RAW EGGS AS A SOURCE OF PROTEIN IN YOUR DOGS DIET

     Myths and folklore abound when it comes to including eggs in the general diet of dogs. The egg is too often regarded as a dangerous food for dogs. Opponents of feeding eggs claim that they are too high in cholesterol, they pose a risk of salmonella and that they cause a biotin deficiency. While this may be true for humans, eggs pose no such risk for a healthy dog. People generally tend to think that what is good or bad for them nutritionally also holds true for dogs, this line of thought is completely false. Dogs are not like people when it comes to nutritional needs, people are omnivores, we need a mixed diet of starches, greens and proteins both from plant and animal; while dogs are carnivores, they have evolved to live on a diet of meat, fat and bone, with little to no vegetable matter.       Here are the facts you need to know about eggs.Eggs are a complete food for dogs – Eggs are an important source of nutrition for many predators. Inside the egg are all the vitamins and nutrients needed for the growth of the chicken embryo that it holds. Eggs are also one of the most complete sources of amino acids, these are the building blocks of protein. Eggs are an excellent source of: Vitamin A, Riboflavin, Folate, Vitamin B12, Iron, Selenium, Fatty Acids and including the shell, calcium.
Enzyme inhibitors – One of the reasons that dog owners are told not to use eggs is that the whites contain enzyme inhibitors which interfere with digestion, especially in very young and old animals. While this is true, it only means that dogs should not be fed solely or even mainly on raw eggs. It is perfectly safe to feed raw eggs several times a week to the average dog. If there is no evidence of digestive upset when feeding eggs to your dog, then he should have no trouble if eggs are a regular part of his diet. However this problem may be overcome by cooking the egg white but much of the natural vitamin content would be lost so it is always best to feed eggs raw.
Egg whites destroy Biotin in the dogs’ gut – Egg whites contain a protein called Avidin, this is a Biotin (one of the B vitamins) inhibitor. (Functional Avidin is found only in raw egg, as the biotin avidity of the protein is destroyed by cooking. The natural function of Avidin in eggs is not known, although it has been postulated to be made in the oviduct as a bacterial growth-inhibitor, by binding biotin the bacteria need. As evidence for this, streptavidin, a loosely related protein with equal biotin affinity and a very similar binding site, is made by certain strains of Streptomyces bacteria, and is thought to serve to inhibit the growth of competing bacteria, in the manner of an antibiotic. The thermal stability and biotin binding activity of avidin are of both practical and theoretical interest to researchers, as avidin's stability is unusually high and avidin is an antinutrient in human food. A 1966 study published in Biochemical and Biophysical Research Communications found that the structure of avidin remains stable at temperatures below 70 °C (158 °F). Above 70 °C (158 °F), avidin's structure is rapidly disrupted and by 85 °C (185 °F), extensive loss of structure and ability to bind biotin is found. A 1991 assay for the Journal of Food Science detected substantial Avidin activity in cooked egg white: "mean residual Avidin activity in fried, poached and boiled (2 min) egg white was 33%, 71% and 40% of the activity in raw egg white."
 The assay surmised that cooking times were not sufficient to adequately heat all cold spot areas within the egg white. Complete inactivation of Avidin's biotin binding capacity required boiling for over 4 minutes. extracted from Wikipedia.) Biotin is one of the group B vitamins and is important for cellular growth, fatty acid metabolism and good skin and coat. Deficiencies of this vitamin are rare and it would take an extraordinarily large amount of eggs to create such a deficiency, especially in a dog. Now when you take into account that egg yolks are very high in biotin, it becomes evident that as long as you feed the whole eggs (white & yolk), there should be no problems. Remember, cooking the egg white will denature or inactivate the Avidin thus eliminating the risk of Biotin deficiency but this will also destroy much of the vitamin content of the egg. Feeding your dog whole raw eggs will overcome the problem of active Avidin, so if you decide to use raw eggs on a regular basis and as a large part of your dog’s diet, use whole eggs.Egg yolks are high in cholesterol. I can’t tell you how many times I heard people say they remove the skin from chicken before they cook it for their dogs or discard the egg yolk because they are high in cholesterol so obviously bad for dogs. Total and complete hogwash, a dog is a carnivore it is naturally able to take in high levels of animal fats and cholesterol in its diet as a general rule. The only exceptions to a dogs’ ability to cope with high levels of cholesterol might be in instances of breed specificity and chronic long term inactivity. A healthy, normal and active dog not only can tolerate high levels of cholesterol that would probably kill most of us but they most likely need it for optimum health, remember they a carnivores and have evolved to live and thrive on such a diet. Eggs contain salmonella – Dogs are well equipped to handle the bacteria in raw foods, all wild and feral canids eat raw meat both fresh and putrid. The health of the hen and the freshness and proper storage of the egg is also important, so it is always best to choose eggs from organic, free-range chickens. Proper storage, keeping the eggs cool and using them within fourteen days of being laid will also go a long way toward keeping the harmful bacteria well within the tolerable level of the vast majority of dogs.Shells a valuable source of calcium – Don’t throw the shells away, if you give them to your dog along with the contents ie. whites and yolks, eggs then become a nearly complete food source for dogs, lacking only in fiber and bulk. Dry the shells out and grind them in a clean coffee mill until they are powdered and sprinkle the powder on your dog’s food, this is a very well digested source of calcium.
The only drawback I can see to using eggs as a major source of protein in your dogs diet is their cost. If one has to buy eggs then it becomes economically unfeasible if you own a large number of dogs.  If you have access to sufficient land to raise your own free range layers and grow their food then your problems visa vie the cost is solved.                                                                                                                                                                                                                                                                                                         Article first published in Caiere Chase (print magazine) vol 2 # 2 August 2013.

