Are Animals Legal Persons, Property or Tool? A Jurisprudential Analysis

Abstract

The legal status of animals has long been a subject of debate in jurisprudence. Traditionally, animals have been classified as property or tools for human use, with laws primarily focusing on regulating their treatment rather than recognizing them as independent rights-holders. However, recent judicial decisions in countries such as India, Argentina, and New Zealand have challenged this notion by granting animals legal personhood or enhanced protections. These developments raise important questions about whether animals should be considered legal persons, mere property, or something in between.

This paper explores the concept of legal personhood in jurisprudence and examines how different countries approach the legal status of animals. It analyzes landmark cases such as Animal Welfare Board of India v. A. Nagaraj (2014), Karnail Singh v. State of Haryana (2019), and the Sandra Orangutan Case (Argentina, 2015), which have contributed to evolving perspectives on animal rights. Additionally, the paper discusses the Prevention of Cruelty to Animals Act, Hindu mythology, and the challenges associated with granting legal personality to animals, including jurisprudential, economic, and ethical considerations.

While full legal personhood for animals remains controversial, the paper argues that strengthening legal protections and moving beyond the strict property framework can provide a more balanced approach to animal rights. A comparative analysis of international laws and legal principles reveals the growing recognition of animals as more than mere property.

Keywords: Legal Personality, Animal Rights, Jurisprudence, Animal Welfare

Introduction

As per Prevention of Cruelty to Animals Act (“PCA Act”),[1] animal means any living creature other than a human being. The legal status of animals has been widely debated. Traditionally, animals have been treated as property or possessions, with laws focused on regulating human behavior rather than granting rights to animals themselves. However, changing societal values and growing concerns for animal welfare have led to discussions on whether animals should be recognized as legal persons rather than just property.

In jurisprudence, legal personhood is not limited to humans. Courts have granted personhood to corporations, rivers, and even religious deities in different legal systems. This raises an important question, if non-human entities can be legal persons, should animals also have similar recognition.

Different countries have taken various legal approaches toward animals. Some, like Argentina, India, and New Zealand, have moved toward granting certain animals legal rights, while others, such as the United States and the United Kingdom, continue to classify them as property with welfare protections. Landmark cases, including Animal Welfare Board of India v. A. Nagaraj,[2] Karnail Singh v. State of Haryana (2019), and the Sandra Orangutan Case,[3] show a shift toward recognizing animal rights.

Additionally, religious and cultural traditions in Hindu mythology, have long emphasized compassion and reverence toward animals, often depicting them as sacred beings. These perspectives provide additional moral and justifications for re-examining the legal framework governing animals.

Legal Person in Jurisprudence

Salmond defines a person as “any being whom the law regards as capable of rights and duties.”[4]

In layman’s terms, we can understand legal persons as those who have the capacity to sue and be sued, to own property, and to be a party to a contract. Chipman Gray says that legal personhood is simply whatever particular bundle of legal rights and duties lawmakers say we have.[5]

1. Theories of Personhood
2. Positivist

Positivists like John Austin says that personality exists only when law explicitly grants an entity with rights and duties. This would mean that animals are not persons since law has not granted them as such. However, this view relies on the position of law. The issue with this approach can be seen that it requires a statute. But the Judiciary in India can also form laws if gaps in previous ones exist.

Animals as Property

Common law and civil law traditions have generally two entities, either persons or things. It treats animals as things.[6] Roman law classified animals as res (things) that could be owned and traded. The view of animals as things can be further substantiated by the use of animals for experimentation, farming livestock, mass breeding, etc. This shows the economic valuation over ethical consideration.[7]

In case of Karnail Singh v. State of Haryana,[8] The Court opined, that “The entire animal kingdom, including avian and aquatic, are declared legal entities having a distinct persona with corresponding rights, duties and liabilities of a living person. All citizens throughout Haryana are hereby declared persons in loco parentis the human face for the welfare/protection of animals.” The judgement of this case also refrenced Narayana Dutt Bhaatta v. UOI[9] for the decision to recognize personality of idols and corporations.

