Supreme Court: While considering this matter pertaining to allegations about Greens Zoological Rescue and Rehabilitation Centre and Radhe Krishna Temple Elephant Trust (‘Vantara’); the Division Bench of Pankaj Mithal and Prasanna B. Varale, JJ., upon perusing the report prepared by the Special Investigation Team (SIT) constituted in pursuance of order dated 25-8-2025, took note of the Report’s conclusion that Vantara did not violate any of the relevant laws such as the Wildlife (Protection) Act, 1972, Recognition of Zoo Rules, 2009, CZA guidelines, Customs Act, 1962, Foreign Trade (Regulation and development) Act, 1992, Foreign Exchange Management Act, 1999, Prevention of Money Laundering Act, 2002, Bharatiya Nyaya Sanhita, 2023 or the Convention of International Trade in Endangered Species of wild Fauna and Flora.
The SIT was constituted on 25-8-2025, and its Report in sealed cover, was submitted on 12-9-2025.
The Court accepted the conclusion so drawn in the Report. Since, no contravention of law was reported by the SIT, therefore, the complaints particularly those listed in Schedule A in the summary of the SIT Report, were closed. Accepting the conclusions of the SIT, the Court directed the following:
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The SIT report and annexures including the pen drive be re-sealed and kept confidential but complete copy of the same be furnished to Vantara, may be electronic copy of the same for its own use and record subject to an undertaking that it shall not be disclosed to third parties;
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The summary of the SIT report which is exhaustive in itself as it does not carry comparable sensitiveness or attract the same degree of confidentiality but provides a faithful account of the conclusions reached by the SIT, shall not be treated as confidential;
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In terms of the recommendations contained in the summary and having regard to the exhaustive investigation conducted by the SIT, the complaints/petitions including newspaper reports, articles, catalogues as mentioned in Schedule A to the summary stand duly investigated and closed.
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No further complaint or proceedings based upon such same set of allegations shall be entertained before any judicial statutory or administrative forum so as to secure finality, obviate repetitive inquiries and investigation on issues concluded by the SIT;
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Vantara and the authorities concerned, were directed to consider and implement the measures suggested by the SIT
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The Court left it open for Vantara to pursue its remedies in accordance with law for the deletion of any offending publication or for any action against those responsible for the misinformation or for actions for defamation or private complaints under the BNS, 2023 and if any such proceedings are initiated, they shall be dealt with on their own merits by the competent court/authority.
Background:
After two writ petitions were filed under Article 32 of the Constitution in public interest, based exclusively on reports and stories published in newspapers, circulated on social media, and on various complaints submitted by non-governmental organizations and wildlife organizations, containing allegations against ‘Vantara’, operated by the Reliance Foundation in Jamnagar, Gujarat, the Division Bench comprising Pankaj Mithal and Prasanna B. Varale, JJ. directed the constitution of a Special Investigation Team (‘SIT’) to inquire into the affairs of Vantara. The SIT, led by former Supreme Court judge, Justice Jasti Chelameswar, was tasked with examining, among other issues, the compliance with the provisions of the Wildlife (Protection) Act, 1972 and other relevant statutory frameworks in relation to the acquisition of animals, particularly elephants, from both within India and abroad.
The petitions made wide-ranging accusations, including unlawful acquisition of animals from India and abroad, mistreatment of animals in captivity, financial irregularities, money laundering, and other serious concerns. These petitions were not confined to making allegations against Vantara but also cast aspersions upon statutory authorities such as the Central Zoo Authority, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (‘CITES’), as well as the Courts. The petitions sought to indict the aforementioned institutions solely based on media reports.
Upon a reading of the pleadings, the Court found that the petitions merely contained allegations without any material of probative value. There appeared to be no supporting evidence to substantiate the claims made. However, in light of the serious nature of the allegations, particularly those questioning the willingness or ability of statutory authorities and even the Courts to discharge their mandated duties, the Court deemed it appropriate, in the interest of justice, to order an independent factual appraisal. Accordingly, the Court directed the constitution of an SIT comprising individuals of impeccable integrity, high repute, and extensive experience in public service.
