF
ANIMAL
HUSBANDRY,
FISHERIES AND
DAIRYING,
 11

through its Secretary,

Krishi Bhawan,
New Delhi- 110001.

4. ANIMAL WELFARE
BOARD OF INDIA
(AWBI),
through its Secretary,
National Institute of
Animal Welfare Campus,
Faridabad, Haryana-
121004.
……RESPONDENTS

WRIT PETITION UNDER ARTICLE 32 OF THE

CONSTITUTION OF INDIA

To,

The Hon'ble ChiefJustice of India

And his companion Justices of the Hon'ble Supreme Court of India

This humble Petition of

the Petitioner herein

MOST RESPECTFULLY SHOWETH:

1. That the present petition has been filed by the petitioners in

public interest, under Article 32 of the Constitution of India,
inter alia, seeking the issuance of a writ/ order/ direction, in
the nature of mandamus, to the Respondents, directing them
to take appropriate measures/steps to review the legal
framework of ‘Prevention of Cruelty against Animals Act,
1960’, identify pitfalls and lacunae within the statutory
provision and implement a purposeful legal framework for
better protection and welfare of Animals in India, and
issuance of a writ/order/direction for the increment of
 12

penalties of any offence under the Prevention of Cruelty

against Animals Act, 1960 from a maximum of Rs. 200 to a
maximum of Rs. 50,000 under Section 20 of the Act and
issuance of a writ/ order/ direction to the Respondents,
directing them to implement a national level programme for
education on animal cruelty and its criminal nature,
specifically via educational institutions, village panchayats
and media outlets.

THE PARTIES

2. That the Petitioner, Centre for all Animals India, is an

unregistered Non-governmental organisation, having its office
at 122, Bandra (West), Mumbai 400-052, engaged in working
for the legal enforcement of animal rights, along with daily
activities of feeding nearly 150 dogs, cats and cows in the
locality, providing emergency medical assistance to injured
animals, conducting neutering drives, conducting donation
drives and arranging for the foster and adoption homes for
rescue animals. For achieving such goals, the petitioner works
in close consonance with larger NGO’s in Mumbai such as
Animal Awareness, Bombay Animal Rights (BAR) and
Mumbai- SPCA (Society for Prevention of Cruelty to
Animals). That the instant petition being a Public Interest
Litigation, the true copies of the Adhaar Card and the PAN
Card of the Director of the Petitioner is being annexed
herewith and marked as ANNEXURE P1 (at Page 23).

3. That the present petition has been filed pro bono publico for
the protection and welfare of animals and the petitioners have
no personal interest, or private/oblique motive in filling the
instant petition. There is no civil, criminal, revenue or any
litigation involving the petitioner which has or could have a
legal nexus with the issues involved in the PIL.

4. That the instant petition is based upon the

information/documents which are well within the public
domain and it is in the pleasure of this Hon’ble Court to take
a judicial notice thereof.
 13

5. That the Respondent No. 1 is the Union of India, through the

office of Chief Secretary, Ministry of Home Affairs, being the
concerned authority responsible for domestic policy in India.

6. That the Respondent No. 1 is the Union of India, through the

office of Chief Secretary, Ministry of Home Affairs, being the
concerned authority responsible for domestic policy in India.

7. That the Respondent No. 2 is the Ministry of Law and Justice,

through its Secretary, being the concerned authority dealing
with the management of the legal affairs, legislative activities
and administration of justice in India.

8. That the Respondent No. 3 is the Ministry of Fisheries,

Animal Husbandry and Dairying, through its Secretary, being
the concerned authority responsible for issues related to
livestock production, preservation, protection from disease
and improvement of stocks and dairy development.

9. That the Respondent No. 4 is the Animal Welfare Board of

India (AWBI) through its Secretary, is a statutory advisory
body established under Section 4 of the Prevention of Cruelty
to Animals Act, 1960 and is responsible for promoting animal
welfare in the country and for ensuring that animal welfare
laws in the country are diligently followed.

