A file is to be prepared for the Director of Public Prosecutions after a suspected puppy farm was searched in Co Louth.
Most of the dogs found - including 23 bitches and eight puppies - were German Shepherds.
A closure order was served on the operation, which is in a rural location, by Louth county vet Garrett Shine.
It also appears that some of the animals were there without the knowledge of their owners.
One man said he had sent his dog to the location because it was advertised as providing training for dogs.
Gardaí said: "The investigation is ongoing and a file will be prepared (for the DPP)."
As part of the operation, 38 dogs including two litters of pups were removed from the property and taken to Louth County Council animal pound, where they have been documented, scanned and vaccinated, a council spokesperson said.
The assistance of the Louth SPCA was also sought to probe the animals' welfare.