Parens patriae

This doctrine of parens patriae has been cited multiple times by courts. Under this doctrine, state is the guardian of beings who cannot care for themselves like child.

In case of Animal Welfare Board of India v. UOI,[10] the court upheld the constitutionality validity of state amendments to PCA Act which allowed animal sports like Jallikattu, Kambala and bull-cart racing in various states.

Hindu Mythology

It must be noted that though in western world animals are chattel and property. The Hindu ancient texts have described the animals otherwise. In Durga Pustaka, animals have been described as sentient beings having conscience. It further states that humans and animals have same life and same wisdom. In simpler terms it means other than body, humans and animals are same.

Garur Puran, one of the Purans which is also read during the funeral states that just like how all karma/rituals have to be done on death of a human. The same should be done for an animals. In case of animal killing, it is necessary to hold the rituals similar to in case of humans.

Comparative Analysis of different Countries

A consistency can be seen in approach of various countries in determining legal status of animals. A shift is seen from traditional property based property based approach to a modern protection of welfare. To be exact, it the approach is a spectrum with extremes as property and welfare, and most countries in between near to either extreme. However even if some level of personhood has been granted to animals, it is by decision of courts, and no statute exists. And in jurisprudence, rights are only by statute, court decisions fall into gray area.

Traditional Property Model

United States

In the United States, animals are classified as property under the law. The Animal Welfare Act (1966) sets minimum standards for the care and treatment of animals in research, transport, but it does not grant them independent legal standing or personhood. The act is mostly barebones. Courts have consistently ruled against recognizing animals as legal persons, despite arguments made by animal rights organizations like the Nonhuman Rights Project (NhRP).

NhRP has filed various habeas corpus petition before the courts. In Matter of Tommy,[11] the NhRP filed habeas corpus petitions on behalf of a chimpanzee, arguing that he should be granted personhood due to his advanced cognitive abilities. However, the courts rejected the petition, stating that legal personhood applies only to entities capable of bearing legal duties and responsibilities. Similarly, in Matter of Happy the Elephant (2022),[12] the New York Court of Appeals ruled against granting legal personhood to an elephant, reaffirming that personhood is a status conferred by law and not based on intelligence or sentience alone. N Matter of NhRP v. Stanley, courts ruled that personality works in all or nothing fashion.

United Kingdom

The United Kingdom acknowledges the sentience of animals but continues to treat them as property under the law. The Animal Welfare Act (2006) establishes a legal duty of care towards animals and criminalizes cruelty. More recently, the Animal Welfare (Sentience) Act (2022) formally recognized animals as sentient beings capable of experiencing pain and emotions. However, it is just an extension to the above act.

Welfare Approach

Germany

Germany has taken significant strides in animal welfare by amending the Animal Welfare Act (2022) which banned male chick culling.[13]

The Court ruled against the mass killing of animals for economic convenience. This decision reinforced the importance of protecting animal welfare beyond purely economic considerations. However, despite such progressive rulings, legal personhood for animals has not been recognized, and they remain classified as a special category of property.

Argentina

Argentina has taken legal steps toward recognizing animal personhood. In a historic ruling, a Buenos Aires court in Sandra the Orangutan Case[14] declared an orangutan named Sandra a “non – human person” with the right to humane treatment. The court determined that Sandra, who had been kept in captivity at a zoo, possessed cognitive abilities and self – awareness that merited legal recognition. She was subsequently transferred to a sanctuary, marking a global precedent for the legal rights of non – human beings.

Following this, the Chimpanzee Cecilia Case[15] reinforced Argentina’s progressive stance. The court granted habeas corpus relief to Cecilia, ruling that she deserved appropriate living conditions in a sanctuary. These cases have positioned Argentina as a leader in the movement toward recognizing non – human personhood, but more of welfare approach.

Despite these judicial decisions, Argentina has not yet enacted legislative reforms to formally recognize animals as legal persons.

