ANIMAL CRUELTY – A BRUTAL ACT:

CONTENTS:
 Introduction to animal cruelty
 Animal cruelty in India
 Statistical data
 Welfare concerns of farm animals
 Types of Animal cruelty
 Animal cruelty related laws in india
 Conclusion
 Reference

INTRODUCTION TO ANIMAL CRUELTY:

Cruelty is the behaviour which causes physical or mental harm to another or willfully causing
pain or suffering to others.
Animal cruelty is also called as animal abuse or animal neglect Which means causing
harm or inflicting pain to animals. Violence, cruel, unethical and depraved behaviour towards
animals, negligence in providing healthy environment to animals, causing psychological
damages such as terror, torment or distress to animals are considered as animal cruelty.
Animal brutality is increasing day by day. People kill animals for their entertainment
and fun. Some people receive pleasure from inflicting pain, harm, and suffering to animals.
Such condition is called zoosadism.

ANIMAL CRUELTY IN INDIA:

India is said to be the land of ahimsa and a place of empathy to all living creatures.
India is also a place where animals are worshipped equally with god. According to Hindu
mythology Cow, tiger, lion, elephant, horse, bull, snake, monkey etc.. are worshipped. but in
reality it’s totally different. There is no recorded data regarding animal cruelty.
 A pregnant goat was gangraped by 8 men in Haryana.
 A female street dog was raped by a man inside his home in Kolkata.
 100 stray dogs were culled and dumped in a forest area in Hyderabad.
 A man had unnatural sex with three cows in Vadodara.
 Eleven langurs were brutally killed and dumped near highway in Rajasthan.
 Several stray dogs were poisoned to death in Nagpur.
 A stray dog fractured its skull after being beaten with an iron rod in Mumbai.
 A cow was run over by a police vehicle in Chhattisgarh.
  A dog was mercilessly beaten to death by three men in Gujarat.
 Elephants being subjected to torture by traffickers in Rajasthan.
 21 beagles were confined in cages for scientific experiments in Pune.
 A street dog was left to die when workers poured hot tar on it while it was sleeping.  
 A Medical student from Chennai threw a dog off the terrace.
 Sick and wounded horses were used in wedding procession in Delhi.
 A dog raped with screwdriver in Goa.
 A monkey is hung and beaten to death in Telangana.
 A street dog is beaten and ties to a scooter and then thrown off from the second floor
of the building in Ludhiana.
 Sixteen puppies are poisoned by nursing students in Kolkata.
 A pregnant elephant in Kerala died after consuming fruit loaded with firecrackers
are the most recent incidents of animal cruelty in India which proves humanity is completely
dead in India.

The animals whose abuse is most often reported are dogs, cats, horses and livestock.
Undercover investigations have revealed that animal abuse abounds in the factory farm
industry. But because of the weak protections afforded to livestock under state cruelty laws,
only the most shocking cases are reported, and few are ever prosecuted.

STATISTICAL DATA:
In India out of 2,400 cases only five cases are being recorded. In past 10 years India
saw nearly 5 Lakh cases of animal cruelty which are recorded where as unrecorded cases
could be much higher which we cannot imagine.

19,028 cases of animal brutality were recorded in Mumbai in a span of 5 years

(2011-2016). Although, not even a single arrest was made. On May 18th, 2018 almost about
100 dead bodies of dogs were found in the forest area in Kongara, Hyderabad. A pregnant
goat was gang raped by 8 men in Gurgaon, Haryana on July 29th 2018 and was later declared
dead. In August 2017, a man was held accused for raping a young female puppy to death. In
January, 2018 a man in Vadodara allegedly raped 3 cows in Vadodara.

According to a report compiled by the Federation of Indian Animal Protection

Organisations (FIAPO) and All Creatures Great and Small (ACGS), between 2010-2020, a
total of 4,93,910 animals were victims of crimes committed by humans. These include 720
cases of crime against street animals, 741 cases against working animals, 588 cases against
companion animals, 88 cases against farm animals, and 258 cases against wild animals and
birds. These were gruesome and intentional acts of violence that led to the animal’s death or
an irreparable harm. 

Most of the animal cruelty cases are never reported. Although there was no reporting
system for animal cruelty, some media reports say that this happens in both rural and urban
areas. According to the statistics of some media and news reports JAPAN, AUSTRALIA,
CHINA, SPAIN, EGYPT countries are most cruel to animals whereas SWITZERLAND,
HONGKONG, GERMANY, UK countries are most kind to animals.

