Jallikattu Ban
Court Decision
In Effect
May 7, 2014
Summary
On 7 May 2014, a two-judge bench of the Supreme Court of India (Justice K. S. Radhakrishnan and Justice Pinaki Chandra Ghose) pronounced judgment in Animal Welfare Board of India v. A. Nagaraja & Ors. (Civil Appeal Nos. 5387–5388 of 2014), holding that bulls cannot be used as performing animals in Jallikattu events or bullock cart races in Tamil Nadu, Maharashtra, or anywhere else in India. The Court upheld the Ministry of Environment and Forests notification dated 11 July 2011 issued under Section 22 of the Prevention of Cruelty to Animals Act, 1960 (PCA Act), which specified that “bulls” shall not be exhibited or trained as performing animals. The judgment declared that Jallikattu, bullock cart races, and similar events, as then conducted, per se contravene Sections 3, 11(1)(a), and 11(1)(m)(ii) of the PCA Act. The Court struck down the Tamil Nadu Regulation of Jallikattu Act, 2009 (TNRJ Act) as repugnant to the PCA Act under Article 254 of the Constitution, removing the specific state-level legislative framework under which Jallikattu had been regulated and permitted in Tamil Nadu. The Court directed the Animal Welfare Board of India (AWBI) and the Governments of Tamil Nadu and Maharashtra to take steps to prevent conduct of these events in contravention of the PCA Act and 2011 notification. Petitioners included the AWBI as statutory appellant and associated animal protection parties; respondents included A. Nagaraja and other private organisers and the States of Tamil Nadu and Maharashtra. The 2014 judgment operated as the binding legal prohibition on Jallikattu and bullock cart races until the legislative and judicial sequence of 2016–2023 modified its practical effect — documented in a separate Development record covering the 2023 Supreme Court Constitution Bench ruling.
Background Context
Before A. Nagaraja, the PCA Act established general duties to prevent unnecessary pain and suffering to animals (Sections 3 and 11) and empowered the central government under Section 22 to specify animals that shall not be exhibited or trained as performing animals. The 11 July 2011 MoEF notification listing bulls under Section 22 created the regulatory basis for the challenge to Jallikattu. Tamil Nadu had separately enacted the TNRJ Act 2009 to regulate and permit Jallikattu under specified conditions, creating a state framework that operated against the direction of the central notification and the PCA Act. The AWBI filed inspection reports documenting practices during Jallikattu and bullock cart races, providing the evidentiary record for the Court’s statutory analysis. In 2015, the Supreme Court dismissed a Tamil Nadu review petition, retaining the operative effect of the 7 May 2014 judgment. In January 2016, the Ministry of Environment, Forest and Climate Change issued a notification creating a conditional exception for regulated Jallikattu and bullock cart races, which was challenged and referred to a five-judge Constitution Bench in 2018. Tamil Nadu, Karnataka, and Maharashtra enacted PCA amendment acts in 2017 providing fresh legislative basis for these events under modified conditions. On 18 May 2023, the Constitution Bench upheld the 2017 state amendments, holding that their basis altered the A. Nagaraja framework — documented in the India 2023 Jallikattu Development record.
System Impact
Direction
Reduces Exploitation
Type
Alters Legal Basis
Significance
Moderate
The Supreme Court pronounced judgment on 7 May 2014. The judgment took immediate effect upon pronouncement, with no phased implementation. The TNRJ Act 2009 was struck down as constitutionally repugnant. The Court directed AWBI and state authorities to prevent events contrary to the PCA Act and 2011 notification. A 2016 Supreme Court order refusing to lift the ban on Jallikattu explicitly referenced the 7 May 2014 judgment as having “put an end” to the annual event. In 2015, the review petition by the Tamil Nadu government was dismissed, maintaining the prohibition. On 7 January 2016, MoEFCC issued a notification creating a conditional exception for Jallikattu and bullock cart races under specified safeguards; this was challenged before the Supreme Court and the batch of matters was referred to a five-judge Constitution Bench in February 2018. Tamil Nadu enacted the Prevention of Cruelty to Animals (Tamil Nadu Amendment) Act, 2017 in January 2017, providing a new statutory basis for Jallikattu. On 18 May 2023, the five-judge Constitution Bench upheld the validity of the 2017 amendments enacted by Tamil Nadu, Karnataka, and Maharashtra, holding that the basis of A. Nagaraja had been altered by the legislative changes. The 2014 judgment has not been formally overruled but its prohibitory effect on Jallikattu and bullock cart races has been modified by subsequent legislation and the 2023 ruling.
Anticipated Effects
If the 2014 judgment had been consistently enforced without subsequent legislative modification, the prohibition on using bulls as performing animals in Jallikattu and bullock cart races would have removed the legal basis for organised public events using bulls in these sports across India, constraining these specific entertainment uses of bulls in Tamil Nadu, Maharashtra, and other states.
Whether the period between 7 May 2014 and the 2016–2017 legislative modifications produced a measurable reduction in the number of Jallikattu events, participating bulls, or related breeding and training activity is not established in sources consulted.
Significance Rationale
Assigned Reduces Exploitation (impact direction) because the 2014 judgment removed the then-operative legal basis for Jallikattu under the TNRJ Act 2009, upheld the 2011 central notification prohibiting use of bulls as performing animals, and declared that the events as practiced could not be conducted under the PCA Act, directly constraining organised sport use of bulls in Tamil Nadu and Maharashtra.
Assigned Alters Legal Basis (impact type) because the primary mechanism is the Court’s interpretation of the PCA Act to prohibit bull use in Jallikattu and bullock cart races, the invalidation of the TNRJ Act 2009 as repugnant to central law, and the affirmation of the 2011 central notification — changing what is legally permitted for these bovine sport events under Indian law.
Assigned Moderate significance because the judgment directly addresses Jallikattu in Tamil Nadu and bullock cart races in Maharashtra — geographically and sectorally specific components of bovine-use systems rather than the broader cattle or buffalo exploitation systems in Indian agriculture, draught, or slaughter. Within those sport events the judgment removed the operative legal framework, but the scale of exploitation addressed is a specific subset of India’s bovine use.
The duration and persistence of the scale change is not established in available sources; the 2016 central notification, 2017 state amendments, and 2023 Constitution Bench ruling modified the practical effect of the prohibition, and no independently verified time-series data on event or bull counts between 2014 and 2017 is available in sources consulted.
Key Actors
The Supreme Court bench comprised Justice K. S. Radhakrishnan and Justice Pinaki Chandra Ghose. AWBI (Animal Welfare Board of India) was the primary petitioner as statutory appellant. A. Nagaraja and associated private organisers were respondents; the States of Tamil Nadu and Maharashtra were governmental respondents. The Ministry of Environment and Forests issued the 11 July 2011 notification upheld by the Court. PETA India and other animal protection parties participated in connected proceedings. The 2023 Constitution Bench that ultimately upheld state amendments was presided over by Justice K. M. Joseph.
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