Supreme Court: While considering this matter pertaining to conservation of tigers and their habitat, restoration of Jim Corbett Tiger Reserve and permitting tiger safaris, the 3-Judge Bench of B.R. Gavai, CJI*, Augustine George Masih and A.S. Chandurkar, JJ., gave the following comprehensive directions:
In relation to Corbett Tiger Reserve
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State of Uttarakhand (State) was directed to submit a plan for the restoration of the Corbett Tiger Reserve in line with the recommendations made by the Expert Committee, within a period of 2 months;
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The State was directed to begin all clearing/demolition of unauthorised construction as identified by the Expert Committee, before the lapse of 3 months from the date of this judgment
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State was directed to file a compliance affidavit within a period of 1 year from the date of this judgment.
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The Central Empowered Committee (CEC) was directed to monitor and supervise the implementation of the ecological restoration plan developed by the State of Uttarakhand. While developing and implementing this plan and carrying out afforestation, the State of Uttarakhand must ensure that only native and indigenous species are identified, with special care to not introduce any alien species to the ecosystem.
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Without going into the issues regarding valuation of quantification of costs for restoration as well as the potential ecological loss caused from the Safari project etc., the Court directed the State to restore the ecological damage caused to the Corbett Tiger Reserve under the supervision, guidance and control of the CEC. The Field Director shall periodically report to the CEC with regard to the restoration and the restoration work would be carried to the satisfaction of the CEC.
On permitting Tiger Safaris in the buffer and fringe areas
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The Court held that Tiger Safari shall not be permitted in the core or a critical tiger habitat area.
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Tiger Safari shall be established on ‘non-forest land’ or ‘degraded forest land’ in buffer area provided that is not part of a tiger corridor.
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Tiger Safari shall be allowed only in association with a full-fledged rescue and rehabilitation centre for tigers where conflict animals, injured animals or abandoned animals are housed for care and rehabilitation.
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These Tiger Safaris shall be subject to the conditions and restrictions mentioned in the Report of the Expert Committee.
Guidelines for Tiger Safaris
Accepting the Committee’s recommendations with regards to Guidelines for Tiger Safaris, the Court directed that the recommendations may be established and run with due consideration of the ‘Guidelines to Establish Tiger Safari in Buffer and Fringe Areas of Tiger Reserves 2019’ issued by the National Tiger Conservation Authority (NTCA) with the following additional requirements:
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The directions in T.N. Godavarman Thirumulpad, In Re v. Union of India, (2025) 2 SCC 641 with regard to sourcing of animals shall be strictly adhered to;
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Only animals rescued and/or conflict animals from the Tiger Reserve or from the same landscape should be housed in the Tiger Safaris;
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Rescue Centre to be established in conjunction with such Tiger Safari shall provide essential veterinary support to such facility and help in treatment/care of captured animals;
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Tiger Safari should be under the management control of the Field Director of the concerned Tiger Reserve with supervision of the Chief Wildlife Warden;
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Earnings should be ploughed back through the concerned Tiger Conservation Foundations;
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Design considerations should be such that there is no scope for interaction between in-situ and ex-situ populations;
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Enclosure design must be approved by the Central Zoo Authority (CZA)
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Carrying capacity norms should be developed
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Solar/Hybrid/Electric vehicles to be promoted and number of vehicles also must be regulated
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Strict Zero Discharge of wastewater to be permitted from safaris.
Permissible and prohibited activities in the buffer and fringe areas of the Tiger Reserve
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The Court approved the letter dated 23-4-2018 (F.No.15-22/2013-NTCA) issued by the Ministry of Environment, Forest and Climate Change (MoEF & CC) to the Chief Wildlife Wardens regarding submission of proposal for notifying ESZ of Tiger Reserves. The Court approved of the rationale in this letter, that the very minimum protection that buffer zones are entitled to, is that which is afforded to the environment in ESZs, which appeared to be in the spirit of the concept of Eco-Sensitive Zones (ESZs), taking forward the culture of conservation. It follows as a natural corollary that insofar as the buffer zone of a critical tiger habitat or the buffer zone of the Tiger Reserve is concerned, the same restrictions as envisaged in the Notification dated 09-02-2011 will apply.