WELFARE CONCERNS OF FARM ANIMALS:

The following are lists of invasive procedures which cause pain, routinely performed on farm
animals, and housing conditions that routinely cause animal welfare concerns. In one survey
of United States homeowners, 68% of respondents said they consider the price of meat a
more important issue.

Welfare concerns of farm animals

Species Invasive procedures Housing

 Debeaking  High stocking

Broiler chickens density
  Restricted
movement

 Branding
 Castration  High stocking
density
 Dehorning
(feedlots)
 Ear tagging
Cattle  Restricted
 Nose ringing
movement
 Restraint (feedlots)
 Tail docking  Veal crates
 Tongue resection (calves)
 High stocking
 Restraint density
 Artificial insemination  Restricted
 Dehorning movement
Dairy cattle  Ear tagging  Separation from
 Tail docking born child
 Branding (calves)
 Nose ringing  Bounded by
milk machines
 Debeaking
 Desnooding  High stocking
 Detoeing density
Domestic turkeys
 Devocalization  Restricted
 Spur removal movement
 Toe clipping
 Castration
 Docking  High stocking
 Ear cropping density[29]
Dogs
 Ear notching  Restricted
 Slaughter by electrocution movement[28]
 Slaughter by beating[28]
 High stocking
 Force-feeding
density
Ducks and geese  Live-plucking
 Restricted
 Wing clipping
movement
 High stocking
 Debeaking
density
Egg laying hens  Blinders
 Restricted
 Dubbing
movement
Goats and sheep  Ear tagging  High stocking
 Ear notching density (fine
 Dehorning wool
 Marking industry, live
 Mulesing export)
 Tail docking  Restricted
movement (fine
 Teeth grinding
wool
 industry, live
export)
 High stocking
 Castration
density
Horses  Branding
 Restricted
 Chaining
movement
 Castration
 CO2 stunning
 Ear cropping
 Gestation crates
 Ear tagging
 High stocking
 Earmarking
Pigs density
 Nose ringing
 Restricted
 Tail docking
movement
 Tattooing
 Teeth clipping
 Tusk trimming

TYPES OF ANIMAL CRUELTY:

1. Animal neglect
Experts divide the forms of animal cruelty into two categories: passive and active.
Negligence is classified as a passive form of animal abuse. It means that lack of proper action
also matters. If a pet suffers from dehydration, starvation, parasite infestation, lives in
unsuitable weather conditions or else, it is considered to be animal abuse. The pet owner
should be educated in order to be able to provide welfare to their animal companion. The
most common victims of animal neglect are dogs and cats.

2. Domestic animal abuse

Because domestic violence is often motivated by the desire for domination and power, it
often goes hand in hand with animal abuse. If a person can hit their family member, they
almost surely can hit their pet.  Experts are adamant that domestic violence is the most
common background for animal cruelty in children. The importance of this statement cannot
be overestimated, as nearly 32% of all domestic animal cruelty cases were committed by
children.
Moreover, psychologists found a clear link between some specific psychological disorders
and human violence toward animals. Intentional animal cruelty for the sake of pleasure is
considered to be one of the three indicators (the Macdonald triad) of antisocial personality
disorder. The other two factors include obsession with fire-setting and enuresis.

3. Farm animal abuse

Industrial farming is considered a form of animal abuse mainly due to the fact the animals
there live and die in horrible suffering. Although many manufacturers argue that it is
impossible to transport and slaughter a huge amount of animals in a “humane manner,”
animal rights activists demand changes in this department. Did you know that broiler
chickens are fed with steroids to grow faster, but the growth happens so fast that their heart,
lungs, or bones often cannot keep up?  One in a hundred chickens dies because of the steroids
dosages. Farm animals are forced to undergo dozens of painful, invasive procedures, such as
castration, branding, tongue resection, dehorning, ear tagging, dubbing (removing the comb,
earlobes, and wattles of poultry), beak-trimming, tail docking, etc.

4. Cultural rituals
Unfortunately, in some countries, such type of animal abuse is still a thing. For example, in
some Asian countries, people capture elephants and use different cruel methods to “break the
elephants’ spirit,” including starvation, sleep deprivation, dehydration, driving nails into the
ears and feet. In some cultures, people continue to perform sacrificial rituals for healing or
spirits’ blessing.

