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People for The Ethical Treatment of Animals Peta India Vs. The Committee for Control and Supervision of Experiments on Animals CCSEA

  Delhi High Court W.P.(C) 9350/2025
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W.P.(C) 9350/2025 Page 1 of 20

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* IN THE HIGH COURT OF DELHI AT NEW DELHI

% Judgment pronounced on: 16.09.2025

+

PEOPLE FOR THE ETHICAL TREATMENT OF ANIMALS PETA

INDIA .....Petitioner

W.P.(C) 9350/2025 and CM APPLs.39564/2025, 44484/2025,

44511/2025, 46954/20 25, 47384/2025, 48673/2025 & 50602/2025

Through: Mr. Rajshekhar Rao, Sr. Adv ocate

along with Ms. Pritha Srikumar,

Ms. Arunima Kedia, Ms. Meghna

Sharma, Ms. Saumya Sinha and

Mr. W. Wasin, Advocates.

versus

THE COMMITTEE FOR CONTROL AND SUPERVISION OF

EXPERIMENTS ON ANIMALS CCSEA, MINISTRY OF

FISHERIES, ANIMAL HUSBANDRY AND DAIRYING,

GOVERNMENT OF INDIA THROUGH ITS CHAIRMAN & ANR.

.....Respondents

Through: Mr. Rajesh Gogna, CGSC alon g with

Mr. Shivam Tiwari, Ms. Priya,

Ms. Robina and Mr. Anubhav Tyagi

(GP), Advocates.

Mr. Vivek Kohli, Sr. Advocate along

with Mr. S. Santanam Swaminadhin,

Mr. Kartik Malhotra, Mr. A. Mandal,

Ms. Vasudha Chadha, Advocates for

R-2.

CORAM:

HON'BLE MR. JUSTICE SACHIN DATTA

JUDGMENT

1. The present petition has been filed by the petitioner seeking the

W.P.(C) 9350/2025 Page 2 of 20

following prayers:

“a. Issue a writ of mandamus to Respondent No. 1 to revoke the licenses

and registrations granted to Respondent No. 2 to breed or use animals

and to permanently shut down the facility;

b. ⁠Issue appropriate directions for rehabilitation of the animals currently

housed at the facility of Respondent No. 2;

c. Award costs of this petition; and

e. Pass such further or other orders as this Hon'ble Court may deem fit

and proper in the circumstances of the case”.

2. The petitioner is a reputed animal welfare organisation registered

under Section 25 of the Companies Act, 1956, that works extensively

towards the prevention of animal suffering/exploitation . Respondent

no.1/The Committee for Control and Supervision of Experiments on Animal

(CCSEA), Ministry of Fisheries, Animal Husbandry and Dairying,

Government of India, is a Committee constituted under Section 15(1) of the

Prevention of Cruelty to Animals Act, 1960 (hereinafter referred as “PCA

Act”) for the purpose of controlling and supervising experimentation on

animals and has the power to regulate its own procedure in relation to the

performance of its duties; respondent no.2/ Palamur Biosciences Pvt. Ltd., is

a Preclinical Contract Research Organisation which operates an integrated

research facility capable of conducting extensive research involving both

large and small animals, including beagle dogs, mini pigs etc. and, is

registered with the respondent no.1, and also holds approvals/ certification

from various other bodies.

3. The factual background, as canvassed by the petitioner is that it

received information which allegedly documented /reported abuse and

neglect of animals while carrying out experimentation and treatment of

W.P.(C) 9350/2025 Page 3 of 20

beagles used for breeding at the facility of respondent no.2. The petitioner

reported the same on 10.06.2025 to the respondent no.1, and various other

concerned authorities. T he petitioner sought initiation of appropriate action

against the respondent no.2, including revocation of its registration and

permission to breed and experiment on animals and, the rehabilitation of the

surviving animals.

4. Consequently, a Multi-D isciplinary Expert Committee, authorized by

the respondent no.1, comprising of members from CCSEA/respondent no.1,

the Animal Welfare Board of India, the Institutional Animal Ethics

Committee, and Humane Worlds for Animals India Foundation was

constituted to conduct an inspection of the facility of respondent no.2

located at Karvena (Village) Bhoothpur (Mandal) Ma habubnagar-District-

509001, Telangana. The said Committee conducted inspections on

11.06.2025 and 12.06.2025 and thereafter submitted a report on 17.06.2025,

recording observations which corroborated the information in receipt of the

petitioner viz. the acts of cruelty and regulatory lapses by respondent no.2,

and recommended a detailed Micro Audit of the respondent no.2 facility.