India

India has emerged as a global leader in animal rights, with courts taking a strong stance on recognizing animals’ legal protections. The Prevention of Cruelty to Animals Act criminalizes mistreatment, and constitutional provisions, particularly Article 51A(g),[16] impose a duty on citizens to protect animals. Indian courts have interpreted these laws broadly, moving towards granting animals legal rights.

One of the most significant rulings came in Animal Welfare Board of India v. A. Nagaraja (2014),[17] where the Supreme Court of India banned Jallikattu (bull-taming sport) and recognized that animals have rights to dignity and humane treatment. This case reinforced the idea that animals should not be subjected to unnecessary suffering for human entertainment.

In another groundbreaking decision, Karnail Singh v. State of Haryana (2019),[18] the Punjab & Haryana High Court declared that all animals are legal persons, invoking the parens patriae principle, which allows the state to act as a guardian for vulnerable beings. This ruling granted animals legal protections similar to those of human persons, making India one of the most progressive jurisdictions in the world for animal rights.

Despite these judicial advancements, India has yet to enact statutory reforms to codify animals legal personhood. However, the judiciary has set a strong precedent for future legal recognition.

Prevention of Cruelty to Animals Act

The Prevention of Cruelty to Animals Act, 1970 (PCA Act)[19] is a landmark Indian legislation aimed at protecting animals from unnecessary suffering and cruelty. At its core, the Act has a welfare approach rather than a rights approach, meaning that while it seeks to prevent cruelty, it does not grant animals legal rights or personhood. Instead, it regulates human behaviour towards animals, ensuring that they are not subjected to unnecessary harm. However, a jurisprudential analysis raises questions that it primarily serves to regulate and legalize the use of animals rather than protect their intrinsic rights.

One of the fundamental jurisprudential critiques of the PCA Act is that it prioritizes human interests over animal rights. This can be seen in provisions that allow for the killing of animals for food and religious purposes while criminalizing cruelty in selective circumstances. Section 11 of the PCA Act, which prohibits acts of cruelty such as beating, overloading, or torturing animals, also includes exceptions for the use of animals for food, breeding, killing stray dogs, etc. While the law acknowledges animal suffering, this raises an issue, it does not extend protection in cases where human interests are deemed more important.

From a jurisprudential standpoint, this law can be interpreted as a utilitarian compromise rather than a true commitment to animal rights. The utilitarian approach suggests that laws should seek the greatest happiness for the greatest number, which in this context means preventing unnecessary suffering while still permitting the use of animals for human consumption and use. However, it can be said that this is treating animals as commodities.

A critical perspective on the PCA Act is that it effectively legitimizes the killing of animals for consumption rather than abolishing cruelty altogether. In this view, the law functions more as a regulatory mechanism for the meat and dairy industry than as a protector of animal interests. Unlike some jurisdictions like Germany that have begun moving towards recognizing the legal rights of animals, Indian law under the PCA Act still permits the commodification of animal life, aligning more with economic and cultural practices than with a rights – based approach.

Despite this, Indian courts have interpreted the Act progressively in some instances. In Animal Welfare Board of India v. A. Nagaraja (2014), the Supreme Court held that animals have a right to dignity and freedom from unnecessary pain and suffering, effectively expanding the understanding of animal welfare beyond the PCA Act. Similarly, in Karnail Singh v. State of Haryana (2019),[20] the Punjab & Haryana High Court declared that animals are legal persons, indicating a shift from mere welfare considerations towards recognizing some elements of legal personhood. However, until the PCA Act is reformed to explicitly acknowledge animals as rights – bearing entities rather than as regulated property, it will continue to operate within the utilitarian and anthropocentric legal framework.

Arguments in Favor of Animals as Legal Persons

The argument for granting animals legal personhood is rooted in the idea that animals are sentient beings, possess intrinsic value and should not be treated merely as property or objects of human enjoyment. Legal personhood would provide animals with enforceable rights, allowing them to be recognized as individuals under the law rather than as commodities.

