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Why the MoD Refused to Release 2024 Military Animal Euthanasia Data

The MoD released 2023 military animal euthanasia figures in February 2025, then refused the identical 2024 request in May 2025 on cost grounds. Two separate record systems went unmentioned.

A UK government building sign rubber stamped refused. AI-generated Illustration for Veriarch

On 4 February 2025, the Ministry of Defence released figures on the number of military horses and dogs euthanised in 2023. On 20 May, it refused to provide the 2024 figures, estimating that the work would exceed the £600 Freedom of Information cost limit.

Data Manifest

  • Primary Investigation: Why the Ministry of Defence refused, under Section 12(1) of the Freedom of Information Act, to release the 2024 military animal euthanasia figures on 20 May 2025, three months after releasing the equivalent 2023 figures.
  • Key Anomalies Documented: Identical directorate moved from full disclosure (FOI2025/00528) to cost-grounds refusal (FOI2025/10040) inside three months; refusal scoped the search to individual animal files without referencing the separate accountable drug records or the animal by-products paperwork; no procedural change is documented between the two responses.
  • Primary Sources Utilised: MoD FOI responses FOI2025/00528 and FOI2025/10040; Veterinary Medicines Regulations 2013; JSP 886 Vol 6 Part 6; JSP 950 Leaflet 12; UK animal by-products regime; contemporaneous reporting on the 24 April 2024 Household Cavalry incident.

Glossary

  • FOI: The Freedom of Information Act 2000, which gives the public a right to request recorded information from public authorities.
  • RAVC: The Royal Army Veterinary Corps, the Army branch responsible for military animal care.
  • JSP 886: The MoD's Defence Logistics Support Chain Manual. Volume 6 Part 6 covers medical supply and lists accountable drugs.
  • JSP 950 Leaflet 12: The specific leaflet within the MoD's medical policy manual that sets out the Controlled Drug Accountable Officer role.
  • Accountable Drug: A drug category under Defence policy that must be logged in a dedicated register, with the documentation archived for seven years.

The Army Secretariat Refusal Letter

ArmyPolSec/E/A/FOI2025/10040 is a short administrative letter. It carries the Army Policy and Secretariat address at Zone 2.C, Blenheim Building, Marlborough Lines, Andover, and responds to a FOI request submitted on 17 April 2025 by Ian Overton of Action on Armed Violence.

The refusal rests on Section 12(1) of the Freedom of Information Act. For central government, the letter gives the limit as £600, or 3.5 working days of staff time. According to the Secretariat, the work would go beyond that threshold.

Then comes the sentence that matters most. Locating the information, the letter says, would ‘involve searching individual records of every Military Working Animal’ between 2024 and 17 April 2025.

A search sheet is not attached. No list of systems appears beneath the letterhead. Nor is there a breakdown showing how many animal files were counted, how long each was expected to take or which database produced the estimate.

That leaves a fairly narrow problem. The refusal tells us what the Secretariat said it would have to search, but not how that route was chosen.

The Refusal in Numbers

  • Reference: ArmyPolSec/E/A/FOI2025/10040
  • Date of Refusal: 20 May 2025
  • Requester: Ian Overton, Action on Armed Violence (request submitted 17 April 2025)
  • Ground of Refusal: Section 12(1), Freedom of Information Act
  • Appropriate Limit (central government): £600 or 3.5 working days of staff time
  • Reason Given: Locating the information would 'involve searching individual records of every Military Working Animal' between 2024 and 17 April 2025
  • Not Attached: Search sheet, list of systems consulted, or breakdown of the cost calculation
Army Policy and Secretariat Refusal Notice FOI2025/10040 (20 May 2025).

The 2025 FOI Response That Set a Precedent

FOI2025/00528 was issued on 4 February 2025. That response did provide annual euthanasia figures: 14 military horses and 18 military dogs for 2023, along with medical reasons ranging from disease and lameness to behavioural problems.

Three months later, the 2024 request was refused on cost grounds.

Placed side by side, the two PDFs are awkward company. One shows that the MoD could produce a detailed annual return for 2023. By contrast, the later response says producing the next set of figures would require a file-by-file search across every military working animal.

The £600 limit was the same in both responses. No source is available for this investigation, records show a change in RAVC record-keeping between 4 February and 20 May 2025.

A change may have occurred. The source that would establish one is absent.

