'Animals have no voice, but we do': Ambika Shukla's fierce warning on India's proposed lab testing rules

Animal rights activist Ambika Shukla questions the reliability of animal testing, arguing that biological differences and distress can compromise research outcomes. In an interview with India TV, she also advocated alternatives such as AI, stem-cell research and computer simulations.

With the November 5 deadline approaching for public feedback on the Centre's proposed draft rules governing the use of animals in laboratories, animal welfare activist Ambika Shukla has raised serious concerns over the proposed changes, warning that they could weaken existing safeguards, compromise scientific research and expose animals to unnecessary suffering. In an interview with India TV, Shukla, an animal rights activist and animal welfare advocate associated with People for Animals, one of India's largest non-profit animal welfare organisations, argued that the proposed framework could take the country several steps backwards in regulating animal experimentation. She questioned provisions concerning the sourcing of laboratory animals, approval of experiments, inspection of facilities and classification of pain during testing.

During the interview, Shukla maintained that the existing regulatory framework, strengthened through the introduction of Good Laboratory Practices (GLP), has helped India establish credibility in scientific research. She cautioned that diluting these safeguards could have consequences extending beyond animal welfare, potentially affecting the reliability of research findings, public health and India's standing as a scientific destination. With the draft rules still at the proposal stage, she urged citizens, scientists and animal welfare organisations to submit their objections and suggestions to the government before November 5.

Why existing safeguards matter: From the 1997 committee to GLP standards

Explaining the background of laboratory animal regulations in India, Shukla said the Committee for the Purpose of Control and Supervision of Experiments on Animals (CPCSEA) was established in 1997 to oversee the use of animals in scientific experiments. She recalled that when laboratories at major medical and research institutions were examined during the initial years, investigators allegedly found animals being kept in extremely poor conditions.

"Some animals had reportedly been left in laboratories for years without being used in experiments, proper cleaning arrangements or adequate scientific supervision. The regulatory framework underwent an important transformation around 2000, when the committee was reconstituted and Good Laboratory Practices were introduced to improve the treatment of animals used in research. Under this system, experiments were subjected to scrutiny to determine whether they were necessary, whether similar research had already been conducted, how many animals were actually required and what scientific outcomes were expected," Shukla said.

She further argued that these checks helped establish a system of accountability and ensured that animal experimentation was not undertaken without examining its scientific necessity. Shukla also linked India's progress in scientific research and vaccine development, including its performance during the Covid-19 pandemic, to the importance of maintaining robust laboratory standards. Her central argument was that scientific progress should not come at the cost of weakening the regulatory mechanisms that ensure reliable research and humane treatment of animals.

'Any animal from anywhere': Why sourcing of laboratory animals is a major concern

One of Shukla's biggest objections concerns the proposed changes to the sourcing of animals for laboratory experiments. She explained that under the existing framework, animals used for experiments were generally required to be bred within registered laboratory facilities. This helped researchers maintain control over their health, medical history and other conditions that could influence experimental results.

However, she alleged that Rule 5 of the proposed draft could allow laboratories to procure animals from other sources when animals bred within their facilities were unavailable. Shukla questioned the lack of clarity over what constitutes an acceptable alternative source, arguing that the provision could potentially open the door to animals being picked up from streets, markets, private homes or even wildlife habitats.

She warned that the absence of clearly defined sourcing restrictions could put stray dogs, cats and other community animals at risk.

"If any animal can be sourced from anywhere, what stops someone from picking up an animal from the street or taking it from someone's home?" she raised the concern during the interview.

Shukla also questioned the scientific implications of such a provision. Animals sourced from uncontrolled environments could have pre-existing illnesses, infections or other health conditions that researchers may not be aware of. According to her, such variables could influence experimental outcomes and make it difficult to establish whether the results were genuinely attributable to the substance or procedure being tested.