A. Expanding the Definition of Legal Personhood

Legal personhood is not limited to human beings. Throughout history, courts have granted legal personhood to corporations, rivers, forests, and even idols in religious contexts. In Shiromani Gurudwara Prabandhak Committee v. Som Nath Dass,[21] the Supreme Court of India reaffirmed that legal personhood is a construct of law, not biology. If non – living entities like corporations can be legal persons, then sentient beings with cognitive abilities, emotions, and social structures should also be eligible for legal recognition.

B. Doctrine of Parens Patriae and the State’s Duty Towards Animals

Under the parens patriae doctrine, the state has a duty to protect those who cannot protect themselves, such as minors, persons with disabilities, and, allegedly, animals. In Karnail Singh v. State of Haryana,[22] the Punjab & Haryana High Court explicitly applied this principle to animals, declaring them legal persons with rights. This ruling reflects an evolving legal perspective that recognizes animals as entities deserving of state protection beyond mere welfare considerations.[23]

C. Animal Sentience and Cognitive Abilities

Scientific research has established that many animals, particularly great apes, elephants, dolphins, and whales, possess self – awareness, problem – solving abilities, emotions, and even rudimentary forms of morality. The Cambridge Declaration on Consciousness (2012) affirmed that non – human animals possess the neurological substrates necessary for conscious experience. If the law grants rights and protections based on cognitive abilities and sentience, then there is a strong argument for extending personhood to highly intelligent animal species. Recent examples could be seen in case of Neura Link, the Elon Musk owned company testing brain implant on a monkey due to its high cognitive ability.

D. Precedents from International Jurisdictions

Several courts worldwide have begun recognizing non – human legal persons. In Sandra the Orangutan Case,[24] a Buenos Aires court ruled that an orangutan was a “non – human person” with the right to humane treatment. Similarly, in Chimpanzee Cecilia Case, a court granted habeas corpus relief to a chimpanzee, allowing her relocation to a sanctuary.

E. Moral and Ethical Considerations

The increasing animal rights movement worldwide have been demanding more rights and welfare for animals. It might seem like human compassionate. But the increasing awareness of people towards animals and environments can be a major factor.

F. Strengthening Legal Protections Against Exploitation

Granting animals legal personhood would provide them with enforceable legal rights, making it easier to prosecute acts of cruelty and prevent exploitation. Under current laws, animal cruelty is often punished with minimal fines or short prison sentences, reflecting the property – based status of animals. Recognizing them as legal persons would elevate their legal standing and ensure stronger protections against abuse, exploitation, and destruction of their natural habitats.

Challenges

Jurisprudential Challenges

a. The Traditional Concept of Legal Personhood

Legal personhood is a human – centric construct designed to govern rights and obligations within society. Traditionally, it has been granted to humans and artificial entities such as corporations, trusts, and religious institutions – all of which can bear rights and duties.

The main argument is that since animals lack the capacity to provide legal duties, they cannot be legal persons. However, this view is not the same for other entities. Courts have granted personhood to infants, comatose individuals, and those with severe cognitive impairments (disabilities), none of whom is able to bear legal obligations. This suggests that legal personhood does not necessarily require reciprocal obligations but can be based on moral and social and ethical considerations.

b. Anthropocentric Nature of Legal Systems

Most legal frameworks are anthropocentric, prioritizing human interests. In case of human – animal conflict, human always prevail. Because law is for human interests. Even laws protecting animals, such as the Prevention of Cruelty to Animals Act, 1970 function primarily as regulations on human behaviour rather than recognizing animals as rights – holders. Granting animals personhood would require a shift to an ecocentric legal model, which challenges previous social constructs.

c. Defining the Scope of Legal Personhood for Animals

A key issue is determining which animals qualify for legal personhood. Would it apply only to higher – order animals like primates, elephants, and dolphins, or extend to all sentient beings. This lack of clarity creates legal uncertainty. Moreover, courts have granted legal personhood to corporations in Salomon v. Salomon,[25] rivers (Ganges and Yamuna in India), and religious deities Shiromani Gurudwara Prabandhak Committee v. Som Nath Dass – but all these entities have human representatives acting on their behalf. In contrast, animals would require a unique legal framework for representation and enforcement of rights.[26]

Practical and Legal Enforcement Challenges

a. Representation and Legal Standing for Animals

If animals are granted legal personality, they will need guardians or representatives to act on their behalf. However, this raises concerns about conflicts of interest among animal rights organizations, governments, and private industries.

