The five-judge Constitution Bench delivered the unanimous judgment on 18 May 2023. The Court dismissed petitions from AWBI, PETA India, and allied organisations challenging the 2016 Union notification and the 2017 state amendments. The Tamil Nadu, Karnataka, and Maharashtra amendments had already come into force before the judgment and had been implemented in the years following 2017 — jallikattu events in Tamil Nadu resumed under the 2017 amendment framework from 2018 onward. The 2023 judgment confirms that this implementation was legally valid. The Court directed state competent authorities (District Collectors, local authorities, veterinary officials designated under the rules) to ensure strict compliance with the regulatory conditions in the state amendments and rules. No subsequent Supreme Court decision reversing the 2023 ruling has been reported in sources consulted through early 2024. The 2014 A. Nagaraja judgment remains on record as a historical precedent but no longer operates as a controlling prohibition in the three states with upheld amendments.

Anticipated Effects

If the state amendments and regulatory frameworks are implemented and enforced as directed, jallikattu events in Tamil Nadu, kambala races in Karnataka, and bullock-cart races in Maharashtra would continue to be conducted annually under administrative oversight (event registration, competent authority permissions, on-site veterinary controls).

If the 2023 Constitution Bench’s interpretation of Article 29(1) and the PCA Act framework for state amendments is applied in future cases, other Indian states could in principle seek to authorise analogous animal-based cultural or sporting practices through tailored PCA amendments designed along the lines upheld by the Court.

Whether the 2023 ruling produces measurable increases in the number of animals used annually in these events compared to the 2014–2017 prohibition period is not established in available sources.

Significance Rationale

Assigned Expands Exploitation (impact direction) because the decision validates state amendments that re-establish the legality of using bulls (jallikattu, bullock-cart races) and buffaloes (kambala) as performing animals in Tamil Nadu, Karnataka, and Maharashtra, reinstating organised sport events involving these animals that had been legally prohibited under the 2014 A. Nagaraja ruling. The decision enables the resumption and continuation of events at a scale beyond what was permitted under the nationwide ban.

Assigned Alters Legal Basis (impact type) because the primary mechanism is the Court’s confirmation of the constitutional validity of state amendments that change what is legally permitted regarding the use of bulls and buffaloes in these events — displacing the 2014 Supreme Court prohibition through legislative and judicial re-authorisation.

Assigned Moderate significance because the decision affects three states’ specific bovine sport events (jallikattu in Tamil Nadu, kambala in Karnataka, bullock-cart races in Maharashtra), which are geographically and sectorally specific components of bovine-use systems. The decision does not modify broader cattle or buffalo exploitation in Indian agriculture, dairy, meat, or transport at the national scale.

The duration and persistence of the scale change is not established in available sources; no independently verified time-series data on event counts or participating animal numbers is provided in primary sources consulted.