BUDDIE GORDON MILLER CONFEDERATION OF HUNTERS ASSOCIATION FOR CONSERVATION TRINIDAD AND TOBAGO vs THE HONOURABLE SENATOR GANGA SINGH, THE MINISTER OF THE ENVIRONMENT AND WATER RESOURCES JOHNNY SEEPERSAD, THE CHIEF GAME WARDEN (2014) JUDICIAL REVIEW CONCLUSION

http://webopac.ttlawcourts.org/LibraryJud/Judgments/HC/charles/2013/cv_13_04146DD20mar2014.pdf

REPUBLIC OF TRINIDAD AND TOBAGO 

IN THE HIGH COURT OF JUSTICE 

CV2013-04146 

IN THE MATTER OF AN APPLICATION BY BUDDIE GORDON MILLER AND THE 

CONFEDERATION OF HUNTERS ASSOCIATIONS FOR CONSERVATION TRINIDAD 

AND TOBAGO FOR LEAVE TO APPLY FOR JUDICIAL REVIEW PURSUANT TO 

SECTION 5 OF THE JUDICIAL REVIEW ACT, CHAP. 7:08 OF THE LAWS OF TRINIDAD 

AND TOBAGO AND PART 56.3 OF THE CIVIL PROCEEDINGS RULES 1998 

AND 

IN THE MATTER OF A DECISION DATED THE 25TH SEPTEMBER 2013 BY THE 

MINISTER OF THE ENVIRONMENT AND WATER RESOURCES TO AMEND PARTS I, II 

AND III OF THE SECOND SCHEDULE OF THE CONSERVATION OF WILD LIFE ACT, 

CHAP. 67:01 OF THE LAWS OF TRINIDAD AND TOBAGO BY DELETING ALL OF THE 

ANIMALS AND BIRDS PREVIOUSLY LISTED THEREIN 

BETWEEN 

BUDDIE GORDON MILLER 

CONFEDERATION OF HUNTERS ASSOCIATION 

FOR CONSERVATION TRINIDAD AND TOBAGO 

APPLICANTS/ INTENDED CLAIMANTS 

AND 

THE HONOURABLE SENATOR GANGA SINGH, THE MINISTER OF THE 

ENVIRONMENT AND WATER RESOURCES 

JOHNNY SEEPERSAD, THE CHIEF GAME WARDEN 

RESPONDENTS/ INTENDED DEFENDANTS 

BEFORE THE HON. MADAME JUSTICE JOAN CHARLES 

Appearances: 

For the Claimant: Mr. N. Samnadda-Ramrekersingh, instructed by Mr. L. Murphy 

and Ms. M. Clerk 

For the Defendant: Mr. R. Martineau S.C., instructed by Mr. C. Moore, Mr. G. Ramdeen 

 And Ms. M. Benjamin 

Date of Delivery: 20th March, 2014 

DECISION

APPLICATION

[1] By Application filed on the 18th October, 2013, the Applicants applied to
the Court for the following:

i. An Order pursuant to SECTION 6 of the JUDICIAL REVIEW
ACT, CHAP. 7:08 and PART 56.3 of the CIVIL PROCEEDINGS
RULES 1998 (“CPR”) for Leave to apply for Judicial Review of
the decision of the First-named Applicant (“the Minister”) dated
the 25th September, 2013 to amend Parts I, II and III of the Second
Schedule of the CONSERVATION OF WILD LIFE ACT, CHAP.
67:01 (“the Act”) by deleting animals and birds listed therein;
ii. An Order pursuant to SECTION 6 of the JUDICIAL REVIEW
ACT and PART 56.3 of the CPR for Leave to apply for Judicial
Review of the decision of the Minister to destroy the hunters’
camps throughout Trinidad and Tobago.

[2] The Applicants are seeking the following reliefs:

i. A Declaration that the decision of the Minister dated the 25th
September to amend PARTS I, II and III of the SECOND
SCHEDULE of the Act by deleting all of the animals and birds
previously listed therein is irrational, unreasonable and unlawful,
having been arrived at in circumstances which were procedurally
unfair and/or in breach of the rules of Natural Justice;
ii. An Order of certiorari to remove into the High Court and quash
the decision of the Minister dated the 25th September, 2013 to amend PARTS I, II and III of the SECOND SCHEDULE of the
Act by deleting all of the animals and the birds previously listed
therein;
iii. A Declaration that the decision of the Minister to destroy the
hunters’ camps throughout Trinidad and Tobago is unlawful
and/or illegal; and,
iv. Damages.