So the February response is a precedent, not proof that the May refusal was false. What happened to the search method between those two dated PDFs is not recorded in the material available here.

Two Requests, Same Directorate

FOI Ref Date of Response Period Covered Outcome Figures Released Cost Ground Cited
FOI2025/00528 4 February 2025 2023 Released 14 military horses, 18 military dogs, with medical reasons None cited
FOI2025/10040 20 May 2025 2024 to 17 April 2025 Refused None Section 12(1), £600 / 3.5 working days threshold
Ministry of Defence FOI2025/00528 (4 February 2025) and FOI2025/10040 (20 May 2025).

Why Pentobarbital Records Could Matter

Veterinary medicines are governed by the Veterinary Medicines Regulations 2013. Military policy adds its own controls. Those records matter because euthanasia requires a drug to be issued, administered and accounted for somewhere in the system.

One part of the original case did not survive checking.

Pentobarbital had been treated as a Schedule 2 controlled drug. JSP 886, the MoD logistics manual cited in the evidence, instead lists Pentobarbital, or Pentobarbitone, as a Schedule 3 ‘Accountable Drug’. Defence policy also requires controlled drug documentation to be archived for seven years, rather than the five-year period initially attributed to these records.

That removes the simple claim that a Schedule 2 register must contain every pentobarbital euthanasia entry. It does not remove the separate Defence requirement to account for the drug.

JSP 950 names a Controlled Drug Accountable Officer, or CDAO, the senior role responsible for oversight of controlled drugs. Two sites matter most to this inquiry: the Defence Animal Training Regiment at Melton Mowbray and the Household Cavalry Mounted Regiment at Hyde Park Barracks.

There was, at least in principle, another place to start looking.

A records officer could ask for the 2024 pentobarbital accounting records and use the entries to identify dates and animals before opening individual clinical files for the medical reasons. That is a proposed search route. Nothing supplied proves that it would yield the complete FOI answer quickly, or that all relevant euthanasia events would sit in one convenient annual list.

We have not seen the underlying 2024 drug records.

Their format is another small but important gap. They may exist as bound books, an auditable electronic system or some combination of the two. Published RAVC material supplied for this investigation does not settle it, and without the pages or an electronic export there is no annual count to perform independently.

The May refusal describes a search through individual animal records. Defence policy also requires separate records for accountable drugs. The correspondence does not say whether those records were considered.

Whether anyone in Andover asked for it before invoking Section 12 is absent from the correspondence.

Two Search Routes, One Question

The route described in the refusal notice, set alongside the accountable drug records route the correspondence does not mention.

Route Cited in the Refusal

Starting Point

Individual clinical file for every Military Working Animal between 2024 and 17 April 2025.

Estimated Volume

Not disclosed. No search sheet or file count was attached to the refusal.

Estimated Cost

Said to exceed £600 or 3.5 working days.

Alternative Route Not Referenced

Starting Point

2024 accountable drug records held by the Controlled Drug Accountable Officer at DATR, Melton Mowbray, and HCMR, Hyde Park Barracks.

Estimated Volume

One or two register sets covering pentobarbital use across 2024. Format not confirmed in the material available.

Estimated Cost

Not calculated. The correspondence does not say whether these records were considered before Section 12 was invoked.

Nothing supplied proves the alternative route would return the full 2024 euthanasia figures quickly. The comparison shows a route that was chosen and a route that was not documented as considered.

Veterinary Medicines Regulations 2013 and JSP 950 Leaflet 12 (Ministry of Defence, 2013 onwards).

Second Record System Behind the Missing Data

Drug records are only one route. Dead animals also enter the animal by-products system, which controls how carcasses are moved and disposed of.

For regulated animal remains, the cited guidance requires a Commercial Document to travel with the load. In plain English, it is a movement record. Guidance cited for this investigation says the form is produced in triplicate and retained for at least two years.

Three copies leave paper in more than one place.

A horse or dog removed for authorised disposal should generate a date, a description of the material and a destination. If the 2024 forms were filed together, those sheets could provide another count of animal deaths without beginning with every clinical file.

One point cannot be checked from the source material available here. The claim that the sender’s copy would be kept by the RAVC or a regimental quartermaster relies on a Bromley disposal source that was cited but was not available for review. Nor can we safely say that counting the forms would take only minutes. Nobody has produced the filing layout at Melton Mowbray or Hyde Park Barracks. A neat folder marked ‘2024’ would make the task simple; the evidence does not contain such a folder.