CAUSE OF ACTION

10.The facts that lead to the cause of action for the present
Petition is the polarity between the alarming number of
instances of animal cruelty within India in comparison to the
number of people convicted and fined for offences under the
Prevention of Cruelty Against Animals Act, 1960. This is
indication of poor implementation of the legislation, thereby
requiring more holistic updated provision to tackle this issue
in 2024 as well higher penalties and bail sums, that act as a
deterrent against such crimes in India.

Shortcomings of the Act

 14

11. That recent cases of animal cruelty in India being barbaric

and gruesome in nature have brought to light the insufficiency
of enforcement of the existing legal provisions in protecting
animals from abuse and the requirement for stringent and
effective laws.

12. That the provisions under the Prevention of Cruelty to

Animals Act, 1960 have not been revised in 60 years to keep
up with the times and even today the only punishment for
such dastardly acts is an outdated amount of merely 200
Rupees fine with no imprisonment and has proven to be
ineffective in deterring animal cruelty.

13.That as per Section 11 of Prevention of Cruelty to Animals

Act, 1960, beating, kicking, overriding, overloading,
overdriving, torturing or otherwise treating any animals so as
to subject it to unnecessary pain amounts to cruelty on
animals. However, the section fails to provide different grades
of offences and treats all kinds of crimes against animals
equally, forcing all crimes to be remain bailable and non-
cognisable. This paradigm which fails to treat kicking a dog
differently than stoning a dog to death is an inherent flaw
within the statutory provisions.

14.That in an interview with Deendayal from Animal Aid,

Udaipur, he recollects:

“Three months ago, a dead dog was being dragged by a car.

The video went viral. We were contacted by people across the
country and by PETA as well. We filed an FIR. But the
accused was released after paying a fine of 10,000 rupees. A
lot of times the person accused admits that they have killed
the animal and the court lets them go for a fine of 50-100
rupees. Recently around Holi, a guard beat a puppy and
grabbed it by its legs and threw it in a manner that the leg of
the puppy broke. We filed an FIR. He was fined around 1,500
rupees by the court and they let him go. He was fined because
we put in IPC 429, otherwise nothing would have happened.”
 15

15.That the duty cast by the PCA Act under section 3 upon every
person to take reasonable measures for the wellbeing of
animals is mandatory and hence confers corresponding rights
on animals. However, these rights if violated are liable for
enforcement with legal sanction. These rights guaranteed to
the animals under the PCA Act are statutory and have to
elevated to the status of fundamental rights, as similarly done
in international jurisprudence upon application of the
"Species Best Interest".

16.That few recent incidents of animal cuelty include a man from

Vile Parle, Mumbai brutally trashing a street dog with an iron
rod causing the dog to die on the spot, two teenage boys
cruelly tying and mercilessly drowning a dog for fun in
Ujjain, Madhya Pradesh, a pet cat found unconscious,
poisoned and dismembered by her owner in Mumbai, and a
leopard was captured and brutally beaten to death by villagers
in Fatasil Reserve Forest in Guwahati, Assam after which
they chopped off its body parts for their satisfaction.
According to the divisional forest officer, the residents had
claimed that the leopard was killing goats and poultry and
was also attacking village dogs.

17.That as per ‘A CITIZENS’ REPORT DEMANDING

RIGHTS FOR ANIMALS IN INDIA’ annexed herewith and
marked as ANNEXURE P2 (at Page 24), of the 1,000 assault
cases documented from over 300 news reports and 700 social
media posts and internal records of animal activists and
organisations, 82 are sexual abuse, 266 cases of coldblooded
murder and over 400 cases of violent attacks of beating,
kicking, torturing, throwing acid or boiling water, maiming a
part of the body, attacking with a knife or a blunt object and
almost 20 of these documented cases represent assault by
children on animals such as dogs, donkeys and monkeys and
that almost 4,230 dogs have been killed by mass culling
drives across the country in the between 2015 and 2020 and
that almost 70 per cent of the documented cases of crimes
against animals did not even make it to the news media cycle.
 16

18.That most cases of cruelty go unreported among law

enforcement authorities who are unaware about the existence
of the Act due to the lack of education and accessibility of the
Prevention of Cruelty to Animals Act.

