The nesting behaviour of laying hens is a highly motivated behaviour whose frustration in cage systems causes measurable distress that has driven reforms in housing standards.
Hen nesting behaviour welfare was instrumental in demonstrating that physical health is not sufficient for good welfare — a hen in a battery cage that was physically healthy but unable to lay in a nest was nonetheless welfare-compromised. The pre-laying behavioural sequence is strongly motivated: hens denied nesting opportunity show escalating frustration behaviour, stress responses, and eventually lay their egg without completing the sequence in a state of welfare compromise. This evidence was part of the scientific case that led to the EU ban on barren battery cages. Nest box provision is a welfare improvement, but the motivation for nesting behaviour requires more than a curtained box in a colony system to be fully satisfied.