In Sandra the Orangutan Case, the court ruled that the orangutan was a non – human person with legal rights, but enforcement of these rights depended on human activists. Similarly, in habeas corpus cases for chimpanzees and elephants in the U.S., courts struggled to determine who should represent these animals and how their rights should be enforced.

b. Conflict with Property and Commercial Laws

Generally legal systems classify animals as property or chattel. Granting them legal personhood would invalidate existing property laws, disrupting agriculture, pharmaceuticals, research, and entertainment industries.

For example, in Karnail Singh v. State of Haryana (2019), the Punjab & Haryana High Court declared animals legal persons, but failed to clarify how this status would interact with livestock ownership laws. The ambiguity surrounding animal personhood and property rights creates difficulties in legal enforcement.

c. Issue of Precent for other entities

Critics argue that recognizing animals as legal persons could create a precedent for granting rights to other non – human entities, such as plants or entire ecosystems. While some legal systems (e.g., Ecuador and Bolivia) have granted rights to nature, practical enforcement remains uncertain. If animals receive legal personhood, how do courts determine liability in cases of animal behavior affecting humans. The absence of clear criteria complicates legal enforcement.

Economic and Social Challenges

a. Disruptions to Agriculture and Animal – Based Industries

Animal – based industries, including meat, dairy, pharmaceuticals, and cosmetics, operate on the premise that animals are economic resources. Recognizing animals as persons would make it legally questionable to raise, trade, or slaughter them, disrupting industries that employ millions of people. This could be a counterargument to Germany’s ban on male chick culling.

For instance, the Prevention of Cruelty to Animals Act regulates animal welfare but allows their use for food, labour, and scientific research. If animals were given rights similar to humans, these industries would face legal challenges, leading to economic issues.

b. Cultural and Religious Conflicts

In many cultures, animals hold religious and traditional significance. In India, cattle are considered sacred, while rituals such as Jallikattu (bull-taming sport in Tamil Nadu) have deep cultural roots. Granting animals legal personality leads to conflicts between animal rights activists and religious communities.

Similarly, in Western societies, practices like hunting, factory farming, and medical testing on animals are deeply ingrained.

Philosophical and Ethical Challenges

a. Rights–Based vs. Welfare–Based Approach

Most legal systems adopt a welfare–based approach to animal protection, which seeks to minimize suffering while permitting human use of animals. A rights–based approach, in contrast, would require recognizing animals as individuals with intrinsic value, prohibiting their exploitation altogether.

For instance, the Animal Welfare Act (U.S.) and the Prevention of Cruelty to Animals Act (India) regulate animal treatment but do not grant them independent legal standing. Transitioning from welfare to rights would overhaul the previous system.

b. Moral Responsibility and Legal Standing

If animals are granted legal personhood, what responsibilities do humans have toward them. Would this create an obligation to provide food, shelter, and healthcare to all animals, similar to human social welfare programs.

Additionally, how do courts address cases of animals harming humans. If an animal’s rights are violated, who would compensate or remedy the situation. These unresolved ethical and legal questions complicate the implementation of animal personhood.

Judicial Precedents and Evolving Legal Recognition

Despite these challenges, courts worldwide have made landmark rulings on animal personhood.