[3] The grounds upon which the foregoing reliefs are being sought, are as
follows:
i. The said decision by the Minister is unlawful, illegal, irrational
for the following reasons:
a. The hunting of wild life in Trinidad and Tobago has been a
settled practice for over sixty (60) years;
b. As a settled practice, the Minister and the members of the
Associations, comprising the Second-named Claimant, had
a legitimate expectation of the benefit of hunting wild life
in Trinidad and Tobago in the manner prescribed by the
Act;
c. The First-named Claimant and the members of the
Associations, comprising the Second-named Claimant, had
a legitimate expectation that their right to hunt would be
unjustifiably interfered with by the Respondents without
proper consultation between the parties or alternatively
that they had a legitimate expectation that they would

have consulted. 

ii. The said decision by the Minister is unlawful, illegal, irrational 

and unreasonable having been arrived at in circumstances which 

were procedurally unfair and/or in breach of the Rules of 

Natural Justice for the following reasons: 

a. The Minister did not first consult the Applicants of the 

basis upon which the said decision would be made such 

that would permit them to prepare complete and informed 

response to the proposed initiatives being considered. The 

decision was therefore made without the relevant 

considerations and enquiry; 

b. The Applicants had a legitimate expectation that they 

would have been consulted prior to the hunting 

moratorium being imposed by the Minister. It is the duty 

of the Minister to act fairly to those affected by the decision 

by giving those persons an opportunity to be heard and to 

state their reasons for objecting to the decision; 

c. The Minister did not adequately address his mind to any 

representations made by the Claimant and/or the effect 

that the said decision would have had on them; 

d. The Minister in all circumstances did not at any relevant 

time adequately consult the Applicants prior to making the 

said decision; 

e. The Minister did not consult with the Wild Life 

Conservation Committee, a statutory body, who pursuant 

to SECTION 8 of the Act “shall act in an advisory capacity 

to the Minister on all matters pertaining to the 

conservation of wild life in Trinidad and Tobago”. 

iii. The said decision by the Minister is irrational and/or 

unreasonable for the following reasons: 

a. The Minister did not consider relevant and current hunting 

reports prior to making the said decision which could have 

affected the overall fairness of the said decision; 

b. The Minister utilised sub-optimal and dated data in 

making the said decision; 

c. The Minister made the said decision in circumstances 

which did not consider the interest and/or direct adverse 

effects that the said decision would have on the Claimant. 

iv. In all the circumstances, the Minister by making the said decision 

has ensured that the Applicants have been deprived of their 

entitlement and their legitimate expectation to obtain a licence to 

hunt whether as sport or as a means of sustaining a livelihood, 

based on erroneous and antiquated data and without giving the 

Claimant a proper opportunity to address any concerns it might 

have had in relation to the same. 

BACKGROUND 

[4] Pursuant to SECTION 6 of the Act the Second-named Respondent (“the 

Chief Game Warden”) is authorised to grant a licence in the prescribed 

form to a person to hunt or be a member of a party engaged in hunting any 

animal specified in the SECOND SCHEDULE of the Act for a period as 

specified therein. 

Further, SECTION 6 of the Act provides that no person other than the 

holder of a licence may hunt any animal listed in the SECOND 

SCHEDULE of the Act; permit any dog to enter upon lands belonging to 

the State; or carry any gun or other weapon or device capable of being 

used to hunt such animals within State lands. It is an offence under the Act 

for any unlicenced person to do such acts. 

Pursuant to the FIFTH SCHEDULE of the ACT, the “closed season” in 

respect of hunting of all wild life is defined as the period from the 1st

 April 

to the 30th September in any given year. 

[5] Prior to the 25th September, 2013, a licence was granted annually in respect 

of the ‘Open Season’ to any person who presented themselves to the Office 

of the Chief Game Warden and paid the prescribed licence fee of twenty 

dollars ($20.00) per licence pursuant to REGULATION 3 of the 

CONSERVATION OF WILD LIFE REGULATIONS. 

[6] The Minister, upon request by the Applicants, convened a meeting with 

them on the 7th August, 2013. The purpose of the meeting was for the 

Applicants to seek clarification from the Minister as to the “Statements made 

on National Television by Ms. Ramona Ramdial, Junior Minister in the Ministry 

of Environment and Water Resources on the 8th July, 2013 that the hunting 

season due to open on the 1st

 of October 2013 would not be reopened for a period of 

2 to 3 years” and the proposed destruction of the hunters’ camps. 

[7] The Applicants contended that during the course of the meeting the 

Minister represented to them that a decision in relation to the imposition of 

the two-year hunting moratorium had not yet been made. Further, in 

relation to the proposed destruction of the hunters’ camps, the Minister 

initially stated that the reports in relation to this were false but eventually 

stated that the hunters’ camps could only be sustained on a temporary 

basis. The Applicants submitted two research papers entitled the “Value of 

Hunting Camps” and the “Economics of hunting to rural communities” tot 

the Minister for his consideration with a view to further discussions on the 

matter. 