Court’s Assessment:
In pursuance of the afore-stated order, the SIT filed its Sealed Cover Report and summary with annexures and pen drives on 12-09-2025. The report filed in sealed cover was opened and perused by the Court. The Court noted that the SIT with the help of multiple Central and State agencies, regulatory and enforcement bodies, had examined reports and affidavits, conducted site visits, obtained expert opinion and granted personal hearings. The SIT during the inquiry covered the entire range of allegations concerning acquisition of animals, smuggling, laundering, welfare and husbandry, conservation and breeding, climatic and location issues, and financial and trade improprieties. The Court further noted that the SIT coordinated with the Central Zoo Authority, wildlife Crime Control Bureau, CITES Management Authority of India, Central Bureau of Investigation, Directorate of Enforcement, Directorate of Revenue Intelligence, Customs Department and the Jurisdictional Police and carried out a thorough and extensive investigation into complaints particularly those listed in Schedule A of the summary of the report.
The Court thus pointed out that the SIT did not find any contravention of law by Vantara and opined that that the receipt of animals by Vantara by rescuing them from various situations and housing them in the rescue centre for conservation, and breeding programs have gone through a complex multi-layered/multijurisdictional statutory approvals, procedure and documentation. The imports of the animals were made only after issuance of valid permits.
Once the imports of animals were fully documented and supported by valid permits, it was not open for anyone to go beyond the said permits and to dispute the validity attached to such permits or official acts. The Court further noted that repeated inquiries into the affairs of Vantara pursuant to multiple complaints/petitions filed from time to time have culminated with findings of no violation of law whatsoever. Thus, there was no merit in any of the allegations of animal smuggling or laundering.
On the issue of welfare, conservation and preservation of the animals at Vantara, the Court took note of SIT’s findings which indicated that Vantara facilities exceed prescribed benchmark, and the mortality figures align with the global zoological averages. Upon consideration of the entire record, the Court was satisfied that the facilities at Vantara in certain respects exceeds the prescribed standards of animal husbandry, veterinary care and welfare as well as the statutory benchmarks laid down by the Central Zoo Authority. The allegations of deficiency in welfare standards were therefore unfounded.
The SIT further did not find any evidence of misuse of carbon credits, water resources, or financial impropriety.
The Court concluded the order by expressing its gratitude to the SIT members and other officers involved with the investigation.
The Court further directed that summary of the investigation, finding and recommendations of the SIT shall form part of the Order copy.
[CR Jaya Sukin v. Union of India, 2025 SCC OnLine SC 2007, order dated 15-9-2025]
Advocates who appeared in this case:
For Parties: Mr. Raghavv Sabharwal, Adv. Mr. Raghav Malhotra, Adv. Mr. Ayush Shrivastava, Adv. Mr. Harsh Vardhan, Adv. Dr. Sandeep Singh, Adv. Mr. Amit Kumar, Adv. Mr. Ashish Pandey, AOR Petitioner-in-person Ms. Yashika Anand (Adv.) Ms. Divya Mishra (Adv.) Mr. Isaac Haiding (Adv.) Ms. Suresh Kumari (Adv.) Mr. Harish N Salve, Sr. Adv. Mr. Shardul Singh, Adv. Mr. Manish Tiwari, Adv. Ms. Sayali Sawant, Adv. Ms. Prerna Gandhi, Adv. Mr. Anish Shahpurkar, Adv. Mr. Manish Tiwari , AOR Mr. Tushar Mehta, Solicitor General Mr. K.M.nataraj, A.S.G. Mr. Gurmeet Singh Makker, AOR Mr. Gaurang Bhusan, Adv. Mr. Bhuvan Kapoor, Adv. Ms. Astha Singh, Adv. Mr. Anuj Udupa, Adv. Mr. Rohan Gupta, Adv. M/S. Lambat & Legiteam, AOR Intervenor-in-person, AOR Ms. Aishwarya Bhati, ASG Ms. Manisha Chava, Adv. Mr. Anirudh Singh, Adv. Ms. Hemadri Sharma, Adv. Mr. M. K. Maroria, AOR
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