WATCH THE FULL INTERVIEW HERE:

Institutional approval of experiments could weaken independent oversight

Another major concern raised by Shukla relates to the proposed changes in the approval mechanism for animal experiments. She argued that the existing regulatory framework provides for scrutiny by a central authority, which examines the necessity and scientific justification of experiments and determines the number of animals required.

However, she alleged that the proposed rules could give greater authority to individual institutions to approve their own experiments. Questioning the effectiveness of such an arrangement, Shukla said institutions may be reluctant to reject research proposals originating within their own establishments. She compared the arrangement to allowing students' parents to evaluate their examination papers, arguing that an independent assessment is necessary to ensure objectivity.

According to her, removing or weakening external scrutiny could result in unnecessary experiments, excessive use of animals and research being conducted without adequate checks. She also warned that when institutions are allowed to assess their own research proposals, the distinction between scientific necessity and institutional convenience could become blurred.

Open-air experiments and prior inspection could compromise research standards

Shukla also flagged concerns over provisions that, according to her interpretation, could dilute requirements relating to laboratory infrastructure and inspections. She questioned the possibility of experiments being conducted without adequately enclosed laboratory facilities, arguing that uncontrolled environmental conditions such as heat, rain, dust and other external factors could affect research outcomes.

She explained that reliable scientific research depends on the ability to reproduce an experiment under the same conditions and obtain consistent results. "If the environment is not controlled and the conditions keep changing, how will researchers replicate the experiment and establish that the results are reliable?" she asked. She further objected to the proposed requirement of prior intimation before laboratory inspections.

According to Shukla, surprise inspections are important because they allow authorities to examine the actual conditions in which animals are kept, and experiments are conducted. If laboratories receive advance notice of inspections, she argued, they could temporarily correct shortcomings or conceal violations before officials arrive. She described such inspections as ineffective if laboratories are given an opportunity to prepare for scrutiny.

Can pain, suffering and mental trauma be adequately classified?

Beyond the sourcing and monitoring of laboratory animals, Shukla raised concerns over the proposed classification of pain and suffering during experiments. She explained that the existing framework categorises animals according to their size, with different requirements applicable to small, medium and large animals. However, she alleged that the proposed framework shifts the classification towards the severity of pain, dividing experiments into categories such as mild pain, moderate pain, severe pain and death.

Questioning the practical application of these categories, she asked how the intensity of pain could be accurately determined in animals that cannot communicate their suffering. She particularly objected to the inclusion of conditions such as starvation and isolation under the mild category, arguing that both can cause significant physical and psychological distress.

"Animals experience fear, stress, pain, loneliness and trauma, just as humans do. Their heightened senses of smell and hearing can make unfamiliar laboratory environments particularly frightening. The suffering does not necessarily begin with an experiment. Animals can experience distress during transportation to laboratories and while being kept in unfamiliar surroundings," Shukla added.

According to her, some animals may stop eating because of fear and stress, while others may suffer from illness, starvation and trauma even before an experiment begins. She stressed that since animals cannot consent to experiments or communicate their suffering, the responsibility of ensuring their welfare rests entirely with the researchers and regulatory authorities.

Why animal testing may not always produce reliable results

Making a case against excessive dependence on animal experimentation, Shukla argued that the physiological differences between animals and humans can sometimes make animal testing misleading. She cited the example of penicillin, one of the earliest antibiotics, claiming that animal testing initially failed to reflect its usefulness in humans. She argued that relying exclusively on such results could have prevented the development of an important medicine. Shukla also referred to tobacco research, alleging that differences in how animals and humans respond to tobacco were exploited by the tobacco industry to delay warnings and restrictions.

According to her, experiments on monkeys were repeatedly used to challenge evidence linking tobacco consumption to lung cancer in humans, despite the growing scientific understanding of its harmful effects. She argued that animal testing cannot always provide an accurate picture of how a drug, chemical or product will affect the human body.