[8] On the 15th August, 2013, the First-named Applicant wrote to the Minister 

in an attempt to secure a second urgent meeting to discuss in further detail 

the proposed initiatives that were addressed in the previous meeting. 

There was no response to this letter. 

[9] An open letter was written to the Minister on the 12th September, 2013 by 

the First-named Applicant, which was also sent to each Member of the 

House of Representatives and the Senate. The said letter outlined the 

position of the Applicants in relation to the proposed hunting moratorium, 

the proposed importation of wild meat into the Country, the promotion of 

wild life farming and the destruction of hunters’ camps location within the 

game sanctuaries. 

[10] However, on the 15th September, 2013 the Minister during the course of a 

post Cabinet Conference made a statement titled “Regarding the 

Protection of Wild Life Resources” wherein he announced that the 

Government was considering the imposition of a hunting moratorium as 

part of “a series of landmark [sic] aimed at protecting the wildlife resources 

of Trinidad and Tobago”. 

[11] The Minister stated, inter alia, that the hunting moratorium which was 

being considered for current imposition was based on the following: 

i. Data analysis conducted by the University of the West Indies and 

the University of Wisconsin of the Mandatory Hunting Return 

Data Return Forms for the period 1990 to 1993 which revealed 

that “the catching-hunting effort relationships of the agouti, 

lappe, red brocket deer, quenk and tattoo had a consistent 

negative relationship, suggesting the populations of these 

animals were being over-exploited ... The University scientists 

also concluded that such sustained rates of decline would lead to 

local extinction of these populations within 25 years”. 

ii. A subsequent survey by the University Researchers of the 

Mandatory Return Data Forms up to 2005 produced a brief 

report to the Conservator of Forests which “advised that there 

continued to be a decline in hunter catch per unit efforts 

indicators for the game species”. 

iii. A survey of the Central Range Wildlife Sanctuary in 2007 

commissioned by the Wild Life Conservation Committee in 2007. 

iv. The Forestry Division “has indicated that there has been a steady 

increase in annual hunting permits sales ... during 2010/2011 

period 22,465 State Game Licences were sold in 2011/2012 – 

18,990 were sold and in 2012/2013 – 21, 236 were sold”. 

[12] According to SECTION 24 of the Act, the Minister may by Regulation, 

inter alia, alter and amend the SECOND or THIRD SCHEDULE “by 

adding thereto, or removing therefrom, the name of any animal and may 

apply any such alteration to the whole of Trinidad and Tobago or confine 

it to any district or other area thereof. 

[13] By Legal Notice No. 206, dated the 25th September, 2013, cited as the 

CONSERVATION OF WILD LIFE (AMENDMENT) REGULATION 

2013, the Minister pursuant to SECTION 24 of the Act amended PARTS I, 

II and III of the Act by deleting the animals and bird listed therein. The 

practical effect of this decision was to classify all of the animals previously 

listed in PART I, II and III as “protected animals”. Protected animals 

according to SECTION 10 of the Act cannot be hunted except under a 

Special Game Licence granted by the Chief Game Warden for “scientific 

research, collection of specimens for zoological gardens, museums and 

similar institutions” and “the eradication of animals declared to be vermin 

by section 11”. 

[14] In addition, the Minister amended REGULATION 8 of the 

CONSERVATION OF WILD LIFE REGULATIONS of the Act by 

“inserting after subregulation (3), the following subregulation: 

4. The power of the Chief Game Warden to authorise hunting under 

subregulation (1) is hereby suspended”. 

[15] By letter dated the 10th October, Counsel for the Applicants wrote to the 

Minister setting out, inter alia, the proposed claim against the Respondents 

and requested that the information upon which the Minister arrived at his 

decision be provided. The Minister did not acknowledge or respond to this 

letter. 

ANALYSIS 

[16] The test to be applied by the Court on an Application for Leave for Judicial 

Review is whether there is an arguable ground for review which has a 

realistic prospect of success1. In Sharma v Brown-Antoine2, Lord Bingham 

of Cornwall opined: 

“The ordinary rule now is that the court will refuse leave to claim judicial 

review unless satisfied that there is an arguable ground for judicial review 

having a realistic prospect of success and not subject to a discretionary bar 

such as delay or an alternative remedy ... But arguability cannot be judged 

without reference to the nature and gravity of the issue to be argued. It is a 

test which is flexible in its application ... It is not enough that a case is 

potentially arguable: an Intended Claimant cannot plead potential 

arguability to ‘justify the grant of leave to issue proceedings upon a 

speculative basis which it is hoped the interlocutory processes of the court 

may strengthen’: Matalulu v Director of Public Prosecutions [2003] 4 LRC 

712 at 733.” 

