Diana Curtis, 53, of Peters Marland, had dogs seized in 2010 and was given an Anti-social Behaviour Order (Asbo).
She was told that she could keep 14 animals, but last week pleaded guilty to breaching the Asbo and is now only allowed to keep six dogs.
The RSPCA said it was considering if any animal welfare offences had been committed and whether to prosecute.
'Sympathy factor'
Torridge District Council said 14 dogs could remain on-site until 10 January, after which time if she still had any more than six dogs, the rest would be removed.
Curtis said: "[It's] totally out of proportion - they weren't that noisy, they might bark some times of the time day but they're not barking constantly..." More
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