She maintained that continuing to rely on animal experiments simply because they have been a conventional method of research is no longer justified when alternative technologies are increasingly available.

AI, stem cells and computer models: What are the alternatives?

Shukla explained that scientific research has advanced significantly, making it possible to explore alternatives to animal experimentation. She specifically mentioned artificial intelligence, stem cell research and computer-simulated models as potential tools that can help researchers study biological processes and assess the effects of different substances. According to her, these approaches can save time, reduce unnecessary experimentation and potentially produce more relevant findings for human health.

She stressed that the objective should not be to conduct a greater number of experiments but to ensure that research is original, scientifically useful and capable of producing reliable results.

"Scientific progress does not mean more experimentation. It means better experimentation," she conveyed as the central message. However, Shukla clarified that she was not demanding an immediate and complete ban on all animal experimentation in India. Instead, she argued that the country should retain its existing safeguards while gradually exploring and adopting alternatives that can reduce dependence on animals.

Could India become a destination for cheaper and less-regulated animal testing?

During the interview, she also warned about the possibility of foreign companies using Indian laboratories to conduct experiments that may be difficult, expensive or restricted under regulations in their own countries. Shukla cautioned that weakening domestic safeguards could make India an attractive destination for companies looking for cheaper animal testing with less regulatory scrutiny. She described the possibility of India becoming the "dustbin of research", where foreign companies could use laboratories to complete testing requirements without necessarily undertaking meaningful scientific innovation.

The animal activist argued that companies could potentially use Indian laboratories to fulfil regulatory formalities at a lower cost while keeping their more advanced research activities elsewhere. She warned that such a development could damage India's reputation as a credible scientific research destination. She also questioned whether international companies and investors would continue to trust Indian research findings if laboratory standards and oversight mechanisms were weakened.

Shukla pointed out that India had already established itself as a major destination for scientific and pharmaceutical research. Diluting the regulatory framework, she said, could undermine years of progress.

Animal testing and India's reputation as a cruelty-free cosmetics market

Shukla also referred to India's existing restrictions on animal testing for cosmetics, arguing that the country had demonstrated that the cosmetics industry could grow without relying on animal experiments. She cited Indian brands, including Lakme, to make the point that the industry had continued to develop despite restrictions on cosmetic animal testing. She expressed concern that the proposed changes could create loopholes that might allow foreign companies to use Indian laboratories for testing that would otherwise face restrictions in their own markets.

She further argued that ethical considerations are increasingly influencing investment decisions, with shareholders and investors paying greater attention to the manner in which companies manufacture products and conduct research.

"The use of cruelty-free and ethical practices is no longer merely an animal welfare issue but is also becoming an important consideration in global business and investment," she added.

'Compassionate research is scientific research'

"On the other hand, maintaining clean laboratories, adequate ventilation, proper space and hygienic conditions can improve both animal welfare and the quality of scientific research," she said.

Shukla also said the consequences of unreliable research could ultimately affect the products and medicines used by ordinary people. "If we use distressed animals, we will get distressed results. Compassionate research is scientific research," she added.

Shukla also invoked Mahatma Gandhi's philosophy of non-violence, arguing that weakening animal welfare protections would contradict India's long-standing values of compassion and ahimsa (non-violence). She said India should focus on strengthening ethical scientific practices rather than creating an environment where animals can be subjected to unnecessary experiments.

Ambika Shukla urges citizens to submit objections before November 5

With the proposed rules still open for public consultation, Shukla appealed to citizens, scientists and animal welfare organisations to use the remaining time to communicate their concerns to the government. She emphasised that the draft has not yet become law and that public feedback could influence the final decision. According to her, the existing regulatory framework has already established a balance between scientific research and animal welfare, and there is no compelling reason to weaken it. She stated India should continue to improve its scientific capabilities while investing in alternatives to animal experimentation. "Animals have no voice. They have no choice. But we have," she said, urging people to raise their concerns before the November 5 deadline.