The relevant portion of the said report reads as under: -

“X. Discussion

The comprehensive inspection of PBPL highlights systemic failures at

multiple levels of its operations to uphold animal ethics and welfare as per

CCSEA guidelines. PBPL's approach to animal research demonstrates an

operational model that prioritizes experimental output over welfare,

compliance, and ethical responsibility. Despite its extensive use of dogs,

non-human primates, pigs, and other species, PBPL has failed to implement

even the most basic standards of care mandated by CCSEA.

Housing conditions were consistently found to be overcrowded, barren, and

inadequate, leading to significant welfare concerns such as elevated stress,

noise, poor body condition, and heightened risk of infectious diseases.

Essential aspects such as environmental enrichment, social interaction, and

W.P.(C) 9350/2025 Page 4 of 20

proper bedding were either entirely absent or grossly insufficient across all

species. The breeding facilities were particularly concerning, with

overproduction of animals resulting in unauthorized repurposing of

experimental spaces as stock rooms, unscreened animal transfers, and

potential biosecurity risks.

Veterinary care infrastructure was deeply inadequate. The facility

maintained minimal medical supplies, lacked essential analgesics,

sedatives, and anaesthetics, and failed to maintain proper treatment

records. Notably, no protocol was in place to manage anxiety, fear, or

distress- an essential component of humane animal care. Painful and

invasive procedures, such as those performed on monkeys involving

surgical implantation, were conducted using only analgesics post

procedure, with animals physically restrained without sedatives. Similarly,

dogs euthanised at the conclusion of research were not sedated before the

administration of thiopentone sodium. These practices reflect glaring

omissions in veterinary planning and a disregard for psychological well -

being.

The animal record- keeping system at PBPL is virtually non- functional, with

key regulatory documentation either missing or grossly insufficient. Without

breeding records, reuse data, health histories, or procedural logs, PBPL

operates in opaque conditions that obstruct regulatory oversight. The

deliberate non- cooperation during inspection - notably the failure to

provide CCTV footage from critical areas - raises serious questions about

transparency and intent.

The inspection also uncovered troubling deviations from approved

euthanasia protocols. Animals were euthanised without sedation, relying

solely on physical restraint-a practice incompatible with ethical norms of

humane care. The high euthanasia rate suggests an unsustainable use

pattern where large numbers of animals are systematically killed after

experimental use, with limited rehabilitation or rehoming efforts.

XI. Conclusion

The operational deficiencies observed at PBPL are not isolated incidents

but indicative of entrenched structural, procedural, and ethical failures. The

scale and severity of noncompliance documented during the inspection raise

significant concerns regarding the facility's adherence to established

standards of animal welfare and regulatory accountability.

The situation demands urgent attention- particularly with respect to the

removal and rehabilitation of animals to prevent further pain, distress, or

suffering. The findings also call for a critical review of the facility's

registration and breeding licence, in view of the serious and repeated

W.P.(C) 9350/2025 Page 5 of 20

deviations from prescribed norms. A detailed micro- audit of PBPL's

Institutional Animal Ethics Committee (IAEC) is imperative, including a

comprehensive reconciliation of records relating to breeding, procurement,

experimentation, reuse, rehabilitation, transfer, euthanasia, and disposal.

Such scrutiny is essential to evaluate compliance with approved protocols

and to verify the accuracy and integrity of reported data.”

5. The counter affidavits filed on behalf of the respondent nos. 1 and 2

inter-alia discloses that consequent to the inspection report dated 17.06.2025

submitted by the multidisciplinary committee, the respondent no.1 issued a

show cause notice dated 25.06.2025 under Section 19 of the PCA Act to the

respondent no.2 and in terms of Section 18 of the PCA Act constituted a

second inspection team for conducting a micro audit at the facility of

respondent no.2. Subsequently, the second inspection team conducted audits

at the facility of respondent no.2 between 28.06.2025 and 29.06.2025 and

submitted a comprehensive report on 10.07.2025.

6. In the meantime (prior to submission of the comprehensive report

dated 10.07.2025 by the second inspection team), the present petition was

preferred before this Court inter- alia seeking to direct the respondent no.1 to

revoke the licenses and registrations granted to respondent no.2 to breed or

use animals and to permanently shut down the said facility.

