Wildlife Management Can’t Be Approached As Administrative Convenience: Supreme Court Halts Translocation Of Deer From A.N. Jha Deer Park

The Supreme Court has halted the translocation of deer from the Delhi’s Aditya Nath Jha Deer Park, saying that wildlife management cannot be approached as a matter of administrative convenience.

The Court was hearing Special Leave Petitions (SLPs) concerning the proposed translocation of hundreds of deer from the A.N. Jha Deer Park in Hauz Khas, New Delhi, an urban green sanctuary for captive deer, to different wildlife sanctuaries/Tiger reserves in the State of Rajasthan as well as within New Delhi.

The two-Judge Bench comprising Justice Vikram Nath and Justice Sandeep Mehta remarked, “Articles 48A and 51A(g) of the Constitution of India embody a collective commitment to safeguard forests and wildlife and to act with compassion for all living beings, while Article 21 has been judicially recognized as encompassing the right to a clean and ecologically balanced environment. The concerns arising from overcrowding, resource constraints, and managerial lapses at the A.N. Jha Deer Park, coupled with questions regarding the scientific rigour of past translocation efforts, underscore that wildlife management cannot be approached as a matter of administrative convenience. It must be anchored in scientific assessment, ecological prudence, and fidelity to constitutional values.”

The Bench said that continued retention of entirety of the remaining population of deer at the Deer Park would be contrary to the very principles of animal welfare enshrined under domestic laws and international conservation protocols.

AOR Rukhsana Choudhury represented the Petitioner, while ASG Aishwarya Bhati represented the Respondents.

Case Background

In 1968, the Delhi Development Authority (DDA) had established the Deer Park namely A.N. Jha Deer Park within the larger green expanse of Hauz Khas Park, South Delhi. The total green area measures approximately 142.30 hectares, of which 10.26 acres were originally earmarked for the deer enclosure, subsequently increased to 10.97 acres by the year 2021. The DDA introduced a population of chital/spotted deer (Axis axis) brought from the State of Uttarakhand, making the Deer Park, apart from the Delhi Zoo (a.k.a. National Zoological Park, New Delhi), the only urban setting in the capital city where the public could view spotted deer in a semi-natural environment. Over the years, the Deer Park has evolved into a significant ecological and recreational space, attracting not only visitors but also a variety of small mammals, birds, reptiles, insects, and nocturnal species.

The translocation sought to be undertaken ostensibly on the pretext of overcrowding, was alleged to be in contravention of the norms established by the Central Zoo Authority, Ministry of Environment, Forest & Climate Change, Government of India, guidelines framed under the Wild Life (Protection) Act, 1972, as well as the International Union for Conservation of Nature Guidelines for Reintroductions and Other Conservation Translocations (ICUN Guidelines). The Petitioner i.e., New Delhi Nature Society had filed a Public Interest Litigation (PIL) before the Delhi High Court, challenging the proposal for translocation of the deer mooted by the authorities, which was disposed of the Order dated July 19, 2024. A subsequent Application seeking the recall of the Order was dismissed by the High Court on January 24, 2025. These two Orders were the subject matter of challenge in the SLPs before the Apex Court.

Court’s Observations

The Supreme Court in the aforesaid background of the case, observed, “Allegations that vulnerable categories of deer, including pregnant females, juveniles, and antlered males, were transported; that overcrowding occurred inside vehicles; that post release monitoring mechanisms were inadequate; and that the chosen release sites lacked assured habitat suitability, are all matters that strike at the core of scientific translocation practice. The IUCN Guidelines emphasize that any relocation of captive wildlife must be supported by ecological feasibility studies, veterinary screening, tagging or identification processes, and structured post release surveillance.”

The Court added that these safeguards appear, prima facie, to have been applied in a perfunctory or incomplete manner, thereby undermining the legitimacy of the exercise and the welfare of the animals involved.