Argentina’s case of Sandra the Orangutan recognized an orangutan as a non-human person, ruling that she had rights to life and liberty. In New Zealand, the Whanganui River Case granted legal personhood to a river, setting a precedent for non–human legal entities.[27]

Literature Review

The Koko Dilemma: A Challenge to Legal Personality [28]

In this article, the author examines the legal status of animals, questioning whether they should be considered legal persons, property, or tools under jurisprudence. The paper explores historical and contemporary perspectives on legal personality and challenges the anthropocentric nature of legal systems that exclude animals from possessing legal rights.

The author frames her argument around Koko, the famous gorilla known for her ability to communicate through sign language and demonstrate complex emotional and cognitive behaviours. The author highlights the inconsistency in legal thought that denies animals legal personality despite evidence of their intelligence and sentience. The paper references bioethicist Peter Singer and other scholars who advocate for expanding the legal definition of personhood to include non–human entities.

The article traces the evolution of legal personality, emphasizing that the concept has historically been extended beyond humans to include corporations and other artificial legal entities. The author argues that nothing inherent in legal philosophy prevents the extension of legal personality to animals. She critiques the existing legal framework that categorizes animals as property, describing them as “sentimental property” due to their unique emotional and social significance to humans. However, current animal welfare laws, she contends, provide only limited protection, as they focus on preventing cruelty rather than recognizing animals as rights–bearing individuals.

The author also explores historical legal practices, such as medieval animal trials, where animals were sometimes treated as responsible entities. She contrasts this with modern laws, which do not attribute legal responsibilities or rights to animals, creating a legal paradox. The paper discusses Christopher Stone’s famous argument in Should Trees Have Standing?, which suggests that granting legal personality to entities like animals and nature would ensure their protection by allowing them legal representation and rights enforcement.

A major obstacle to this shift, the author acknowledges, is the societal and economic interests invested in maintaining animals as property, particularly in industries like agriculture and biomedical research. She suggests that legal reforms often lag behind ethical considerations, necessitating a gradual approach to recognizing animals as legal persons. The article further critiques the reliance on human – like cognitive abilities as a criterion for personhood, arguing that this standard excludes many humans with cognitive impairments, thereby weakening the rationale for denying animals legal recognition.

In conclusion, the author advocates for a redefinition of legal personhood that accommodates animals, allowing them to possess rights proportionate to their capacities. She suggests that assigning legal guardians to represent animals in court could serve as a practical means of implementing their legal personhood.

Conclusion

The legal status of animals remains an issue in jurisprudence. Traditionally classified as property or possessions, animals have been granted certain protections through welfare laws, but these laws primarily regulate human behavior rather than recognize animals as independent rights-holders. The debate over legal personhood for animals challenges long-established legal principles and raises significant philosophical, ethical, and practical concerns.

Judicial decisions in countries like India, Argentina, and New Zealand indicate a growing recognition of animal rights, with courts granting legal personhood to certain animals or ecosystems. Cases such as Animal Welfare Board of India v. A. Nagaraj (2014), Karnail Singh v. State of Haryana (2019), and the Sandra Orangutan Case (Argentina, 2015) reflect this shift. However, despite these advancements, most legal systems still consider animals property, balancing animal welfare with human economic and social interests.

Granting legal personhood to animals presents several challenges, including defining the scope of rights, ensuring legal representation, and addressing conflicts with property and industry laws. It also raises philosophical questions about whether legal personhood requires the ability to bear duties and responsibilities, a criterion animals do not fulfill.

While full legal personhood for animals may not yet be practical, strengthening animal welfare laws, recognizing their intrinsic value, and adopting a more compassionate legal framework can bridge the gap between property status and full legal recognition. A balanced approach, considering both legal and ethical obligations, will be crucial in shaping the future of animal rights and ensuring their protection within the legal system.

[1] The Prevention of Cruelty to Animals Act, 1970.

[2] Animal Welfare Board of India v Nagaraja and Ors 2014 (7) SCC 547.

[3] Cámara Nacional de Apelaciones en lo Criminal y Correccional, sala 6 [CNACCC] [National Court of Appeals in Criminal and Correctional Matters, Chamber 6], 18/12/2014, “Orangutana, Sandra / habeas corpus,” (68831/2014/CA1) (Arg.).