Triplicate paperwork still presents an outside route. A receiving contractor or disposal site may hold the corresponding copy of a carcass movement record.

The Second Paper Trail

Regulation Document Required Minimum Retention Held By What It Would Show for 2024
UK animal by-products regime (assimilated from EC 1069/2009 and EU 142/2011) Commercial Document, produced in triplicate 2 years Not confirmed from the material available. The claim that the sender's copy sits with the RAVC or a regimental quartermaster rests on a source not provided for this investigation. Date, description and destination of each carcass moved for authorised disposal.

The filing layout at Melton Mowbray and Hyde Park Barracks has not been produced. Whether the 2024 forms are grouped in a way that permits a quick count is not established by the sources cited here.

UK animal by-products regime and associated statutory guidance.

From the Cavalry Horse Bolt to the FOI Refusal

Five Household Cavalry horses bolted during a morning exercise near Buckingham Palace on 24 April 2024 after construction rubble was dropped nearby. They were Vida, Quaker, Trojan, Tennyson and Vanquish. Reports from the time say they bolted after construction rubble was dropped nearby during a morning exercise.

The horses ran through central London and collided with vehicles, including a double-decker bus and a taxi. Vida and Quaker were reported to have suffered the most serious injuries.

News footage also recorded the incident as it happened. The images show the horses running through traffic and the injuries that followed, but they do not answer the later question of how many military horses or dogs were euthanised during 2024.

Vida and Quaker survived. Both underwent surgery and were later transferred to The Horse Trust in Buckinghamshire.

Three of the other horses had returned to duty by June 2024. The material gathered for this investigation identifies them as Trojan, Tennyson and Vanquish, although the contemporary report cited for the return confirms that three horses resumed duty without naming all three in the same passage.

AOAV’s later Freedom of Information request covered more than the April incident. It asked for the numbers of military dogs and horses euthanised, the reasons given, rehoming figures and whether any euthanasia had been connected to the London incident.

From the Bolt to the Refusal

  • 24 April 2024

    Five Household Cavalry horses bolt in central London

    Vida, Quaker, Trojan, Tennyson and Vanquish bolted during a morning exercise near Buckingham Palace after construction rubble was dropped nearby. The horses collided with vehicles, including a double-decker bus and a taxi. Vida and Quaker were reported to have suffered the most serious injuries.

  • Late April to May 2024

    National and international coverage

    Contemporary reporting recorded the incident and the injuries that followed, without answering how many military horses or dogs were euthanised during 2024.

  • June 2024

    Three horses return to duty

    The material gathered for this investigation identifies the three as Trojan, Tennyson and Vanquish. Vida and Quaker had by then been transferred to The Horse Trust in Buckinghamshire after surgery.

  • 4 February 2025

    MoD releases the 2023 figures

    FOI2025/00528 discloses 14 military horses and 18 military dogs euthanised in 2023, with medical reasons.

  • 17 April 2025

    AOAV submits the 2024 request

    Ian Overton of Action on Armed Violence asks for the numbers of military dogs and horses euthanised, the reasons given, rehoming figures, and whether any euthanasia was connected to the London incident.

  • 20 May 2025

    Section 12 refusal issued

    The Army Policy and Secretariat refuses FOI2025/10040 on cost grounds, stating that the search would 'involve searching individual records of every Military Working Animal'.

The Guardian (29 April 2024), Horse Canada (2024), Ministry of Defence FOI2025/00528 and FOI2025/10040, and AOAV (2025).

The Language Contradiction

Earlier MoD correspondence contains a small editorial correction. In the 2023 disclosure, the department objected to the word ‘destroyed’, calling it ‘inaccurate to the treatment provided and lack[s] compassion’. It preferred ‘humanely euthanise’.

AOAV responded that ‘compassionate language without accompanying recordkeeping risks becoming hollow’. That is AOAV’s assessment, rather than a finding established by the documents.

The two MoD responses still sit uneasily together. The February letter gave figures for 2023 and corrected the language used to describe euthanasia. The May letter did not provide the equivalent 2024 figures because the proposed search was said to exceed the cost limit.

The documents needed to explain that difference have not been produced. They include the Section 12 cost calculation, any correspondence between the Army Secretariat and the RAVC and any record showing whether the Controlled Drug Accountable Officer was consulted before the refusal was issued.