“It is evident from the record that the translocation protocol and best practices incorporated in the guidelines issued by the Central Zoo Authority and IUCN Guidelines were not adhered to during the translocation of deer from Deer Park to Ramgarh Vishdhari Tiger Reserve and Mukundra Hills Tiger Reserve in the State of Rajasthan. There is no documentary evidence of pre-translocation genetic screening, tagging, tranquilisation protocols, veterinary fitness certification, or behavioural acclimatisation, all of which are internationally recognised preconditions for release”, it noted.

The Court said that no scientific assessment was carried out with respect to the carrying capacity of the recipient sanctuaries in Rajasthan, the predator-prey dynamics, or the impact of introducing semi-captive deer into those ecosystems.

“The translocated deer, many of whom were zoo-bred, and some reportedly pregnant or juvenile, were moved to tiger-bearing sanctuaries, without any indication of whether they possessed the necessary survival skills or ecological fitness. Photographic and field evidence brought on record by the petitioner-Society points to a distressing pattern of negligence. Deer were allegedly loaded into overcrowded trucks, sometimes in groups as large as 40-50, without proper ventilation, padding, or segregation. In one instance, a blue rope used to tie the limbs of a deer was reportedly recovered from the relocation site, raising serious concerns about the use of force and the absence of ethical handling procedures”, it further noted.

The Court was of the opinion that the Central Empowered Committee (CEC), constituted by the Court [now working under a Statute, namely, Environment (Protection) Act, 1986] vested with expertise in forest-wildlife governance, is best placed to undertake an evaluation.

“A comprehensive assessment is required not only to ascertain compliance with statutory norms but also to restore confidence in the decision-making process and ensure that any future translocation conforms strictly to the ethical, ecological, and legal standards binding upon all agencies”, it added.

Court’s Directions

The Court, therefore, issued the following directions –

A. CEC shall conduct an on-ground survey of A.N. Jha Deer Park and file a detailed report before the Court within eight weeks.

B. The CEC shall further undertake an inspection of the release sites, i.e., Ramgarh Vishdhari Tiger Reserve and Mukundra Hills Tiger Reserve in the State of Rajasthan and file a status report within eight weeks.

C. The CEC shall also prepare a comprehensive roadmap for any future translocation, detailing the scientific methodology, identification and tagging processes, procedural safeguards, transportation protocols, veterinary requirements, ecological feasibility studies, and post-release monitoring framework, in strict conformity with the domestic statutory regime and IUCN Guidelines.

D. All concerned authorities shall extend full cooperation to the CEC, ensuring timely support, information sharing, and access to necessary sites, required for implementing these directions.

E. The DDA shall, within eight weeks, place on record a comprehensive report detailing the past and present status of land formerly designated for deer enclosures, including the unexplained reduction of more than 20 acres reported in the Evaluation Reports.

F. The DDA shall refrain from organizing, permitting, or facilitating any commercial events, private parties, or non-conservation related gatherings within the premises of the A.N. Jha Deer Park or its surrounding ecological buffer zones.

G. Until further Orders, no additional translocation of deer from A.N. Jha Deer Park shall be carried out by the Respondents or any other authority.

Conclusion

Moreover, the Court observed that the deer population at the Deer Park is a reminder that conservation is not merely the relocation of animals but an exercise in stewardship: preserving species, habitats, and the environmental ethos enshrined in our constitutional framework.

“The Court’s intervention is therefore guided by the imperative that decisions affecting wildlife must reinforce the principles of dignity, ecological integrity, and intergenerational equity that lie at the heart of this Court’s environmental jurisprudence”, it concluded.

Accordingly, the Apex Court listed the case on March 17, 2026 for receiving the reports of CEC and the DDA.

Cause Title- New Delhi Nature Society through Verhaen Khanna v. Director Horticulture DDA & Ors. (Neutral Citation: 2025 INSC 1358)

Appearance:

Petitioner: AOR Rukhsana Choudhury, Advocates Amita Singh, and Shumaila.

Respondents: ASG Aishwarya Bhati, AORs Mukesh Kumar Maroria, Nitin Mishra, Gurmeet Singh Makker, Advocates Shreya Jain, Chitrangda Rastravara, Jagdish Chandra, and Mitali Gupta.

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