[4] Fitzgerald P.J., Salmond on Jurisprudence, (12th edn., 2016).

[5] John Chipman Gray, The Nature and Sources of the Law 12 (2d ed., Columbia U. Press 1921) (noting that an individual’s legal rights are those which society will enforce).

[6] Gary L. Francione, Animals as Property, 2 ANIMAL L. i (1996).

[7] Korsgaard, Christine M. “Personhood, Animals, and the Law.” Think: Philosophy for Everyone 12, Number 34, Summer 2013.

[8] Karnail Singh v. State of Haryana, 2019 SCC OnLine P&H 704.

[9] Naryana Dutt Bhatt v Union of India & Ors 2018 SCC OnLine Utt 645.

[10] Animal Welfare Board of India v. Union of India, 2023 SCC OnLine SC 661.

[11] Matter of Nonhuman Rights Project, Inc. on behalf of Tommy v. Patrick C. Lavery, 31 N.Y.3d 1054, 100 N.E.3d 846 (2018) (USA).

[12] Nonhuman Rights Project, Inc. v. Breheny, No. 52, 2022 WL 2122141 (USA).

[13] Germany bans male chick culling from 2022 – DW – 05/20/2021, dw.com, https://www.dw.com/en/germany-bans-male-chick-culling-from-2022/a-57603148 (last visited Feb 27, 2025).

[14] Cámara Nacional de Apelaciones en lo Criminal y Correccional, sala 6 [CNACCC] [National Court of Appeals in Criminal and Correctional Matters, Chamber 6], 18/12/2014, “Orangutana, Sandra / habeas corpus,” (68831/2014/CA1) (Arg.).

[15] Tercer Juzgado de Garantías, Poder Judicial Mendoza [PJ Mza] [Third Court of Guarantees, Judicial Branch of Mendoza], 2015, “Acción de hábeas corpus presentada por la Asociación de Funcionarios y Abogados por los Derechos de los Animales (AFADA) / hábeas corpus,” EXPTE. NRO. P-72.254/15.

[16] India Const. art. 51A cl. (g).

[17] Animal Welfare Board of India v Nagaraja and Ors 2014 (7) SCC 547.

[18] Karnail Singh v. State of Haryana, 2019 SCC OnLine P&H 704.

[19] The Prevention of Cruelty to Animals Act, 1970.

[20] Karnail Singh v. State of Haryana, 2019 SCC OnLine P&H 704.

[21] Shiromani Gurudwara Prabandak Committee, Amritsar v. Shri Somnath Dass, 2000 (4) SCC 146.

[22] Karnail Singh v. State of Haryana, 2019 SCC OnLine P&H 704.

[23] Saumya Giri, Case Analysis of Karnail Singh vs. State Of Haryana, 2 IJLSI 364 (2020), https://www.ijlsi.com/wp-content/uploads/Case-Analysis-of-Karnail-Singh-Vs.-State-Of-Haryana.pdf.

[24] Cámara Nacional de Apelaciones en lo Criminal y Correccional, sala 6 [CNACCC] [National Court of Appeals in Criminal and Correctional Matters, Chamber 6], 18/12/2014, “Orangutana, Sandra / habeas corpus,” (68831/2014/CA1) (Arg.).

[25] Salomon v Salomon & Co. Ltd. [1897] AC 22.

[26] Shiromani Gurudwara Prabandhak Committee v. Som Nath Dass, 2000 (4) SCC 146.

[27] Matthias Kramm, When a River Becomes a Person, 21 Journal of Human Development and Capabilities 307 (2020), https://www.tandfonline.com/doi/full/10.1080/19452829.2020.1801610 (last visited Feb 27, 2025).

[28] Jane Nosworthy, The Koko Dilemma - A Challenge to Legal Personality, 2 S. CROSS U. L. REV. 1 (1998).