Two Statements, Same Directorate

  • February 2025, FOI2025/00528: The MoD objects to the word 'destroyed', calling it 'inaccurate to the treatment provided and lack[s] compassion', and insists on 'humanely euthanise'.
  • May 2025, FOI2025/10040: The same directorate declines to provide the 2024 figures, on the basis that the search would 'involve searching individual records of every Military Working Animal' and exceed the £600 cost limit.
  • Not Produced: The Section 12 cost calculation, any correspondence between the Army Secretariat and the RAVC, and any record showing whether the Controlled Drug Accountable Officer was consulted before the refusal was issued.
Ministry of Defence FOI2025/00528 (4 February 2025) and FOI2025/10040 (20 May 2025).

Source Box

Sources include: Ministry of Defence Freedom of Information responses FOI2025/00528 (4 February 2025) and FOI2025/10040 (20 May 2025); the Veterinary Medicines Regulations 2013; JSP 886 Vol 6 Part 6 (Defence Logistics Support Chain Manual, Commodity Supply Management, Medical); JSP 950 Leaflet 12 (Defence medical policy); Royal College of Veterinary Surgeons guidance on veterinary medicines and controlled drugs; the assimilated UK animal by-products regime (originating in EC 1069/2009 and EU 142/2011); Business Companion statutory guidance on fallen stock and the disposal of animal by-products; Martlands guidance on ABP categories; Action on Armed Violence commentary ‘When records fall silent’ (2025); and contemporaneous reporting on the 24 April 2024 Household Cavalry incident in ‘The Guardian’ (29 April 2024) and ‘Horse Canada’ (2024).

Claim-Source Matrix

Core Finding Primary Source Document Status
The Army Secretariat refused FOI2025/10040 on 20 May 2025, citing Section 12(1) and the £600 / 3.5 working days threshold. Army Policy and Secretariat Refusal Notice FOI2025/10040 Confirmed
The refusal states the search would 'involve searching individual records of every Military Working Animal'. Army Policy and Secretariat Refusal Notice FOI2025/10040 Confirmed
FOI2025/00528, issued 4 February 2025 by the same directorate, released 2023 figures of 14 military horses and 18 military dogs with medical reasons. Ministry of Defence FOI2025/00528 Confirmed
Pentobarbital is listed by JSP 886 Vol 6 Part 6 as a Schedule 3 accountable drug, not Schedule 2. JSP 886 Vol 6 Part 6 Annex A Confirmed
Defence policy requires controlled drug documentation to be archived for seven years. JSP 886 Vol 6 Part 6 Confirmed
JSP 950 Leaflet 12 names the Controlled Drug Accountable Officer as the senior role responsible for oversight of controlled drugs. JSP 950 Leaflet 12 Confirmed
The UK animal by-products regime requires a Commercial Document, produced in triplicate and retained for at least two years, to accompany carcass movements. UK animal by-products regime and associated statutory guidance Confirmed
Five Household Cavalry horses (Vida, Quaker, Trojan, Tennyson and Vanquish) bolted in central London on 24 April 2024 after construction rubble was dropped nearby. The Guardian (29 April 2024) and contemporaneous reporting Confirmed
Vida and Quaker survived, underwent surgery, and were transferred to The Horse Trust in Buckinghamshire. Horse Canada (2024) and further contemporaneous reporting Confirmed

What We Still Do Not Know

  • How the Section 12 cost estimate was actually built. The refusal cites the £600 threshold without disclosing the file count assumed, or the staff time assigned to each file.
  • Whether anyone spoke to the Controlled Drug Accountable Officer before FOI2025/10040 was refused. No note of such a conversation appears in the correspondence.
  • What the 2024 accountable drug registers at Melton Mowbray and Hyde Park Barracks actually look like, and whether they can be searched by date, medicine or animal without opening individual clinical files.
  • Did anything change between the 4 February 2025 disclosure and the 20 May 2025 refusal. No records system change, policy instruction or local practice shift has been documented.
  • Where the 2024 Commercial Documents are held, and which disposal contractors hold the matching receiving copies.
  • What the Veterinary Medicines Directorate or Animal and Plant Health Agency last found at the relevant military sites on drug accounting or carcass disposal.
  • Why individual clinical files were chosen as the starting point. No internal email, search note or draft calculation explaining that choice has been produced.

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