[17] The essence of the Applicants’ case is that: 

i. They had a legitimate expectation that they would be able to 

continue to enjoy the benefit of hunting wild life in accordance 

with the Act; 

ii. They, being a group that would be adversely affected by the 

Legal Notice, had a legitimate expectation that their right to hunt 

or the practice of hunting would not be unjustifiably interfered 

with without proper and/or adequate consultation; 

iii. They had a legitimate expectation that they would have been 

consulted with and/or adequately consulted prior to the making 

of the Minister’s decision. 

CONSULTATION 

[18] The Respondents contend that there was adequate consultation with the 

Applicants before the decision made by the Minister. They stated that there 

was public consultation, acknowledged by the Applicants in their 

Affidavit filed on the 18th October, 2013, in addition to a request by the 

Applicants for comments and the submission of reports on the matter. It 

was further submitted by the Respondents that the fact that no decision 

was yet made was no reason for fairness to require more than was done. 

Good public administration requires not only finality but also that matters 

be dealt with at a reasonable speed: R v Monopolies and Merger 

Commission ex parte Argyll Group PLC3. 

[19] It could be said to be best practice, in modern thinking, that before an 

administrative decision is made there should consultation in some form, 

with those who will clearly be adversely affected by the decision. But 

Judicial Review is not granted for a mere failure to follow best practice. It 

has to be shown that the failure to consult amounts to a failure by the local 

authority to discharge its admitted duty to act fairly. The Minister is a 

person having legal authority to determine a question affecting the rights 

of individuals. This being so, it is a necessary implication that he is 

required to observe the principles of Natural Justice when exercising that 

authority.4 

[20] In R v North and East Devon Health Authority ex parte Coughlan5, Lord 

Woolf M.R. discussed the importance of consultation and opined: 

“... whether or not consultation of interested parties and the public is a 

legal requirement if it is embarked upon it must be carried out properly. To 

be proper, consultation must be undertaken at a time when proposals are 

still at a formative stage; it must include sufficient reasons for particular 

proposals to allow those consulted to give intelligent consideration and an 

intelligent response; adequate time must be given for this purpose; and the 

product of consultation must be conscientiously taken into account when 

the ultimate decision is taken.” 

Legal standards require that a consultation exercise (1) be conducted at a 

time when proposals are at a sufficiently formative stage, (2) with 

adequate information and time to allow a proper and informed response, 

and (3) leading to a conscientious and open-minded consideration of 

relevant matters.6 

[21] From the evidence before me, it is clear that the Respondents embarked 

upon consultation with the Applicants and having proceeded to do so, 

such consultation should have been conducted properly and adequately. 

This duty to consult is not confined to a singular meeting or discussion but 

rather than which fully ventilates the matter(s) at hand. It is not disputed 

that the Respondents convened a meeting with the Applicants to discuss 

the proposed moratorium. Subsequent to this meeting, the Applicants tried 

to no avail to seek audience with the Minister to discuss further issues 

regarding the (then) proposed moratorium. This, in my view, is inadequate 

consultation. There were clearly other issues that needed to be discussed 

and/or resolved between the parties which were not adequately addressed 

and ventilated. 

LEGITIMATE EXPECTATION 

[22] The Respondents submitted that the Applicants did not have any 

legitimate expectation. The fact that they were told on the 7th August, 2013 

that the decision to impose a two-year moratorium was not yet made did 

not mean the Minister would not take the decision without further 

consultation. Rather, it could be a “hope” and not a legitimate expectation 

on the part of the Minister that he would not have done so. 

[23] Legitimate expectation is defined as an expectation which, although not 

amounting to an enforceable right, is founded on a reasonable assumption 

which is capable of being protected in public law. It enables a citizen to 

challenge a decision which deprives him of an expectation founded on a 

reasonable basis that his claim would be dealt with in a particular way.7 

[24] The terms of the representation by the decision-maker (whether express or 

implied from past practice) must entitle the party to whom it is addressed 

to expect, legitimately, one of two things: 

i. That a hearing or other appropriate procedures will be afforded 

before the decision is made, or 

ii. That a benefit of a substantive nature will be granted or, if the 

person is already in receipt of the benefit, that it will be continued 

and not be substantially varied.8 

[25] It is well-known that the practice of hunting has existed for centuries as a 

means through which persons provide for themselves and their families. 

This practice also pre-dates the Act and its commencement. Therefore, the 

Applicants had a legitimate expectation, through practice, that should 

there be a ban on hunting, even on a temporary basis, they would be 

properly consulted and their opinions taken into consideration given the 

fact that many of them depend on hunting animals as a means of living 

and providing for their families. 

[26] Based on the evidence before me, the Applicants were not given an 

adequate opportunity to put forward their views and/or objections on the 

matter. Several requests were made to contact the Minister both prior to 

and after his decision to place a moratorium on hunting but no response 

was given by the Minister. Nor was there any other meeting with the 

Applicants after that of the 7th August, 2013 despite the Applicants giving 

the Minister material to review on the then proposed ban. No reason was 

given by the Minister as to why he never responded to the 

communications sent by the Applicants. 