19.That the police almost never convert complaints under PCA

Act 1960 into FIRs (First Information Report) and in cases
where the complaints are entertained by Police, they are
merely recorded as NCRs – non-cognisable reports, as not all
acts of cruelty under section 11 of the Prevention of Cruelty
Act are cognizable. Therefore, activists, who file complaints
against perpetrators of animal cruelty, are often compelled to
add provisions under the Indian Penal Code (Sections 428 and
429) and now the Bharatiya Nyaya Sanhita to overcome the
ineffectiveness of the PCA 1960 and ensure registration of an
FIR.

20.That the present Petition is based on authentic information

and public documents sourced from authentic news reports,
opinions and writings of eminent experts and scholars on
criminology and other publicly available information and that
the true copies of compiled newspaper reports of the aforesaid
narrated incidents are annexed herewith and marked as
ANNEXURE P3 (at Page 26).

21.That the Petitioner has not filed any similar petition before
any court of law seeking the reliefs sought in the present
Petition.

GROUNDS

Extension of Article 21 to Animals

A. Because Article 21 of the Constitution of India protects

one’s right to life and personal liberty and was understood
to be of widest amplitude in the landmark judgement of
Maneka Ghandhi v. Union of India.

B. Because right to life provided for under Article 21 of the

Indian Constitution was expanded to include within its
scope application to all forms of life, including animals
 17

life, in the case of Animal Welfare Board of India Vs. A.

Nagaraja and Others, popularly known as the ‘Jallikattu’
case. The judgement depicted the court’s compassionate
approach towards animals, banning the usage of bulls in
bullock cart races and Jalikattu, which were prevalent in
the states of Tamil Nadu and Maharashtra and subjected
the bulls to torture for human pleasure and enjoyment.

C. Because the above cited case, found the Tamil Nadu

Regulation of Jallikattu Act, 2009 which permitted such
practices as culture and tradition within the state of Tamil
Nadu, to be an anthropocentric legislation, repugnant to
the Prevention of Cruelty against Animals Act which is an
ecocentric legislation.

D. Because the Hon’ble court held,

“Article 21 of the Constitution, while safeguarding the

rights of humans, protects life and the word “life” has
been given an expanded definition and any disturbance
from the basic environment which includes all forms of
life, including animal life, which are necessary for human
life, fall within the meaning of Article 21 of the
Constitution... Right to dignity and fair treatment is,
therefore, not confined to human beings alone, but to
animals as well.”

E. Because, the court also held Article 21, when expanded to

different forms of life awards a larger right than mere
survival and existence for human needs but rather the right
to lead a life with intrinsic value, honor, and dignity.

F. Because The Hon’ble Madras High court in its judgment

of S. Kannan v. The Commissioner of Police (2014 5 MLJ
440) upheld the rights of animal and also held that animals
have the same right to life as that of humans. The Hon’ble
Court also opined as follows,

“Every species has a right to life and security, subject to

the law of the land, which includes depriving its life, out of
 18

human necessity. Article 21 of the Constitution, while

safeguarding the rights of humans, protects life and the
word "life" has been given an expanded definition and any
disturbance from the basic environment which includes all
forms of life, including animal life, which are necessary
for human life, fall within the meaning of Article 21 of the
Constitution.”

Fundamental duties towards Animals under Article

51A (h) & Article 51A (g)

G. Because Article 51A(h) states that it shall be the duty of

every citizen to develop the scientific temper, humanism
and the spirit of inquiry and reform.

H. Because Article 51A (g) places a duty on the citizens of

India to protect and improve the natural environment and
have compassion for all living creatures.