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The Court directed all State Governments to notify ESZs around all Tiger Reserves, including buffer and fringe areas, no later than 1 year from the date of this judgment.
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The formulation of ESZs for these Tiger Reserves will abide by the letter dated 23-4-2018 issued by the MoEF & CC which clarifies that the minimum area comprised in the ESZs will be the buffer or fringe area of the Tiger Reserve. These ESZs will be accorded the same safeguards provided in the Notification dated 9-2-2011, issued by the MoEF & CC, at the minimum. The Court clarified that these notified ESZs will be subject to all the same restrictions as per the Notification dated 09-02-2011, including the restriction that within a distance of 1 km from a Tiger Habitat or buffer area, or the notified ESZ (whichever is larger), there will be a complete ban on mining activities.
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The Court further summarised a list of prohibited and regulated activities which would be applicable to the buffer or fringe areas of Tiger Reserves:
Prohibited activities:
(i) Commercial mining.
(ii) Setting of sawmills.
(iii) Setting of industries causing pollution (water, air, soil, noise, etc.).
(iv) Commercial use of firewood for hotels and other business-related establishment.
(v) Establishment of major hydroelectric projects.
(vi) Introduction of exotic species.
(vii) Use of production of any hazardous substances.
(viii) Undertaking activities related to tourism like overflying the tiger reserves by low flying aircraft (including drones and hot air balloons). The minimum height of any aircraft shall be at a level which is at least 300m (1000 ft) above the highest obstacle located within 8 km of the estimated position of the aircraft.
(ix) Discharge of effluents and solid waste in natural water bodies or terrestrial area.
(x) Felling of trees without permission from appropriate Authority.
Regulated activities:
(i) Establishment of hotels and resorts as per approved Tourism prescriptions of Buffer component of the TCP, which takes care of habitats allowing no restriction on movement of wild animals.
(ii) Commercial use of natural water resources including ground water harvesting. As per approved master plan, which takes care of habitats allowing no restriction on movement of wild animals.
(iii) Fencing of premises of hotels and lodges.
(iv) Widening of roads.
(v) Movement of vehicular traffic at night.
(vi) Protection of hill slopes and riverbanks as per the master plan.
Other recommendations on permissible and prohibited activities:
(i) Tiger Conservation Plan should clearly delineate zones within the buffer areas where new tourism infrastructure may be developed considering road accessibility, proximity to village habitations, animal corridors, etc.
(ii) Development of tourism infrastructure in buffer zones should be regulated in accordance with the ESZ notifications issued under the Environment (Protection) Act 1986.
(iii) Eco friendly tourism facility and infrastructure can be allowed on non-forest land in buffer area of Tiger Reserve.
(iv) Tourism infrastructure zone should be marked and delineated in the buffer area and such tourism zone should be part of Tiger Conservation Plan and Zonal Master plan of Eco sensitive zone.
Whether resorts can be permitted within proximity of protected areas and restrictions
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Ecotourism cannot resemble mass tourism and must be adequately regulated and adhere strictly to NTCA Guidelines. New eco-friendly resorts may be allowed in buffer but shall not be allowed in an identified corridor;
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Homestays and community-managed establishments should be encouraged and incentives should also be given to them;
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Zero waste practices should be made mandatory; Use of mobile phones within tourism zones of the core habitat of tiger reserves should not be permitted
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Vehicular carrying capacity as prescribed in the NTCA guidelines needs to be calculated and strictly enforced;
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Complete ban on night tourism must be implemented
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In those tiger reserves where roads traverse the core/critical tiger habitat, strict night regulation (no traffic from dusk to dawn except ambulances/emergency) needs to be exercised.
Permissible noise levels and the distance from the boundary of the protected forest for which restrictions on noise level will be applicable
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The entire area of the Tiger Reserve (including ESZs of the Protected Areas) shall be notified as “Silence Zone” under the Noise Pollution (Regulation and Control) Rules, 2000, within 3 months from the date of this judgment. Further, the authorities of Tiger Reserve would be empowered to enforce the regulation of maintaining silence zone and acting under relevant statutes.
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Central Government, or the State Government shall also consider declaring that all Protected Areas of the State and their ESZs notified as Forests under the Forest Act, 1927 and respective State Forest Acts, as Silence Zones.