[27] In R v Home Secretary ex parte Doody9, Lord Mustill expounded on the 

importance of fairly executing an administrative power and opined: 

“... (1) where an Act of Parliament confers an administrative power there is 

a presumption that it will be exercised in a manner which is fair in all the 

circumstances. (2) The standards of fairness are not immutable. They may 

change with the passage of time, both in the general and in their application 

to decision of a particular type. (3) The principles of fairness are not be 

applied by rote identically in every situation. What fairness demands is 

dependent on the context of the decision, and this is to be taken into account 

in all aspects ... (5) Fairness will often require that a person who may be 

adversely affected by the decision will have an opportunity to make 

representations on his own behalf either before the decision is taken with a 

view to producing a favourable result; or after it is taken, with a view to 

procuring its modification; or both ...” 

[28] I am of the view that the Applicants have raised several arguable grounds 

with a realistic prospect for success for a Judicial Review of the decision of 

the Defendant dated 25th September 2013 to amend Parts I, II and III of the 

CONSERVATION OF WILD LIFE ACT. 

CONCLUSION 

[29] In the circumstances, I order that: 

i. Leave for Judicial Review of the decision of the First-named 

Respondent dated the 25th September, 2013 to amend PARTS I, II 

and III of the CONSERVATION OF WILD LIFE ACT by 

deleting the animals and birds listed therein is granted; 

ii. The Respondents to pay the Applicants’ costs of this Application, 

to be assessed in default of agreement by a Master in Chambers. 

JOAN CHARLES 

JUDGE 

Canine parvovirus

Canine parvovirus type 2 (CPV2, colloquially parvo) is a contagious virus mainly affecting dogs. The disease is highly contagious and is spread from dog to dog by direct or indirect contact with their feces. It can be especially severe in puppies that are not protected by maternal antibodies or vaccination. Treatment often involves veterinary hospitalization. Vaccines can prevent this infection, but mortality can reach 91% in untreated cases. Canine parvovirus will not infect humans.

History

Parvovirus CPV2 is a relatively new disease that appeared in the late 1970s. It was first recognized in 1978 and spread worldwide in one to two years. The virus is very similar to feline panleukopenia (also a parvovirus); they are 98% identical, differing only in two amino acids in the viral capsid protein VP2. It is also highly similar to mink enteritis, and the parvoviruses of raccoons and foxes. The current belief is that the feline panleukopenia mutated into CPV2. It is possible that CPV2 is a mutant of an unidentified parvovirus (similar to feline parvovirus (FPV)) of some wild carnivore. A strain of CPV2b (strain FP84) has been shown to cause disease in a small percentage of domestic cats, although vaccination for FPV seems to be protective. CPV2, however, does not cause disease in cats and does so only mildly in mink and raccoons, and is a virus almost exclusively affecting canines.

Two more strains of canine parvovirus CPV2a and CPV2b were identified in 1979 and 1984 respectively. Most cases of canine parvovirus infection are believed to be caused by these two strains, which have replaced the original strain, and the present day virus is different from the one originally discovered although they are indistinguishable by most routine tests. A third type, CPV2c (a Glu-426 mutant), has been discovered in Italy, Vietnam, and Spain.

Virology

CPV2 is a non-enveloped single-stranded DNA virus. The name comes from the Latin parvus, meaning small, as the virus is only 20 to 26 nm in diameter. It has anicosahedral symmetry. The genome is about 5000 nucleotides long. CPV2 continues to evolve, and the success of new strains seems to depend on extending the range of hosts affected and improved binding to its receptor, the canine transferrin receptor. CPV2 has a high rate of evolution, possibly due to a rate of nucleotide substitution that is more like RNA viruses such as Influenzavirus A. In contrast, FPV seems to evolve only through random genetic drift.

CPV2 affects dogs, wolves, foxes, and other canids. CPV2a and CPV2b have been isolated from a small percentage of symptomatic cats and is more common than feline panleukopenia in big cats.

Previously it has been thought that the virus does not undergo cross species infection. However studies in Vietnam have shown that CPV2 can undergo minor antigenic shift and natural mutation to infect felids. Analyses of feline parvovirus (FPV) isolates in Vietnam and Taiwan revealed that more than 80% of the isolates were of the canine parvovirus type, rather than feline panleukopenia virus (FPLV). CPV2 may spread to cats easier than dogs and undergo faster rates of mutation within that species.

Variants

There are two types of canine parvovirus called canine minute virus (CPV1) and CPV2. CPV2 causes the most serious disease and affects domesticated dogs and wild canids. There are variants of CPV type 2 called CPV-2a, CPV-2b and CPV-2c. The antigenic patterns of 2a and 2b are quite similar to the original CPV type 2. Variant 2c however has a unique pattern of antigenicity. This has led to claims of ineffective vaccination of dogs, but studies have shown that the existing CPV vaccines based on CPV type 2b, provide adequate levels of protection against CPV type 2c.

