The Draft of the Administrative Instruction (AI) for Shelters is public and requires your comments!
AI for shelters is a sub-legal act which aims to regulate the conditions that shelters in Kosovo must meet in order to operate as shelters for dogs or cats.
This AI was initiated by the MAFRD in cooperation with KFVA within the framework of the EU project “Support to establishing disease surveillance and control programs and alignment with Chapter 12 of the acquis” and the experts of this project have proposed that the dogs with keepers/owners be euthanized after 30 days of being brought to the shelter, if the owner does not want the animal (dog or cat) and if the animal’s welfare is compromised if it were to be kept for a long time in the shelter. You can find this part in article 23, paragraph 4.
Our organization agrees to make an ethical commission so that in some cases and for some shelters where dogs or animals live in extremely bad conditions (which would result in chronic or repeated disease or the death of the animals) the measure of euthanasia is foreseen, since even international laws propose it so that there is no risk of killing animals with other insidious or institutional methods (in public shelters) and to free the animals from any cruel or suffering life, but the working group of the MAFRD and KFVA have not accepted our extremely professional, efficient and humane comments for dealing with this issue, and has decided to keep paragraph 4 as published.
Our organization was also a part of the Working Group and we have studied all the drafts and comments and consulted with other world organizations working in this field, and have sent proposals not only once, but dozens of times to the officials of the institutions mentioned above regarding Article 23. To tell the truth, Article 23 was even worse in the beginning, but anyway, the MAFRD has accepted some of our comments and remarks.
Paragraph 4 of Article 23 will be applied to all dogs whose ownership is proven, and we all know that in Kosovo every dog that is abandoned once had a keeper/owner.
Our organization has also engaged some lawyers to make a legal analysis of whether euthanasia is allowed as described in paragraph 4 of Article 23 and according to the findings, paragraph 4 of Article 23 is not in accordance with the Law on Animal Welfare, since according to this law, euthanasia is allowed only for aggressive and sick animals that would result in their death.
We request that euthanasia be done only with the permission of an ethical commission from the relevant institutions that includes civil society or other scientific and professional entities such as the Institute of Veterinary Medicine within the Faculty of Agriculture and Veterinary Medicine to avoid the misuse of euthanasia by municipalities and private shelters in the future.
We as an organization witness how stray animals are treated in the CNVR projects in different municipalities and we are sure that public shelters will end up in the systematic euthanasia of street dogs.
Legal analysis for animal euthanasia: https://bit.ly/3gBvhKM
You can find our proposals as an organization for Article 23 in this link: https://bit.ly/3h8gx6p
AI link for commenting: https://bit.ly/3eVQ239
The consultation period is open from October 20 – November 9, 2022, 4:00 p.m. You should send your comments to the following email addresses: isuf.cikaqi@rks-gov.net, isah.rudaku@rks-gov.net; arsim.memaj@rks-gov.net ; sadik.heta@rks-gov.net ; berat.hoxha@rks-gov.net.