Effective management of Tiger Reserves, on a pan-India basis
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All the States were directed to notify the buffer and core areas of the Tiger Reserves within 6 months from the date of this judgment. Additionally, all States were directed to prepare a Tiger Conservation Plan (TCP).
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The Court directed the States to constitute a Steering Committee if not yet constituted for each Tiger Reserve, shall be done so within 2 months and further directed the NTCA to monitor the issue as to whether the TCPs have been put in place or not and whether the Steering Committees have been meeting on a regular basis or not. It was directed that the Steering Committees shall hold at least two meetings in a year.
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All States must adhere to the NTCA guidelines on tourism, thus adopting the overarching aim for regulation to move towards a system of community-based tourism around Tiger Reserves. Court also gave its seal of approval to the NTCA prescription against night tourism in entirety.
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Financial assistance under the Project Tiger component of the CSS-IDWH should be mandatorily linked to an approved Tiger conservation plan Forest areas in buffer and corridor regions identified in the TCP should be managed as per the TCP to ensure harmony of forestry operations vis-à-vis wildlife concerns; Forestry operations in forest lands forming part of the buffer areas should be incorporated in TCP in consultation with working plan of the State Forest Department;
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Critical Tiger Habitat notified under Section 38-V(4)(i) of the WLP Act should be treated at equivalence with Critical Wildlife Habitats as per Section 2(b) of the Scheduled Tribes and other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006, as both are decided on scientific principles and ecological importance with due recognition of rights of tribals and forest dwellers
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TCP should also have the tiger carrying capacity calculated as per extant norms, based on which habitat interventions should be decided; While continuing the use of CAMPA funds for voluntary village relocation, dedicated funds should be earmarked for this activity to ensure an inviolate core/critical tiger habitat. Voluntary village relocation should also be financially assisted in areas of other strategic ecological value such as villages in buffer or in dispersal routes of tigers.
Additionally, the Court issued directions vis-a-vis filling in all the vacancies in various cadres.
The Court directed that the MoEF & CC, the NTCA and the CEC will jointly come out with a policy framework on funding for tiger reserves. Such a policy should contain a Standard Operating Procedure for raising budgetary grants and assessment and approval of the same. MoEF & CC, the NTCA and CEC were directed to formulate the said policy framework on funding, within 6 months from the date of this judgment.
The Court further stated that it would be appropriate if the NTCA frames Model Guidelines, incorporating suggestions on Proper Human Wildlife Conflict Management within 6 months from the date of this judgment, which will then in turn be implemented by the State Governments within 6 months. NTCA may consult the State Governments and the CEC, if required, while framing these Model Guidelines.
Notifying ‘Human wildlife conflict’ as a “natural disaster” (as has already been done by some states like Uttar Pradesh) should be actively considered by other states. All the States were directed to give ex-gratia amount of Rs 10 lakh as fixed by the MoEF & CC under CSS-IWDH.
All information about Tiger Reserves, Tiger Corridors, Protected Areas, and ESZ should be uploaded on the “Gati Shakti” portal of the Central Government. Mitigation measures as prescribed by the Wildlife Institute of India, NTCA, Standing Committee of the National Board of Wildlife for any developmental activity and linear infrastructure must be strictly followed in the interest of wildlife conservation and development both. Transmission lines wherever are required to be laid through tiger reserves, should be insulated or bunch cabling to be done or be laid underground as per the technical feasibility.
On the issue of Regulation of Religious Tourism, the Court directed the MoEF & CC as well as the various State Governments to take necessary steps by notifying rules and/or by issuing memorandums or circulars for implementing the directions and recommendations issued hereinabove within a period of 6 months from the date of this Judgement.
[IN RE : CORBETT, I.A. NO. 20650 of 2023, decided on 17-11-2025]
*Judgment by CJI B.R. Gavai
Advocates who appeared in this case:
Ms. Aishwarya Bhati, ASG; Mr. K. Parameshwar, Amicus Curiae assisted by Mr. M.V. Mukunda, Ms. Kanti, Ms. Raji Gururaj, Mr. Shreenivas Patil and Ms. Veda Singh, counsels