In Pakistan, the practice of animal testing operates without a clear and comprehensive legal and institutional structure. Despite the significant use of animal testing in biomedical studies, pharmaceutical and veterinary research, vaccine development, toxicological research, and industrial testing, Pakistan has no comprehensive national framework specifically regulating the scientific use of animals. Factors such as the lack of reliable government statistics, the absence of a dedicated national authority responsible for regulating animal experimentation, the absence of reporting systems, and the lack of a specific regulatory body have made it difficult to assess how commonly animal experiments are carried out. Moreover, the absence of standards for reporting animal experiments raises a number of legal issues: without systematic records of animal experiments, it becomes difficult to challenge the manner in which these experiments are performed and whether they comply with the ethical standards of scientific research.
When compared with current international requirements, the shortcomings of Pakistan’s legal framework become apparent. In Pakistan, around 31 institutions of higher education offer studies in animal sciences, veterinary medicine, biomedical studies, and other related subjects. However, there are no clear legal requirements for these institutions to establish Institutional Animal Care and Use Committees (IACUCs), institutional ethics committees, or similar bodies with the authority to review animal studies and approve animal experiments. Furthermore, the laws of the country lack regulations requiring the application of the principles of Replacement, Reduction, and Refinement, endorsed internationally and used globally to replace animals with alternative methods where possible, reduce the number of animals to the minimum necessary, and refine procedures to minimize pain and suffering during experiments. The absence of relevant legal provisions makes it possible to conduct animal experiments without adequately assessing the necessity or proportionality of the experiments to be conducted.
Animal testing and research occurs in various types of institutes, veterinary and agricultural universities, medical schools, pharmacy schools, pharmaceutical companies, biomedical research laboratory facilities, industrial testing facilities, and specialist facilities that manufacture vaccines and anti-venoms. Veterinary universities, along with agricultural universities like the University of Veterinary and Animal Sciences (UVAS) and Pir Mehr Ali Shah Arid Agriculture University (PMAS-UAAR), as well as the agricultural and veterinary universities of Sindh and other parts of Pakistan, have been conducting experiments on animals in their studies and research programs for a long time. The issue became a matter of public concern in 2022 when footage emerged showing dogs being operated on in the veterinary institutions.
One of the most contentious forms of animal experimentation is live-animal surgery. Reports and activist campaigns have claimed that stray canines, and even some owned pets, were captured and subjected to surgeries for training purposes. The concerns did not end with the use of animals per se; there were also allegations of poor anesthesia, inadequate aftercare, and a complete lack of proper ethical supervision. While such claims need to be verified against the facts, their recurrence indicates a more sophisticated systemic issue: it is very difficult to differentiate between justified scientific or educational necessity and unnecessary animal experimentation or cruelty when institutions are not required to seek independent ethical approval, maintain publicly accessible records, or report the number of procedures they perform.
The pharmaceutical industry is another significant area of animal research. The purpose of preclinical research generally includes animal testing for a number of parameters, such as toxicity, pharmacodynamics, pharmacokinetics, biological effects, and the safety of pharmaceuticals prior to their introduction into clinical use. The regulatory requirements of the Drug Regulatory Authority of Pakistan (DRAP) contain requirements relating to preclinical investigations. However, the existence of regulatory requirements does not mean that there are comprehensive animal-welfare rules governing this area of activity. More specifically, there is no comprehensive system requiring researchers and manufacturers to demonstrate that animal use is unavoidable, that alternative techniques cannot reasonably be used, that the number of animals is scientifically justified, and that the procedures involved do not cause unnecessary or avoidable suffering to animals.
Animal experimentation is not limited to universities and hospitals but also occurs in commercial and industrial contexts. Animal testing is involved in the manufacture and testing of cosmetics, pesticides, toxic materials, and other industrial products. Animal welfare organizations have identified this area as raising significant ethical concerns, particularly in relation to toxicological testing. The 2022 restrictions imposed in the Islamabad Capital Territory are particularly noteworthy because they reportedly applied to veterinary colleges and industrial complexes as well as animal-testing facilities. Moreover, these restrictions indicate that animal experimentation was not limited to academic research but also played a role in commercial and industrial testing. On the other hand, the territorial nature of such restrictions is indicative of one of the main flaws of the current regulatory system in Pakistan: a measure effective in Islamabad does not ensure that animal experimentation is regulated or restricted uniformly across the country.