7. The case of the petitioner before this Court is that, despite a detailed

inspection of the said facility being undertaken by respondent no.1, resulting

in categorical findings in the inspection report dated 17.06.2025 as regards

mismanagement and failure to adhere to applicable norms and

recommendation for immediate rehabilitation of the animals housed at the

facility of the respondent no.2, respondent no.1 failed to address the

violation of animals’ rights and regulatory non-compliances taking place at

W.P.(C) 9350/2025 Page 6 of 20

the hands of the respondent no.2 at its facility.

8. Considering the averments made in the present petition, this Court

vide order dated 08.07.2025 directed respondent no.1 to conduct a fresh

inspection along with a representative of the petitioner and restrained the

respondent no.2 from procuring/housing any new animals at its facility till

the aforesaid exercise is being conducted. The relevant portion of the said

order reads as under:

“..................................

13. Accordingly, the respondent no.1 is directed to take immediate steps

to ensure that the necessary remedial steps are taken, and measures put

in place for providing veterinary treatment, proper handling of animals

and also to prevent proliferation of practices such as euthanasia,

treatment without sedatives, etc. Adequate arrangement is also required

to be placed for proper habitat of the animals.

14. For the aforesaid purpose, let an inspection be conducted by the

respondent no.1 along with representatives of the petitioner to identify

the areas of concern. Let the same be done within one week. Let requisite

steps be taken within a period of two weeks thereafter. Let a Status

Report be filed within four weeks from today.

15. Till the aforesaid exercise is conducted, the respondent no.2 is

restrained from procuring/ housing any new animals at its facility.”

9. However, respondent no.2 preferred two applications before this

Court in the present proceedings [CM APPL.41110/2025 and CM

APPL.41112/2025] seeking modification and recall of the aforesaid

directions in the order dated 08.07.2025, and in particular paragraph 14

thereof, apprehending that permitting a representative of the petitioner to

accompany inspecting authority to the facility of respondent no.2 would

tantamount to allowing an adversarial and non-regulatory party , access to

sensitive research areas with potential likelihood of misuse of such access.

10. An application [CM APPL.41783/2025] was also filed by the

W.P.(C) 9350/2025 Page 7 of 20

respondent no.1 seeking modification of the aforementioned order, in

particular paragraph 14 thereof, averring that joint inspection with a private

third-pa rty (i) is contrary to the statutory mechanism under the PCA Act,

which vests inspection and enforcement powers exclusively with respondent

no.1 and its authorized personnel/ s (ii) undermines statutory confidentiality,

risks procedural irregularity and compromises the regulatory neutrality

intended by law.

11. In view of the aforesaid applications, with consent of the parties to the

present proceedings , vide order dated 17.07.2025 paragraph 14 of the order

dated 08.07.2025 was modified and a Local Commissioner was appointed

by this Court to act as an observer during the said inspection. The order

dated 17.07.2025 reads as under: -

“1. With the consent of the parties, the directions contained in

paragraph- 14 of the order dated 08.07.2025 are modified inasmuch as

the inspection as directed to be conducted thereunder shall now be

conducted by the respondent no.1 along with Dr. S. G. Rama Chandran,

Chief Scientist, Indian Institute of Science (IISc), Bangalore.

2. The expenses to enable Dr. S. G. Rama Chandran to participate in the

inspection shall be borne by the respondent no.1. Let the inspection be

carried out within a period of one week. Let the inspection be video-

graphed and kept in a sealed cover.

3. The respondent no.1, as also Dr. S. G. Rama Chandran are directed to

file a report as to the outcome of the inspection within a period of two

weeks after the date of inspection.

4. Let a status report be also filed by the respondent no.1 as to the action

taken pursuant to the areas of concern, if any, identified during the

inspection.

5. Dr. S. G. Rama Chandran is directed to join the proceedings virtually

on the next date of hearing.

6. It is further directed that Ms. Shradha Deshmukh, Advocate is

appointed as a Local Commissioner to act as an observer during the

W.P.(C) 9350/2025 Page 8 of 20

inspection. Let a report be also filed by the said Local Commissioner

before the next date of hearing. The Local Commissioner shall be paid

fees of Rs. 1 lakh, to be borne by the petitioner.

7. The rest of the directions contained in the order dated 08.07.2025

shall continue to operate.”

12. In terms of the aforesaid orders, an inspection was conducted by Dr.

S.K Dutta, Member Secretary of respondent no.1 and Dr. S.G. Rama

Chandran, Chief Scientist, Indian Institute of Science (IISc), Bangalore.

Consequently, a report dated 24.07.2025 has been placed on record and

perused by this Court.

