大方廣佛華嚴經隨疏演義鈔 44.58

44.58

疏「如殺馬祀」等者。即《百論》中外道，計殺馬祀天得生梵天。即逼惱於馬，謂為戒等。

The Commentary states: "Like slaughtering horses for sacrifice," and so forth. This refers to the non-Buddhists in the Śataśāstra who posited that by slaughtering horses to sacrifice to heaven one could be born in the Brahmā heaven. This is precisely tormenting horses and calling it a precept, and so forth.