Another crucial aspect to consider in this field lies in biomedical research laboratories. The Dow Institute for Advanced Biomedical Research and Animal Research (DIABAR) has publicly announced facilities for in vivo testing, which can be applied to oncology studies, cardiology research, and diabetes treatment. This laboratory illustrates the existence of specialized infrastructure capable of conducting animal-based biomedical research in accordance with the needs of research organizations, governmental bodies, and companies. Animal studies are also associated with the development and production of vaccines such as anti-rabies vaccines and anti-venoms. These products can support various public-health goals that are especially relevant in countries where infectious diseases, rabies, and poisonous snakebites remain significant concerns. Nevertheless, the utility of these scientific goals should not exempt such activities from ethical and regulatory scrutiny.
There are other laws that create additional but incomplete legal connections. The Drugs Act 1976 and the rules and regulations enforced by DRAP help regulate the pharmaceutical industry, where data collected from animal studies before testing on humans may be used as evidence in the approval of drugs. However, these laws on their own do not create a comprehensive framework for animal welfare. Likewise, wildlife laws allow the possession or use of wild animals for scientific purposes subject to certain conditions, which means that scientific research is recognized as one of the permissible purposes, although these laws do not specify all the welfare requirements applicable to laboratory testing of animals. At the same time, provincial laws relating to livestock and poultry regulate only certain areas without creating a comprehensive system for animals used in laboratories.
Certain provisions could, nevertheless, provide alternative avenues for intervention. For example, Section 429 of the Pakistan Penal Code criminalizes certain acts involving the killing, poisoning, maiming, or rendering useless of animals where the statutory requirements are met. While these provisions have historically been understood through the lens of animals as property, their application may also be relevant in instances where experimental animals are intentionally harmed through unlawful or impermissible actions. One limitation of this approach is the antiquated nature of the provisions and their lack of specific focus on scientific experimentation. Hence, relying solely on these provisions would represent a weak substitute for dedicated legislation governing the use of animals in research.
More hopeful developments, however, have been witnessed through executive actions and judicial interpretations. In 2022, an executive action adopted in Islamabad restricted the use of live animals in veterinary schools and industrial centers, with penalties reportedly consisting of fines and imprisonment. Although important from a policy standpoint, the territorial limitations of the measure and its executive nature highlight the weaknesses of relying on administrative actions instead of comprehensive legislation.
In the absence of an effective system of inspections, transparent reporting, and accountability, announced restrictions will be difficult to enforce. The Khyber Pakhtunkhwa Animal Welfare Act 2024 represents a significant development in Pakistan’s legislative history. The Act adopts a more contemporary and welfare-oriented approach to the treatment of animals and provides a broader statutory framework for preventing unnecessary pain and suffering. Yet, even though its provisions lay the groundwork for a more developed understanding of animal welfare in provincial legislation, it would be an oversimplification to assume that legal reform alone translates into effective protection. The implementation of the Act, including the functioning of the welfare mechanisms provided for under the legislation, remains an important challenge.
The period since 2022 has demonstrated, in terms of animal protection, a gradual but fragmented movement towards stronger animal-welfare standards in Pakistan. The public outcry stemming from allegations of live-animal surgeries, new restrictions adopted in the Islamabad Capital Territory, advocacy for the use of simulation instead of animals, progressive judicial reasoning, and the introduction of the Khyber Pakhtunkhwa Animal Welfare Act 2024 have attracted greater public attention to animal welfare. Nevertheless, all these developments fall short of creating a coherent national framework for animal experimentation. The core issues concerning permissible procedures, scientific necessity, ethical approval, the availability of alternatives, the number of animals involved, humane procedures, inspections, record-keeping, and institutional accountability remain unresolved in Pakistan.
Several coordinated actions need to be taken at different levels of administration, institutions, and legislation to tackle the above-mentioned issues. The Higher Education Commission and other concerned regulators need to make it mandatory for institutions conducting research on animals to have their own ethics committees, obtain ethics clearance, and ensure transparency in documentation. The Drug Regulatory Authority of Pakistan should also include the principle of the Three Rs, which stands for Replacement, Reduction, and Refinement, in the guidelines for drug testing while introducing alternatives to animals and ensuring that animals are not subjected to pain or suffering.
Finally, Right to Information mechanisms should be utilized to gather information regarding the number of animals used, the types of animals employed, and the nature of the research conducted. In the long run, Pakistan should introduce national legislation aimed at laying down licensing rules, standards for ethical review, animal-welfare requirements, inspection and enforcement mechanisms, reporting obligations, and a national registry of animal experiments. The ultimate aim should not simply be to ban animal experimentation, but to ensure that it takes place in accordance with scientifically valid and legally enforceable principles.
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The views and opinions expressed in this article/paper are the author’s own and do not necessarily reflect the editorial position of Paradigm Shift.
Aiza Musaddiq is a lawyer. She can be reached at aizamusaddiq4@gmail.com.