Pathophysiology

There are two forms of CPV2: intestinal and cardiac. Puppies are most susceptible, but more than 80 percent of adult dogs show no symptoms. With severe disease, dogs can die within 48 to 72 hours without treatment by fluids. In the more common, less severe form, mortality is about 10 percent. Certain breeds, such as Rottweilers, Doberman Pinschers, and Pit bull terriers as well as other black and tan colored dogs may be more susceptible to CPV2. Along with age and breed, factors such as a stressful environment, concurrent infections with bacteria, parasites, and canine coronavirus increase a dog's risk of severe infection.Dogs who catch Parvovirus usually die from the dehydration it causes or secondary infection rather than the virus itself.

Intestinal form

Dogs become infected through oral contact with CPV2 in feces, infected soil, or fomites that carry the virus. Following ingestion, the virus replicates in the lymphoid tissue in the throat, and then spreads to the bloodstream. From there, the virus attacks rapidly dividing cells, notably those in the lymph nodes, intestinal crypts, and the bone marrow. There is depletion of lymphocytes in lymph nodes and necrosis and destruction of the intestinal crypts. Anaerobic bacteria that normally reside in the intestines can then cross into the bloodstream, a process known as translocation, with bacteremia leading to sepsis. The most common bacteria involved in severe cases are Clostridia, Campylobacter and salmonella species. This can lead to a syndrome known as Systemic inflammatory response syndrome(SIRS). SIRS leads to a range of complications such as hypercoagulability of the blood, endotoxaemia and acute respiratory distress syndrome(ARDS). Bacterial Myocarditis has also been reported secondarily to sepsis. Dogs with CPV are at risk of intussusception, a condition where part of the intestine prolapses into another part.Three to four days following infection, the virus is shed in the feces for up to three weeks, and the dog may remain an asymptomatic carrier and shed the virus periodically. The virus is usually more deadly if the host is concurrently infested with worms or other intestinal parasites.

Cardiac form

This form is less common and affects puppies infected in the uterus or shortly after birth until about 8 weeks of age. The virus attacks the heart muscle and the puppy often dies suddenly or after a brief period of breathing difficulty due to pulmonary edema. On the microscopic level, there are many points of necrosis of the heart muscle that are associated with mononuclear cellular infiltration. The formation of excess fibrous tissue (fibrosis) is often evident in surviving dogs. Myofibers are the site of viral replication within cells. The disease may or may not be accompanied with the signs and symptoms of the intestinal form. However, this form is now rarely seen due to widespread vaccination of breeding dogs.

Even less frequently, the disease may also lead to a generalized infection in neonates and cause lesions and viral replication and attack in other tissues other than the gastrointestinal tissues and heart, but also brain, liver, lungs, kidneys, and adrenal cortex. The lining of the blood vessels are also severely affected, which lead the lesions in this region to hemorrhage.

Infection of the fetus

This type of infection can occur when a pregnant female dog is infected with CPV2. The adult may develop immunity with little or no clinical signs of disease. The virus may have already crossed the placenta to infect the fetus. This can lead to several abnormalities. In mild to moderate cases the pups can be born with neurological abnormalities such as cerebellar hypoplasia.

Symptoms

Dogs that develop the disease show symptoms of the illness within 3 to 7 days. The symptoms include lethargy, vomiting, fever, and diarrhea (usually bloody). Diarrhea and vomiting result in dehydration and secondary infections can set in. Due to dehydration, the dog's electrolyte balance can become critically affected. Because the normal intestinal lining is also compromised, blood and protein leak into the intestines leading to anemia and loss of protein, and endotoxins escaping into the bloodstream, causing endotoxemia. Dogs have a distinctive odor in the later stages of the infection. The white blood cell level falls, further weakening the dog. Any or all of these factors can lead to shock and death. The first sign of CPV is lethargy. Usually the second symptoms would be loss of appetite or diarrhea followed by vomiting.

Diagnosis

Diagnosis is made through detection of CPV2 in the feces by either an ELISA or a hemagglutination test, or by electron microscopy. PCR has become available to diagnose CPV2, and can be used later in the disease when potentially less virus is being shed in the feces that may not be detectable by ELISA. Clinically, the intestinal form of the infection can sometimes be confused with coronavirus or other forms of enteritis. Parvovirus, however, is more serious and the presence of bloody diarrhea, a low white blood cell count, and necrosis of the intestinal lining also point more towards parvovirus, especially in an unvaccinated dog. The cardiac form is typically easier to diagnose because the symptoms are distinct.

Treatment

Survival rate depends on how quickly CPV is diagnosed, the age of the dog and how aggressive the treatment is. Treatment usually involves extensive hospitalization, due to the severe dehydration and damage to the intestines and bone marrow. A CPV test should be given as early as possible if CPV is suspected in order to begin early treatment and increase survival rate if the disease is found.