5. TV and film industry

When you see a cute dog or maybe a wild animal on the screen, think about how they were
tamed and trained, as well as in what conditions they were kept. In case you didn’t know,
even some of the biggest-budget films had multiple precedents of maltreatment and even
killed animals during the production.

6. Circus animal abuse

The use of animals in the circus has always been a controversial topic. There are hundreds of
documentations reporting animal cruelty not only during the training process, but also in
matters of caging, feeding, veterinary care, etc. Nowadays, some circuses present animal-free
performances. The world’s first ban on animals in all circuses has been enacted in Bolivia.
The similar case is with the famous SeaWorld marine-mammal park, where the sea creatures
also become severely maltreated and abused, families become torn apart, and all that happens
in cramped, unnatural living conditions, which leads to much shorter lifespan, everyday pain
and suffering. Such things happen across the whole world in nearly every aquarium or marine
park.

7. Bullfighting
Animal rights activists consider bullfighting a barbaric blood sport that has absolutely no
place in the modern civilized world. During this event, bulls suffer extreme stress and violent,
slow, torturous death. And indeed, the matador rarely kills the bull instantaneous. The
attendees are warned to be prepared for blood and multiple failed attempts at killing the
animal.

8. Unnecessary laboratory experiments, demonstrations, and tests

Yes, we wouldn’t have many life-saving remedies without the experiments on animals.
However, most such activities can surely be classified as animal abuse due to the shift in
ethical standards and development of technologies. According to different scientists,
experiments on dogs, rabbits, mice and other animals are almost never necessary, because the
specialists have human organs-on-chips to model diseases and even test drugs, for example.
Not to mentioned, that too often poorly designed products have led to so many meaningless
animals’ lives.

9. Most horrible types of animal abuse

Dogfighting, dog racing, fur farms, puppy mills, and other extremely violent forms of animal
cruelty simply destroy the faith in humanity. Whether it is for entertainment or money, we
believe that people who organize such activities or operate the business should receive
maximum punishment. Killing dogs and cats to sell fake fur coats, killing dogs because they
aren’t fast enough, force two dogs to fight for their lives through the use of drugs… This is
just absolutely not normal. Blood, death, fights do happen in the wild world. But there’s
always a natural reason behind it – a survival.

ANIMAL CRUELTY RELATED LAWS IN INDIA:

CONSTITUTION OF INDIA, 1949

Article 48 talks about improvement of agriculture and animal husbandry. It provides
guidelines for the state to organize agriculture and animal husbandry based on new modern
and scientific methods and to get rid of the old traditional ones. It prohibits the practice of
animal slaughtering and imposes a complete ban on the slaughtering of cows, calves, milch
and draught cattle.
Article 48A talks about the protection of the environment and wildlife. It directs the state to
protect and improve the condition of the environment, safeguard and preserve the forests and
wildlife of the country.
Article 51A lays down the 11 fundamental duties that were added in the Constitution by the
42nd Amendment act, 1976. Article 51A(g) specifies that it is the utmost duty of every
citizen to protect and preserve the natural environment which includes the wild life, forests,
lakes, rivers etc. It also lays that the citizens must have feelings of compassion and love
towards the animals. 

INDIAN PENAL CODE, 1860

Section 428 and Section 429 lay down that a person who commits any mischief on animals or
cattle with a motive of either causing harm, injury, killing, poisoning or maiming them will
be held punishable with fine or imprisonment up to 5 years or both. Section 377 lays down
that sexual intercourse between a man and animal is a cognizable and non-bailable offence. It
can be termed as an unnatural offence. Whoever has carnal intercourse with any man, woman
or animal against the order of nature will be liable to a punishment of imprisonment of life or
imprisonment which may extend up to 10 years and shall be liable to fine.

THE PREVENTION OF CRUELTY TO ANIMALS ACT, 1960

Prevention of Cruelty to Animals Act was enacted in 1960 by the Parliament of India to
prevent the infliction of unnecessary cruelty and the brutality on animals. It lays down the
acts and the behavior which would amount to animal cruelty and their corresponding
punishments. Section 11 of the PCA, 1960 lays down the major offences which clearly
amount to animal cruelty. 