I. Because in the case of State of Gujarat v. Mirzapur Moti

Kureshi Kassa Jamat, (2005) 8 SCC 534, with regard to
the duty of citizens to show compassion for living
creatures, "humanism" under Article 51A (h) was
explained in the following terms:

“Article 51A(h) says that it shall be the duty of every

citizen to develop the scientific temper, humanism and the
spirit of inquiry and reform. Particular emphasis has been
made to the expression "humanism" which has a number
of meanings, but increasingly designates as an inclusive
sensibility for our species. Humanism also means,
understand benevolence, compassion, mercy etc. Citizens
should, therefore, develop a spirit of compassion and
humanism which is reflected in the Preamble of PCA Act
as well as in Sections 3 and 11 of the Act. To look after the
welfare and well- being of the animals and the duty to
prevent the infliction of pain or suffering on animals
highlights the principles of humanism in Article 51A(h).
Both Articles 51A(g) and (h) have to be read into the PCA
 19

Act, especially into Section 3 and Section 11 of the PCA

Act and be applied and enforced."

J. Because in the case of Court On Its Own Motion vs The

Deputy Commissioner (2018) the court understood the
duty of humans towards animals and held that while all
animals have a fundamental right, it is our duty to take
care of them and reduce their suffering. While assessing
whether cruelty has been committed against domesticated
horses by leaving them out in the rain, the court held:

“Such an act is against public morale and order. Animals

do have emotion, though they may not have the language
of humans, but animal-lovers do understand their such
emotions, expressed in various forms, including sound,
body language and behaviour. In our considered view,
animals do have a fundamental right under the Indian
Constitution. In the instant case, there is no conflict of
interest between animals and humans. On the contrary,
man needs to attend to the animals. Their sufferings need
to be lessened and life ameliorated.”

K. Because the doctrine of loco parentis has been applied to

animals in India jurisprudence through the case of Karnail
Singh & Ors. v. State of Haryana (2019) wherein while
recognizing all animals as legal entities, it also recognized
all citizens of the state of Haryana as declared persons in
loco parentis (in place of a parent), which will enable them
to act as guardians for all non-human animals within the
state of Haryana. That it was further observed in the
aforesaid judgment that,

“All the animals have honour and dignity. Every specie[s]

has an inherent right to live and is required to be
protected by law. The rights and privacy of animals are to
be respected and protected from unlawful attacks. The
Corporations, Hindu idols, holy scriptures, rivers have
been declared legal entities, and thus, in order to protect
and promote greater welfare of animals including avian
 20

and aquatic, animals are required to be conferred with the

status of legal entity/legal person. The animals should be
healthy, comfortable, well nourished, safe, able to express
innate behaviour without pain, fear and distress. They are
entitled to justice. The animals cannot be treated as
objects or property.”

Directive to states under Article 48A

L. Because the Directive Principle of State Policy under

Article 48A enjoins the State to take steps to protect the
wildlife of the country and this is not limited to wildlife
animals but all animals and requires the state to protect
animals from instances of cruelty.

International Standards

M. Because the World Health Organization of Animal Health,

of which India is a member, states that an animal is in a
good state of welfare if it is healthy, comfortable, well-
nourished, safe, able to express innate behavior, and if it is
not suffering from unpleasant states such as pain, fear, and
distress.

N. That it has been determined in a plethora of scientific

studies that animals are emotional beings and experience
pain, emotional and physical and that there exists a link
between animal abuse and psychological issues, with
instances of animal abuse being a precursor to criminal
violence.

PRAYER

In light of the facts and circumstances detailed in the present writ

petition, as well as the legal grounds relied upon therein, it is most
humbly prayed thatthis Hon'bleCourt may be pleased to:

A. Issue an appropriate writ, order or direction, in the nature

of mandamus, directing the Central Government to
formulate a committee of legal experts, animal activists
 21

and members of the relevant ministries to review the legal

framework of the Prevention of Cruelty against Animals,
1960 and identify any lacunae within the provisions and
recommend requisite amendments to the Act.

B. Issue an appropriate writ, order or direction, in the nature

of mandamus, directing the Central Government to a
national programme for the education and awareness of
the criminalization of different modes of animal cruelty.

