In court cases regarding animals, the animals have the status of ""legal person"" and humans have the legal duty to act as "loco parentis" towards animals welfare like a parent has towards the minor children. A court while deciding the ""Animal Welfare Board of India vs Nagaraja"" case in 2014 mandated that animals are also entitled to the fundamental right to freedom enshrined in the Article 21 of Constitution of India i.e. right to life, personal liberty and the right to die with dignity (passive euthanasia). In another case, a court in Uttarakhand state mandated that animals have the same rights as humans. In another case of cow-smuggling, the Punjab and Haryana High Court mandated that ""entire animal kingdom including avian and aquatic"" species has a ""distinct legal persona with corresponding rights, duties, and liabilities of a living person"" and humans are ""loco parentis"" while laying out the norms for animal welfare, veterinary treatment, fodder and shelter, e.g. animal drawn carriages must not have more than four humans, and load carrying animals must not be loaded beyond the specified limits and those limits must be halved when animals have to carry the load up a slope.