Depending on the bitch, but I have had 2 sections and then spayed. I do not make these decisions with out the consult of my vet ** repro specialist**. I do NOT schedule c-sections, free whelp is prefered of course. Some have free whelped some have not. Also, sections should be done once labor has begun, NEVER BEFORE!! Otherwise you are looking at the posibility of the uterus rupturing.
When I've had sections it's because the bitch was in hard labor for more than 45 min and no sign of the 'bubble' and when doing an internal check the pups head is just at the finger tip not close to being on it's way out. We don't do sections just because...
Sections are done for more reasons other than the mom being a 'tiny' or too small to whelp on her own. Just wanted to through that out there.
Sections are controversial on here I can feel it..lol. Although I prefer free whelping. I am not opposed to having a section instead of literally pulling pups out to avoid the surgery.
I don't consider having to reach yoru hand in and pull pups out free whelping. Free whelping IMO is pups are guided on the way not, never pulled. But others may not agree.
Also, if I have to chose between having a puppy pulled out (literally) or a section, I would go for the section in a heart beat! I had a bitch that had a litter of 4 pups pulled out of her and it was the worst experience I have ever witnessed, she had no anesthetic to dull the pain, she was black and blue and swollen for weeks afterwards. That was cruel IMO.
Studies that my vet has done prove that sections (done by experienced vets) result in more live births and less risks of losing the bitch (of course timing is a biggie as well).
Great article on sections..
http://www.dogbreedinfo.com/whelpingcsection.htm