Section 11(1)
 This lays down the offences relating to Animal Cruelty. They are as follows:

1. If a person beats, kicks, overrides, tortures or treats any animal as to subject it to

immense pain, suffering, agony and discomfort. Or if the owner of the animal permits
it to be treated that way. 
 2. If the owner of the animal permits it to be employed in any kind of work or labor
which is unfit and inappropriate for the health of the animal due to any kind of
infection, disease, wound or even age.
3. If a person intentionally and unreasonably injects or administers any kind of harmful
drug or chemical into the bodies of animals. Even the attempt to do so is an offence.
4. Transportation or carrying of animals in a vehicle in such a manner that it causes them
pain and discomfort.
5. Keeping an animal caged or confined in a space which is extremely small or not
suitable for its size.
6. When an owner of an animal unreasonably neglects it by excessive solid chaining for
a long period of time in a confined space.
7. Failure in providing an animal with the right amount of nutrition, sufficient food,
drinking water etc.
8. Abandoning animals without any reasonable cause which leads to deprivation of food,
water and shelter.
9. Permitting an animal while it is affected by a contagious disease or infection to go out
in the streets without any protection. Letting any disabled or affected animal die in the
streets.
10. Offer of sale of an animal suffering immense pain due to starvation, thirst, mutilation
or any other harsh treatment.
11. Mutilation or killing of any animal (including stray dogs) by the use of any strychnine
injection into the heart or any other brutal way or manner.
12.  Keeping an animal in a confined caged space either for entertainment purposes or to
pose as a bait or prey to some other animal. Provoking or instigating animals to fight
against each other.
13. Use of animals either for animal fighting or animal baiting like dog fighting, cock
fighting, bull fighting etc.
14. Animals being used to shooting matches or competitions where they are brutally shot.
All the above offences are punishable by law. In case of an offence committed for the first
time, a fine of not less than not less than ten rupees is imposed which may extend up to fifty
rupees. In case of an offence committed for a subsequent time, within 3 years of the previous
offence, a fine of not less than twenty-five rupees which may extend up to fifty rupees is
imposed or with imprisonment for a term of 3 months or both. 

Section 12: Prohibition of practising Phooka

Phooka is known as the practice of injecting a harmful kind of substance or drug into the
bodies of cows or any cattle to improve the process of lactation. This practice is prohibited
since it proves to be very harmful and painful to the animals. Liable to a fine which may
extend up to one thousand rupees or imprisonment up to 2 years or both.

Section 13: Order for Destruction of Suffering Animals

When the owner of the animal is convicted of an offence under section 11, if the court is
satisfied that it would be cruel enough to keep the animal alive, then the court shall direct a
lawful order to cause the destruction of that animal. A person will be assigned to destroy the
animal without causing any more unreasonable harm and suffering. Any expenses incurred
during the destruction process shall be paid by the owner as fine. This is done so as to free
such animal from the immense pain, torture and suffering that it will endure if it were to be
alive, which would amount to cruelty. This destruction method is put into use when the
animal is either severely diseased or injured. 

Section 14: Experimentation and Product Testing of Animals 

Although the act does not provide any penalties, it renders the performance of laboratory
experiments and product testing on animals unlawful. India is the first South-Asian country to
impose a ban on the Cosmetic animal testing. The bureau of Indian Standards has confirmed
the removal of animal testing by the cosmetic brands. Any manufacturer who wishes to run a
test of the cosmetic ingredients or finished products, must seek permission from the India’s
Central Drug Standards Organization Control. A manufacturer will be given permission only
if he agrees to the BIS non-animal testing standards. 
As per Section 148(c) of the Drugs and Cosmetic rules 1945, cosmetic testing on animals
have been banned within the country. 
As per Section 135(b) of the Drugs and Cosmetic rules, 1945, import of cosmetic goods
which are tested on animals abroad have been banned within the country. 

THE WILD LIFE PROTECTION ACT, 1972

The Wildlife Protection Act was enacted by the Parliament of India on 9th September, 1972.
It consists of 66 sections and 6 schedules. The main objective of the act was to provide
protection to the wildlife flora and fauna and prevent unnecessary infliction of harm on
animals. 

Section 9: Prohibition of Hunting 

Hunting is prohibited under section 9 of the Chapter III of The Wildlife Protection Act, 1972.
Hunting of any wild animals specified under Schedule I, schedule II and schedule III of the
act is illegal and prohibited.

Section 38(J): Prohibition of Teasing, Injuring Animals in Zoo

Section 38 (J) under chapter IV A lays down that any person who injures, teases, molests or
causes any kind of harm or discomfort to the animals in the zoo will be held punishable by
the law.

