Animal welfare law prevails over Jallikattu regulation, with cruelty-based restrictions on bulls upheld and state law invalidated.

The Prevention of Cruelty to Animals Act, 1960 was treated as welfare legislation requiring a liberal construction to prevent unnecessary pain and suffering. Jallikattu and bullock-cart races, as conducted, were found to subject bulls to fear, distress, exhaustion and injury, thereby violating Sections 3 and 11(1)(a) and the corresponding constitutional duties of compassion. Bulls were held not to be suitable performing animals for these events, and the Central Government notification prohibiting their exhibition or training was upheld as a valid exercise of statutory power. The Tamil Nadu Regulation of Jallikattu Act, 2009 was found repugnant to the Central Act and void under Article 254(1).

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Issues: (i) Whether Jallikattu and bullock-cart races, as conducted, violated the duties and prohibitions under the Prevention of Cruelty to Animals Act, 1960 and the constitutional duty to protect animals from unnecessary pain and suffering; (ii) whether bulls could be treated as performing animals and whether the Central Government notification banning their exhibition or training was valid; (iii) whether the Tamil Nadu Regulation of Jallikattu Act, 2009 was repugnant to the Prevention of Cruelty to Animals Act, 1960 and therefore unconstitutional.

Issue (i): Whether Jallikattu and bullock-cart races, as conducted, violated the duties and prohibitions under the Prevention of Cruelty to Animals Act, 1960 and the constitutional duty to protect animals from unnecessary pain and suffering.

Analysis: The Prevention of Cruelty to Animals Act, 1960 was treated as a welfare legislation requiring a liberal construction in favour of animal well-being. Section 3 was read as imposing a positive duty to ensure the well-being of animals and to prevent unnecessary pain or suffering. On the evidence considered, the events subjected bulls to fear, distress, exhaustion, injury, and cruelty, and the conduct was held inconsistent with the statutory duty to safeguard their welfare. Section 11(1)(a) was interpreted broadly, including the phrase "or otherwise", to cover all forms of unnecessary pain and suffering. The Court also read Articles 51A(g) and 51A(h) into the statutory scheme, emphasizing compassion, humanism, and the intrinsic worth of animals.

Conclusion: Jallikattu and bullock-cart races, in the form conducted, were held to violate Section 3 and Section 11(1)(a) of the Prevention of Cruelty to Animals Act, 1960 and the corresponding constitutional duties.

Issue (ii): Whether bulls could be treated as performing animals and whether the Central Government notification banning their exhibition or training was valid.

Analysis: The Court held that bulls are draught and pack animals, not anatomically designed for performance events of this nature. Sections 21 and 22 of the Act, read with the Performing Animals Rules, were interpreted in light of the welfare obligations under Sections 3 and 11. The Court found that the events involved not mere exhibition but incitement of bulls to react under fear and pressure, which attracted Section 11(1)(m)(ii). The notification issued by the Central Government under Section 22 was treated as a valid exercise of statutory power, based on material showing that bulls should not be exhibited or trained as performing animals.

Conclusion: Bulls were held not to be permissible performing animals for these events, and the notification dated 11 July 2011 was upheld.

Issue (iii): Whether the Tamil Nadu Regulation of Jallikattu Act, 2009 was repugnant to the Prevention of Cruelty to Animals Act, 1960 and therefore unconstitutional.

Analysis: The Court held that the Central Act occupied the field as a comprehensive welfare statute and that the State enactment, by permitting and regulating an activity found to cause cruelty and by conferring rights on organizers and bull tamers, conflicted with the statutory protections afforded to animals under the Central Act. The State law was found inconsistent with Sections 3, 11(1)(a), 11(1)(m)(ii), and 22 of the Central Act and therefore hit by Article 254(1). The Court concluded that the State Act could not override the welfare protections secured by Parliament.

Conclusion: The Tamil Nadu Regulation of Jallikattu Act, 2009 was held repugnant to the Prevention of Cruelty to Animals Act, 1960 and void under Article 254(1) of the Constitution of India.

Final Conclusion: The judgment enforced animal welfare as the controlling legal principle, invalidated the State law permitting Jallikattu, sustained the Central prohibition on bulls as performing animals, and directed implementation of the statutory protections owed to animals.

Ratio Decidendi: Animal welfare statutes must be construed to protect animals from unnecessary pain and suffering, and a State law that authorizes or regulates an activity inherently causing such cruelty cannot prevail over a comprehensive Central enactment occupying the same field.

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