13. It transpires that although an inspection was conducted in the

aftermath of the aforesaid orders dated 08.07.2025 and 17.07.2025, the

Local Commissioner appointed vide order dated 17.07.2025 did not

participate therein, in view of the circumstances narrated in the report dated

01.08.2025, filed by the Local Commissioner. The same inter alia states as

under:

“....................................................

6. In response, an email was received on 24.07.2024 from Ms. Saumya

Sinha, Counsel for the Petitioner, marking a copy to the CPCEA-MEF,

Mr. Rammurthy, Dr. SK Dutta, Mr. SG Ramachandra, Ms. Pritha

Srikumar and Mr. Sulabh Rewari, wherein it was stated that the

Petitioner had orally mentioned the matter on 21.07.2025 before the

Hon’ble High Court in the presence of Respondent No. 1’s counsel and

Dr Tyagi, seeking alteration to the attendees of the inspection. It was

also stated that upon mentioning, the Hon’ble High Court had directed

that an Application for the said relief be filed by the Petitioner. The email

noted that a copy of the said Application had been served upon CCSEA

and the same was to be listed before the Hon’ble High Court in a day or

so. A copy of the Application seeking Modification of the Order dated

17.07.2025 was also enclosed alongwith the said Email, where

objections were raised regarding the impartiality of the Sr. Scientist to

conduct the said inspection.

7. Furthermore, the said e-mail stated that the Petitioner had been kept

W.P.(C) 9350/2025 Page 9 of 20

out of the loop in relation to the said inspection despite the fact that

CCSEA had vide its letter dated 22.07.2025 asked the Petitioner to

coordinate with the Court Commissioner in relation to the inspection.

Accordingly, a request was made by the Counsel for the Petitioner to

defer the inspection until further orders were passed by the Hon’ble High

Court. A copy of the Email dated 24.07.2025 received from the Petitioner

along with its enclosed attachments is attached herewith as ANNEXURE

A-5.

8. Having been made aware of the pendency of the Application before the

Hon’ble High Court, which as per the statement of the Petitioner, was

filed pursuant to the direction given by the Hon’ble High Court on an

oral mentioning, and where a challenge had been made to the

independence of the Sr. Scientist who was to conduct the very inspection,

I felt it appropriate that the inspection be deferred until a decision was

taken by the Hon’ble High Court in relation to the same.

9. Accordingly, I addressed an email on 24.07.2025 to both the parties,

stating that it would be appropriate to await the decision of the Hon’ble

High Court and conduct the inspection subject to the directions, if any,

passed by the Hon’ble High Court with respect to the Application. I

requested both the parties to keep me informed regarding the outcome of

the said Application so that the next date of the inspection could be

scheduled with the mutual consent of the parties. A copy of the email

dated 24.07.2025 is attached herewith as ANNEXURE A- 6. ...........”

14. The petitioner, by way of an application bearing CM No . 44484/2025

has, inter-alia, averred that Dr. S. G. Rama Chandran (who was directed to

conduct the inspection in terms of directions contained in the order dated

17.07.2025) has a ‘ conflict of interest’ since (i), as per the official records he

has been serving as the Chief Research Scientist since 1991 at the Central

Animal Facility, Indian Institute of Science, Bangalore, which itself is an

animal experimentation facility, and as such is focused on ‘ animal use’ as

compared to welfare (ii) vide notification dated 16.01.2025 Dr. S. G. Rama

Chandran was notified as a member of respondent no.1 Core Committee

itself.

15. Learned senior counsel on behalf of the petitioner also submits that in

W.P.(C) 9350/2025 Page 10 of 20

contradiction to the findings rendered in an earlier inspection conducted on

11.06.2025 and 12.06.2025 at the same facility by the Multi -Disciplinary

Committee, the third inspection report placed before this Court virtually

gives a clean chit to the respondent no.2.

16. Evidently, till date three inspections have been conducted in respect

of the facility of the respondent no.2: -

i. Multi-Disciplinary Committee constituted by respondent no.1

conducted an inspection on 11.06.2025 and 12.06.2025, and thereafter

submitted its inspection report on 17.06.2025 (hereinafter referred as

“the first inspection”).

ii. Micro Audit /second inspection committee constituted by the

respondent no.1 conducted inspection between 28.06.2025 and

29.06.2025, and thereafter submitted an inspection report dated

10.07.2025 (hereinafter referred as “the second inspection”).

iii. Inspection conducted by a committee constituted pursuant to the

direction passed by this Court vide order dated 17.07.2025 in the

present proceedings, which submitted a report dated 24.07.2025

(hereinafter referred as “the third inspection”).

