20 days to go Objections close:
Labs could soon approve their own animal experiments.
India has published draft rules that move most approvals for animal experiments from the national committee to each lab’s own committee. Read what the rules say, then send your objection in two minutes.
What’s happening
On the Gazette of India published draft rules (G.S.R. 864(E)) to replace the 1968 and 1998 rules on experiments on animals in India. The public has 30 days to send objections to the Committee for Control and Supervision of Experiments on Animals (CCSEA).
- : notification signed
- : published in the Gazette
- : last day for objections
What the draft does
Labs approve most experiments themselves
Mild and moderate experiments on any species, including dogs and monkeys, would be approved by the lab’s own ethics committee and not sent to CCSEA. CCSEA only receives reports for animals larger than rabbits.
Some animals could come from open markets
If registered breeders can’t supply them, livestock, farm animals, fish and birds could be bought from unregistered sources or the open market, with only the lab committee’s approval.
Strays: banned, with exemptions
Stray and feral animals are not to be used, but “competent authorities”, never defined in the draft, can grant exemptions. In 2022 the regulator told labs stray dogs may be used in vaccine trials, and withdrew that in 2023.
Wildlife and monkeys: allowed under conditions
Protected species and primates can be used for listed purposes with justification and permission. The draft is unclear on primates.
A lab doesn’t need walls
Places that are not wholly enclosed, and mobile facilities, count as labs.
Training is a reason to use animals
Higher education and professional training are listed purposes, and teaching approvals can last five years.
The pain scale decides who says yes
Every experiment would be labelled by how much pain it is expected to cause. The label decides whether anyone outside the lab reviews it.
Mild: approved by the lab’s committee. Examples in the draft: keeping sociable rats or mice alone for a short time; withholding food from adult rats for under 24 hours.
Moderate: approved by the lab’s committee. Examples: withholding food from adult rats for 48 hours; stimuli the animal cannot escape or avoid; inducing tumours.
Severe: CCSEA approval for animals larger than rodents and rabbits. Examples: toxicity tests where death is the endpoint; inescapable electric shock; long isolation of dogs and monkeys.
Non-recovery: CCSEA approval for animals larger than rodents and rabbits. Done fully under anaesthesia; the animal does not wake up.
The draft does not say who approves severe experiments on rats, mice or rabbits.
Today vs the draft
| Today | Draft 2026 | |
|---|---|---|
| Who approves | Lab committee for small animals; CCSEA for large animals (CPCSEA procedures) | Lab committee for mild and moderate experiments on every species |
| Where animals come from | Registered breeders; other legal sources only with written permission from a competent authority (2006 amendment) | Unregistered sources or the open market for some species, with the lab committee’s approval |
| Anaesthesia | Required for anything more severe than a simple injection (1998 Rules, Rule 9(d)) | No such rule |
| What counts as a lab | Animal house facility | Includes unenclosed and mobile facilities |
| How it’s judged | Size of the animal | Expected pain |
| Penalty in the Act | Up to ₹200 | Up to ₹200 (Act unchanged); the draft adds suspension or revocation of registration |
Read the 1998 Rules and their amendments · Read the Prevention of Cruelty to Animals Act, 1960
Send your objection
Choose your grounds, add your name and city, and send it from your own email. Letters with a name, a city and a line in your own words count as individual responses.
- Rule 11(3): Approval of mild and moderate experiments on every species should not rest with the establishment’s own committee alone. Rule 11(4) only makes that committee report to CCSEA, and a report is not an approval. Experiments on animals larger than rodents and rabbits should keep needing CCSEA approval, as CPCSEA’s procedures require today.
- Rule 21(2): Rule 21(2) would let establishments buy livestock, farm animals, fish and birds from unregistered sources or the open market with only their own committee’s approval. Today, any source other than a registered breeder needs written permission from a competent legal authority (2006 amendment). Open-market sourcing should be removed, and any other source should keep needing outside permission.
- Rule 5(3): Stray and feral animals should be excluded without exception. “Competent authority” is not defined anywhere in the draft.
- Rules 5(1)(c) and 6: Rule 5(1)(c) is unclear and appears to conflict with Rule 6(2) on non-human primates. Primates protected under the Wildlife (Protection) Act must be excluded without exception.
- Rule 2(i): An “establishment” should not include places that are not wholly enclosed, or mobile facilities, given the risks to biosafety and animal welfare.
- Annexure I: Withholding food, short-term solitary caging of sociable animals, and stimuli the animal cannot escape should not be classed as “mild” or “moderate”.
- Rule 11: The draft does not say who approves severe experiments on rodents and rabbits. This gap must be closed by requiring CCSEA approval.
- Rules 4(6) and 11(11): Animals should not be used for education and training where non-animal methods exist, and five-year teaching approvals should be removed.
- Rule 3: Replacement should be mandatory, not required only “wherever possible”, with a public list of validated non-animal methods that establishments must check before applying.
- Penalties: CCSEA should ask the Ministry to amend Section 20 of the Act, which still sets the fine at up to ₹200.
- Rule 15(1), rehabilitation: The draft leaves rehabilitation and reuse to future CCSEA guidelines. The 2006 amendment’s duty of aftercare and rehabilitation, with its cost built into research budgets, should be written into the rules.
- Anaesthesia: The draft drops Rule 9(d) of the 1998 Rules, which requires anaesthesia for any procedure more severe than a simple injection or superficial venesection. That duty should be restored.
- Reuse: The draft allows an animal to be reused (Rule 15(1), Annexure I). An animal that has been through a moderate or severe experiment should not be used again.
- Rule 5(3), strays in practice: In CPCSEA told labs that stray dogs may be used for new vaccine trials and challenge studies, and withdrew that only “till further orders” in . Rule 5(3)’s exemption would allow the same again, and should be deleted.
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Other ways to send
Copy and paste. Copy the letter and the address, and paste them into any email app.
By post. Member Secretary (CCSEA), Office of CCSEA, Near State Bank of India, Delhi Milk Scheme Complex, Shadipur, Delhi – 110008. Post it by 30 October so it arrives in time.
Write your own. Use your own words. Mention G.S.R. 864(E), the rule numbers, your name and city, and ask for an acknowledgment.
Questions
Are these rules already in force?
No. They take effect only after CCSEA considers objections and publishes final rules in the Gazette.
Who can send an objection?
Anyone. The notification invites objections and suggestions within thirty days.
Does one email matter?
Every objection received in the window must be considered before the rules are finalised. Individual letters with names and cities carry more weight than identical copies.
Does the draft ban any experiments?
It bars experiments that cause severe pain, suffering or distress that is likely to last long and cannot be relieved (Rule 7(2)). Other severe experiments are allowed with approval.
Can community dogs be used?
The draft says strays should not be used, but allows exemptions by “competent authorities”, a term it does not define (Rule 5(3)). In the regulator told labs stray dogs may be used for new vaccine trials; it withdrew that in “till further orders”.
Is Animal Writes against medical research?
We ask for the oversight that exists today to stay, for non-animal methods to come first, and for clear limits on where animals come from.
What happens after 5 November?
CCSEA reviews objections and may revise the draft before final notification. We will publish updates here.
Is my data stored?
The letter is sent from your own email. We store nothing unless you choose to join our updates.
Read the law
What happens next
- Objections close on .
- CCSEA reviews the objections and suggestions.
- Final rules, revised or not, are published in the Gazette.
- We follow every step here and in our newsletter.
Latest updates
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Colours from the explainer artwork by @p.s___withlove, used with her permission.