Treatment ideally also consists of crystalloid IV fluids and/or colloids (e.g., Hetastarch), antinausea injections (antiemetics) such as maropitant, metoclopramide,dolasetron, ondansetron and prochlorperazine, and broad-spectrum antibiotic injections such as cefazolin/enrofloxacin, ampicillin/enrofloxacin, metronidazole,timentin, or enrofloxacin. IV fluids are administered and antinausea and antibiotic injections are given subcutaneously, intramuscularly, or intravenously. The fluids are typically a mix of a sterile, balanced electrolyte solution, with an appropriate amount of B-complex vitamins, dextrose and potassium chloride. Analgesic medications can be used to counteract the intestinal discomfort caused by frequent bouts of diarrhea; however, the use of opioid analgesics can result in secondary ileus and decreased motility.

In addition to fluids given to achieve adequate rehydration, each time the puppy vomits or has diarrhea in a significant quantity, an equal amount of fluid is administered intravenously. The fluid requirements of a patient are determined by the animal's body weight, weight changes over time, degree of dehydration at presentation and surface area.

A blood plasma transfusion from a donor dog that has already survived CPV is sometimes used to provide passive immunity to the sick dog. Some veterinarians keep these dogs on site, or have frozen serum available. There have been no controlled studies regarding this treatment. Additionally, fresh frozen plasma and human albumin transfusions can help replace the extreme protein losses seen in severe cases and help assure adequate tissue healing. However, this is controversial with the availability of safer colloids such as Hetastarch, as it will also increase the colloid osmotic pressure without the ill effect of predisposing that canine patient to future transfusion reaction.

Once the dog can keep fluids down, the IV fluids are gradually discontinued, and very bland food slowly introduced. Oral antibiotics are administered for a number of days depending on the white blood cell count and the patient's ability to fight off secondary infection. A puppy with minimal symptoms can recover in 2 or 3 days if the IV fluids are begun as soon as symptoms are noticed and the CPV test confirms the diagnosis. If more severe, depending on treatment, puppies can remain ill from 5 days up to 2 weeks. However, even with hospitalization, there is no guarantee that the dog will be cured and survive.

Unconventional treatments

There have been anecdotal reports of oseltamivir (Tamiflu) reducing disease severity and hospitalization time in canine parvovirus infection. The drug may limit the ability of the virus to invade the crypt cells of the small intestine and decrease gastrointestinal bacteria colonization and toxin production. However, due to the viral DNA replication pattern of parvovirus and the mechanism of action of oseltamivir, this medication has not shown to improve survival times or shorten hospitalization stay. Lastly, recombinant feline interferon omega (rFeIFN-ω), produced in silkworm larvae using a baculovirus vector, has been demonstrated by multiple studies to be an effective treatment. However, this therapy is not currently approved in the United States.

A recent 2012 study (not yet published) from Colorado State University has shown good results with an intensive at-home treatment using maropitant (Cerenia) and Convenia (a long acting antibiotic injection), two drugs newly released by Zoetis (formerly Pfizer). This treatment was based out outpatient care, and would cost $200 to $300 US, a fraction of the $1,500 to $3,000 US that inpatient care cost. However, note that the ideal standard of care is intravenous (IV) fluid therapy. In the CSU study, survival rate for the new treatment group was 85%, compard to the 90% survival for the conventional inpatient treatment. Note that the outpatient dogs received initial intravenous fluid resuscitation, and had aggressive subcutaneous fluid therapy and daily monitoring by a veterinarian.

Prognosis

Untreated cases of CPV2 have a mortality rate approaching 91%. With aggressive therapy, survival rates may approach 80–95%, a mortality rate of 5–20%. However in small dogs and small puppies in most breeds (Chihuahua, Pomeranian, Rottweiler) the survival rate is much lower, between 20–50%.

Prevention and decontamination

Prevention is the only way to ensure that a puppy or dog remain healthy because the disease is extremely virulent and contagious. Appropriate vaccination should be performed starting at 5–6 weeks of age, with a booster given every 3–4 weeks until at least 14 weeks of age (some note 22 weeks of age in suspectible breeds). Likewise, pregnant mothers should be vaccinated early to pass on maternal antibody to puppies. The virus is extremely hardy and has been found to survive in feces and other organic material such as soil for over a year. It survives extremely cold and hot temperatures. The only household disinfectant that kills the virus is bleach. Only a very dilute bleach solution (1:30 ratio) is necessary to disinfect and kill parvovirus.

Puppies are generally vaccinated in a series of doses, extending from the earliest time that the immunity derived from the mother wears off until after that passive immunity is definitely gone. Older puppies (16 weeks or older) are given 3 vaccinations 3 to 4 weeks apart. The duration of immunity of vaccines for CPV2 has been tested for all major vaccine manufacturers in the United States and has been found to be at least three years after the initial puppy series and a booster 1 year later.

A dog that successfully recovers from CPV2 generally remains contagious for up to three weeks, but it is possible they may remain contagious for up to six. Ongoing infection risk is primarily from fecal contamination of the environment due to the virus's ability to survive many months in the environment. Neighbours and family members with dogs should be notified of infected animals so that they can ensure that their dogs are vaccinated or tested for immunity. The vaccine will take up to 2 weeks to reach effective levels of immunity; the contagious individual should remain in quarantine until other animals are protected.

Article is a Wikipedia extract

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