Tiger Safari Not To Be Permitted In Core Tiger Habitat Area; Religious Tourism Shall Be Regulated: Supreme Court

The Supreme Court has issued certain directions with respect to the permission of Tiger Safaris and the regulation of religious tourism.

The Court had earlier in March 2024, directed the constitution of an Expert Committee to carry out an in-depth inquiry, and make recommendations based on various aspects.

The three-Judge Bench comprising Chief Justice of India (CJI) B.R. Gavai, Justice Augustine George Masih, and Justice A.S. Chandurkar held that held that Tiger Safari shall not be permitted in the core or a critical tiger habitat area. It issued the following directions –

• 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.

• 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.

• These Tiger Safaris shall be subject to the conditions and restrictions mentioned in the Report of the Expert Committee.

Senior Advocate K. Parameshwar was appointed as an Amicus Curiae, assisted by Advocates M.V. Mukunda, Kanti, Raji Gururaj, Shreenivas Patil, and Veda Singh. Additional Solicitor General (ASG) Aishwarya Bhati and Advocate Gaurav Kumar Bansal appeared as Applicant in person and Standing Counsel (Advocate) Abhishek Attrey appeared for the State of Uttarakhand.

Guidelines for Tiger Safaris

The Court accepted the Expert Committee’s recommendations with regards to Guidelines for Tiger Safaris and directed that they 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 –

• The directions of the Court in T.N. Godavarman case with regard to sourcing of animals shall be strictly adhered to;

• Only animals rescued and/or conflict animals from the Tiger Reserve or from the same landscape should be housed in the Tiger Safaris;

• 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;

• Tiger Safari should be under the management control of the Field Director of the concerned Tiger Reserve with supervision of the Chief Wildlife Warden;

• Earnings should be ploughed back through the concerned Tiger Conservation Foundations;

• Design considerations should be such that there is no scope for interaction between in-situ and ex-situ populations;

• Enclosure design must be approved by the CZA (Central Zoo Authority);

• Carrying capacity norms should be developed;

• Solar/Hybrid/Electric vehicles to be promoted and number of vehicles also must be regulated; and

• Strict Zero Discharge of waste water to be permitted from safaris.

Proper Human Resource Development and Management

The Court directed the MoEF&CC (Ministry of Environment, Forest and Climate Change) and CEC (Central Empowered Committee) to jointly set up a Special Cell to review and assess staffing patterns and cadre requirements in all Tiger Reserves and this exercise shall be completed in a time-bound manner, no later than within 1 year.

“After this exercise is completed, State Governments will take steps to fill in all the vacancies in various cadres in accordance with this exercise conducted by this Special Cell, in a time-bound manner. Special care must be taken to avoid outsourcing of core patrolling roles and scientific posts, and other such jobs which are integral to management of Tiger Reserves”, it added.

Timely and adequate funding support

The Court further directed the MoEF&CC, the NTCA and the CEC to jointly come out with a policy framework on funding for tiger reserves.

Regulation of Religious Tourism

The Court observed that it has come across various instances wherein the sites for pilgrimage are situated within the Tiger Reserves and also the grievance that on account of huge influx of devotees, there is large disturbance to the wildlife.

“It is noticed that hundreds of people ply within the core areas on account of such pilgrimage. In order to regulate such disturbances, we find that a balanced approach needs to be adopted balancing the concerns of the wild as well as religious sentiments of the devotees. We are informed that Sariska Tiger Reserve and some other reserves have issued certain guidelines so as to regulate the movement of devotees in the core areas. We find that similar steps are required to be taken into other Tigers Reserves wherever the sites of pilgrimage are situated”, it remarked.

The Court, therefore, 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 within a period of 6 months.

Conclusion

The Court also clarified that such directions and recommendations would be made applicable to all the Tiger Reserves and the State would be at liberty to make minor modifications in the recommendations made in consultation with the Wildlife Institute of India and NTCA.

“We, therefore, direct 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”, it concluded and directed.

Accordingly, the Apex Court issued the necessary directions.

Cause Title- In Re: Corbett (Neutral Citation: 2025 INSC 1325)

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