17. The stark contrast between the findings rendered in the latest

inspection report submitted by respondent no.1 and Dr. S. G. Rama

Chandran (pursuant to order dated 17.07.2025 ) vis-a-vis the earlier

inspections has been encapsulated in the following chart submitted by the

learned senior counsel on behalf of the petitioner :

W.P.(C) 9350/2025 Page 11 of 20

W.P.(C) 9350/2025 Page 12 of 20

W.P.(C) 9350/2025 Page 13 of 20

W.P.(C) 9350/2025 Page 14 of 20

W.P.(C) 9350/2025 Page 15 of 20

W.P.(C) 9350/2025 Page 16 of 20

W.P.(C) 9350/2025 Page 17 of 20

W.P.(C) 9350/2025 Page 18 of 20

18. During the course of proceedings, Mr. Vivek Kohli, learned senior

counsel for the respondent no.2 submits that although the respondent no.2

facility conducts experiments in strict conformity with the terms of Licenses

and the POCA Act and Rule framed thereunder, if there still exist certain

shortcomings in the said facility, the respondent no.2 is committed to take

requisite steps to overcome / rectify the same.

19. It is evident that the inspection conducted pursuant to order dated

17.07.2025 is mired in controversy inasmuch as (i) the same was conducted

in the absence of the Local Commissioner appointed by this Court vide order

dated 17.07.2025 (in view of the circumstances enumerated by the Local

Commissioner in her affidavit); (ii) serious allegations have been made by

the petitioner as regards ‘conflict of interest’ of Dr. S. G. Rama Chandran

(who, along with the Local Commissioner, was entrusted with the task of

inspection at the facility of the respondent no.2).

20. In the circumstances, it is directed that a fresh inspection be

undertaken at the facility of the respondent no.2. The modalities for conduct

of the inspection shall be as under:

i. The inspection team shall comprise of three members viz.:

(a) Dr. Arvind Ingle, Member of CCSEA;

W.P.(C) 9350/2025 Page 19 of 20

(b) Dr. M. Jerald Mahesh Kumar, Principal Scientist CCMB,

Hyderabad

(both being members of committee constituted by the respondent no.1

for conducting micro-audit on 28.06.2025 and 29.06.2025) ; and

(c) Ms. Shradha Deshmukh, Local Commissioner (appointed by this

Court in the present proceedings vide order dated 17.07.2025).

ii. The aforesaid Local Commissioner shall be entitl ed to take the

assistance of a veterinarian who shall accompany the Local

Commissioner during the inspection. The Local Commissioner shall

ensure that the veterinarian neither has affiliation with the petitioner

nor has any conflict of interest with either of the parties. The cost/s for

the same shall be borne by the petitioner.

iii. The inspection shall be conducted as expeditiously as possible and in

any event, within a period of three weeks from today. The Local

Commissioner shall coordinate with the concerned parties and the

other members of the Inspection team to fix the date and time for the

aforesaid inspection.

iv. For the aforesaid exercise, the Local Commissioner shall be paid a

sum of Rs.2 Lakhs by the petitioner (in addition to expense s and the

fee/s directed to be paid to the Local Commissioner vide order dated

17.07.2025). The charges for the other members of the Inspection

Committee (if any) shall be borne by the respondent no.1 and / or the

respondent no.2.

21. Upon conclusion of the aforesaid exercise, the inspection report

(together with recommendations, if any) shall be provided to the petitioner

and the respondents. Upon receipt of the inspection report, the respondent

W.P.(C) 9350/2025 Page 20 of 20

no.1 shall take cognizance of any deficiencies that may be revealed in the

inspection report and shall take appropriate steps in accordance with law.

The respondent no.2 shall also take immediate rectificatory steps as may be

warranted in terms of the inspection report and/or directions issued by the

respondent no.1. This Court acknowledges the fair stand of Mr. Vivek

Kohli, learned senior counsel for the respondent no.2, that appropriate

rectificatory steps (as may be required) shall be taken if any deficiencies are

found during inspection.

22. The interim order dated 08.07.2025, whereby, the respondent no.2

was restrained from procuring / housing any new animals at its facility, shall

stand vacated upon the aforesaid inspection being conducted.

23. Needless to say, the respondent no.1 shall continue to exercise its

regulatory oversight in respect of the activities of the respondent no.2 to

ensure that the said respondent is in compliance with all applicable rules and

guidelines.

24. The petition is disposed of in the above terms. Pending applications

also stand disposed of.

SACHIN DATTA, J

SEPTEMBER 16, 2025

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