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Victoria’s proposal is not taking into account the care the dogs are given, only a number which has no correlation to animal welfare.

“Labor is proposing that all dog breeders have a maximum of 10 female dogs. This is regardless of the care they are given, the experience of the breeders, or the number of staff a breeder has,’ their website reads.” 

http://www.dailymail.co.uk/news/article-3739769/Victoria-restrict-sale-puppies-kittens-pet-shops.html