Section 51: Provisions for Penalties 

 Whoever violates the provisions of section 38 (J) will be held liable for a term of
imprisonment up to 6 months or a fine which may extend up to two thousand rupees or
both. 
  Chapter VA deals with the prohibition of trade and commerce of any article, weapons
or trophies etc. derived from the skin of animals. Any person violating the provisions
of this chapter will be punishable with a term of imprisonment not less than three
years and also with a fine not less than ten thousand rupees. 
 Any person who violates the provisions of section 9 or commits any offence (hunts or
hurts) against an animal specified in schedule I, II, III or IV will be punishable with a
term of imprisonment not less than 3 years which may extend up to 7 years and with a
fine not less than twenty-five thousand rupees or both. For the first time offenders,
imprisonment terms remaining the same and with a fine of ten thousand rupees. 

INDIAN CASE LAWS RELATED TO ANIMAL CRUELTY:

1.      State of Bihar v. Murad Ali Baig, AIR 1989 SC 1.
This case dealt with the provisions of the Wildlife Protection Act, 1972. It specifically dealt
with the hunting of elephants and whether the hunting of elephants is justified under the
provisions of the Indian Penal Code and under the necessary provisions of the Wildlife
Protection Act. The word, “hunting” has been defined under Section 2(16) of the Wildlife
Protection Act, 1972 as follows: “Hunting means- i) the killing or poisoning of any wild
animal or captive animal as well as an attempt to do so; ii) capturing, coursing, snaring,
trapping, driving or baiting any animal as well as any attempt to do so; iii) injuring or
destroying or taking any part of the body of any such animal; iv) in the case of wild birds or
reptiles, damaging the eggs of such birds or reptiles or disturbing the eggs or nests of such
birds or reptiles.” [4]  The case further dealt with the provisions of Section 9 of the Act which
lays down that, “No person shall hunt any wild animals specified in Schedules I, II, III and IV
except as provided under Section 11 and 12 of the Act.” [5]
Emphasis was laid upon the provisions of Section 11 and 12 of the Act, which provides a
Schedule. Schedule I of the act contained a list of animals, amphibians, reptiles, fishes, birds
and insects, e.g. Himalayan Brown Bears, Black Bucks, Cheetahs, elephants, crocodiles,
pythons, whale sharks, sea horses, vultures, etc. Schedule II of the act covered animals like
the Bengal Porcupine, wild dogs, chameleons, etc. Schedule III of the act covered animals
like the barking deer, hog deer, hyenas, etc, however, the Schedule IV covered under its
scope hares, pole cats, Indian porcupines and a lot of other species of birds like the cranes,
the cuckoos and the bulbuls.
The Supreme Court in this case, held that since the elephant was an animal which fell under
the scope and list of animals provided under the Schedule I, it can be assumed that the
hunting of elephants is prohibited. The Court was also of the view that the offense of,
“hunting” as defined under the Wildlife Protection Act, 1972, is not the same as the offense
which is committed under Section 429 of the Indian Penal Code (which provides for the
punishment for killing, poisoning, maiming, etc. of any elephants, camel, horse and other
animals, the list of which is provided under the ambit of the said section.) The Supreme Court
was of the view that the ingredients of the offense provided under the Wildlife Protection
Act, 1972 is quite contrary to the ingredients of the offense provided under the scope and
ambit of the Indian Penal Code and hence the two offenses are not the same.

2.      Tilak Bahadur Rai v. State of Arunachal Pradesh, 1979 Cr. L.J. 1404.
In this case, the accused shot and killed a Tiger. It was held by the court that while taking a
decision with regards to whether the accused acted in good faith or not when he killed a wild
animal, it is imperative to understand the nature and the dangers that lurked around the
accused and under what circumstances did the accused kill the animal. After due
deliberations and arguments put forth by both the parties, the Court was of the view that the
accused shot the tiger that charged at him in good faith and as a means to protect himself. The
Court was of the view that if the accused hadn’t shot the tiger which was charging towards
him, planning to attack him, then the accused would have been dead. Therefore, in order to
protect himself, he shot the tiger and this can be amounted as self-defense and was, therefore,
justified. It was also clarified in this judgement that if any animal is killed or wounded as by
an individual as a means to protect himself, then such animal is the property of the
government. The individual who has shot or killed or injured the animal has no claim on such
an animal.
 