C. Issue any such other and further order(s) in addition to or

in substitution for the above prayer(s), as this Hon’ble
Court may deem fit and proper in the facts and
circumstances of the case.

FOR WHICH ACT OF KINDNESS, THE PETITIONERS

SHALL AS INDUTY BOUND, EVER PRAY.

DRAWN BY:

Soumit Banerjee

Advocate

FILED BY:

Ms. Ishika Hinduja

Advocate

235, New Lawyers Chambers,

Supreme Court of India

NEW DELHI

DATE: 18/10/24
 22

BEFORE THE HON’BLE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION

PUBLIC INTEREST LITIGATION

WRIT PETITION (CIVIL) NO. 9819 OF 2024

IN THE MATTER OF:

CENTRE FOR ALL

ANIMALS, INDIA ……PETITIONER
Versus

UNION OF INDIA & ORS. ……RESPONDENTS

AFFIDAVIT

I, Mr. Sunil Hinduja, S/o Mr. Dhanraj Hinduja, presently working as

the director of Centre for All Animals India, having its office at 122,
Bandra (West), Mumbai 400052, do hereby solemnly affirm and
declare as under:

1. That I am the Authorized Signatory of the Petitioner

Organization, Centre for All Animals India.
2. That the petitioner organization, Centre for All Animals India
is a non-profit and non-political organisation. The petitioner
organisation or its members do not have any political
affiliation.
3. That I am the representative of the Petitioner and in the above
Petition and being conversant with the facts of the case, am
competent to swear this affidavit. That I have reading the
accompanying writ petition and I state that the facts contained
in paragraphs 1-21 of the Petition and the miscellaneous
applications filed therein are true and correct to the best of my
knowledge and belief.
4. That the Annexures annexed at P-1 to P-3 filed along with
the Petition are true copies of their respective originals.
 23

DEPONENT

VERIFICATION:

Verified at New Delhi on this 18th day of October, 2024, that the
facts stated in the above affidavit are true and correct to my
knowledge and belief. No part of it is false and nothing material has
been concealed therefrom.

DEPONENT
 24

ANNEXURE P-1
 25

ANNEXURE P-2
26
 27

ANNEXURE P-3
 28

BEFORE THE HON’BLE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION

PUBLIC INTEREST LITIGATION

WRIT PETITION (CIVIL) NO. 9819 OF 2024

IN THE MATTER OF:

CENTRE FOR ALL

ANIMALS, INDIA ……PETITIONER
 29

Versus

UNION OF INDIA & ORS. ……RESPONDENTS

VAKALATNAMA

KNOW ALL to whom those present shall come that I, Mr. Sunil
Hinduja, S/o Mr. Dhanraj Hinduja, presently working as the director
of the Petitioner Organisation, Centre for All Animals India, having
its office at 122, Bandra (West), Mumbai 400052, do hereby
appoint: Ms. Ishika Hinduja (herein after called the Advocate) to be
my Advocate in the above noted case and authorise her: -

1. To act, appear and plead in the above-noted case in this Court

or in any other Court in which the same may be tried or heard
and also in the appellate Court subject to payment of fees
separately for each Court by me.
2. To sign, file, verify and present pleadings, appeals, cross-
objections or petitions for executions, review, revision,
withdrawal, compromise or other petitions or affidavits or
other documents as may be deemed necessary or proper for
the prosecution of the said case in all its stages subject to
payment of fees for each stage.
3. To file and take back documents, to admit and/or deny the
documents of the opposite party.
4. To withdraw or compromise the said case or submit to
arbitration any differences or disputes that may arise touching
or in any manner relating to the said case.

5. To deposit, draw and receive monthly cheques, cash and grant

receipts thereof and to do all other acts and things which may
be necessary to be done for the progress and in the course of
the prosecution of the said case.

Centre for All Animals, India

Though its Director

 30

Mr. Sunil Hinduja

PETITIONER

THROUGH

Ms. Ishika Hinduja

Advocate

235, New Lawyers Chambers,

Supreme Court of India.

NEW DELHI

DATE: 18/10/24