3.      Tarun Bharat Sangh, Alwar v. Union of India (1992 Supp (2) SCC 448)
In this case, a social action group, a voluntary organization, filed a Public Interest Litigation
(PIL) in the Supreme Court of India under Article 32 of the Constitution of India, claiming
that the Rajasthan State Government had issued a number of Notifications declaring the
Sariska Tiger Park as a sanctuary, however, the petitioner was of the view that there was
widespread illegal mining activity going on in the aforesaid area and the State Government
had issued licenses for carrying out such mining activities. It was held by the petitioner that
there were a number of notifications issued previously which prohibited all sorts of mining
activities in that area, however, the State Government of Rajasthan granted hundreds of
licenses for conducting mining activities. The mining of marble, dolomite and other materials
was being carried out which was deemed to be in total contravention to the guidelines which
were laid down in the Notifications which were issued previously. The petitioner contended
that these mining activities impaired the environment and the wildlife within the park. The
Court then decided to appoint a committee which would study and understand the objective
of the various acts and Notifications which were issued in respect of the particular protected
area. The committee found that there were 215 mines which completely fell outside the areas
which were deemed to be declared as protected forest, while the other 47 mines fell partially
under the ambit and partially outside the ambit of the areas declared as protected forest. The
Court was of the view that this was a simple matter wherein it was the job of the court to
simply ensure whether the laws which were enacted in that particular area were being
adhered to or not and it was the duty of the State to protect the environment and the ecology
of the impugned area in question. The Supreme Court took cognizance of this situation and
passed an order which directed that no mining operations could be conducted any further
within the area which was demarcated as, “protected”. It also went on to further appoint a
Committee headed by a retired judge to ensure that the wild life within the park is secure. 
Besides this, it directed that all the mining activities which were conducted in the mines
which were located outside the protected forest areas, but within the territorial boundaries of
the tiger reserve could continue for a period of four months, however, if no permission is
obtained by the miners within a period of four months, then mining activities in the entire
area which was declared as a tiger reserve had to be stopped for good.
 
4.      Naveen Raheja v. Union of India [(2001) 9 SCC 762].
In this case, the Supreme Court dealt with a gruesome issue. The issue was with regards to
the skinning of a tiger in a zoo in Andhra Pradesh. The Supreme Court was in utter shock and
dismay when it first heard the facts of the case. The Court was utterly tormented at the fact
that such a gruesome act was indulged into by humans, rendering the voiceless animal
helpless and in sheer pain and agony. The tiger received no protection from those whose duty
it was to protect it and look after its well-being. The Top court of India, therefore, was of the
view that it was extremely necessary to summon the chairperson of the Central Zoo Authority
to appear before the court in person and to elucidate on what steps and measures were being
taken to protect and preserve the tiger population in zoos and reserved forests. The Supreme
Court then passed appropriate orders in the said issue and gave the necessary orders with
regards to the protection of tigers. The Supreme Court elucidated that it is necessary for the
Central Zoo Authority to take cognizance of this issue and take the necessary steps in order to
protect the plight of these voiceless creatures as the situation in which they are is quite
distressful and far from satisfactory.

CONCLUSION:
For most of the people worldwide, meat is considered as a go-to meal, be it
breakfast, lunch or dinner. What most of the people don’t realize is how and
from where all the meat and chicken in the world is coming from. Animal
cruelty is a very sensitive and serious issue. Pain is felt by each and every
living organism, be it humans or animals. The brutal action against the
innocent creatures is rarely acknowledged and very few people feel the urge
of raising their voice against animal cruelty. Therefore, by the way of this
paper, I tried to focus on the types of animal cruelty, the depraved customs
and traditions which are practiced across the world. People should know that
all lives matter, be it humans or animals. It can be seen how humans misuse
their power and lack the feelings of love and compassion towards the
animals. Animals do not have any rights of their own, they do not have a
voice to protect themselves from cruelty, thus they go through unspeakable
sufferings daily. Just as humans, even animals deserve to lead a happy and
painless life. As humans, it is our duty to speak up for those who cannot
speak for themselves. 

REFERENCE:
 http://www.scroll.in/
 http://www.new indian express.com/
 http://www.indiatimes.com/
 http://www.humansociety.org/
 http://www.scoopwhoop.com/
 http://www.en.wikipedia.org/
 http://www.blog.ipleaders,in/
 http://www.fabiosa.com/
 http://www.ipsnews.net/