The Supreme Court has granted conditional clearance to the State of Uttar Pradesh for the establishment of its ambitious night safari and zoological park in the Kukrail reserve forest area of Lucknow.

The Bench allowed the state’s application, mandating absolute compliance with the environmental safeguards and terms outlined by the Central Empowered Committee (CEC), the Central Zoo Authority (CZA), and the Ministry of Environment, Forest and Climate Change (MoEFCC).

The Bench of Chief Justice Surya Kant, Justice Joymalya Bagchi and Justice V Mohana ordered, "In view of the fact that the Central Zoo Authority, the Ministry of Environment, Forest and Climate Change, and the CEC have approved and recommended the proposal for the establishment of the night safari and zoological park in the Kukrail forest area, Lucknow, we see no reason to withhold prior approval to the State of Uttar Pradesh in terms of our order dated February 19, 2024...Consequently, the application is allowed. The State of Uttar Pradesh is permitted to proceed with the project, subject to the strict compliance of all conditions imposed by the Central Empowered Committee, the Central Zoo Authority, and the Ministry of Environment, Forest and Climate Change."

The Court directed, "To ensure that these conditions are meticulously complied with, we direct the Member Secretary of the CEC to periodically visit the project site and monitor compliance. Any deviation or breach of the conditions shall be viewed seriously. The CEC shall submit its first status report after visiting the site on or before three months from today. Since the project involves the diversion of reserve forest land, this permission is also subject to the State of Uttar Pradesh obtaining prior permission, if so required, under the Forest Conservation Act or any other applicable law from the Central Government/Union of India."

Senior Advocate Shadan Farasat appeared for the Intervenors, while ASG K.M. Natarajan appeared for the State.

The matter originated from a mandatory directive issued by the apex court on February 19, 2024, which made prior judicial approval compulsory for any new zoo or safari projects across the country. Seeking to implement its ambitious project—envisioned as the first of its kind in India—the Uttar Pradesh government moved an impleadment application along with a plea for project clearance.

Representing the state, ASG K.M. Natarajan submitted that the project had already received statutory clearances from the CZA on January 31, 2025, and the MoEFCC on February 28, 2025.

During the proceedings, counsel appearing for the original intervenors raised concerns regarding commercialization and land diversion within a notified reserve forest. The intervenors also pointed out that the state’s original Detailed Project Report (DPR) included a proposal to relocate the historic, century-old Nawab Wajid Ali Shah Zoological Park from Lucknow city to the new site—a proposal that had drawn public concern.

Addressing the relocation concerns, ASG Natarajan clarified that the state had dropped the plan to shift the 100-year-old zoo, noting that the CEC had categorically vetoed the transfer in its vetting process. "We are not shifting the zoo. The original zoo will remain untouched," the ASG assured the bench.

However, Senior Advocate Shadan Farasat, appearing for the intervenors, raised critical concerns regarding key ambiguities in the project's design. He pointed out that while the CEC had rightly barred the creation of an "adventure zone" within the reserve forest, the state's proposal still contained a separate head for an "amusement park."

He argued that without explicit judicial clarification, the state might exploit this loophole to establish commercial amusement facilities, which would equally damage the ecological integrity of the reserve forest.

Acknowledging this submission, the Court agreed with the logic and explicitly clarified that the restriction on the adventure zone would extend to the amusement park as well, effectively ensuring its exclusion.

According to the project blueprint recorded by the court, the Kukrail forest area is a notified reserve forest measuring a total of 2,027.4 hectares. The State Government intends to establish the night safari and zoological park within a designated area of 855.07 hectares.

The Court recorded the state's undertaking regarding environmental mitigation and said "...It has been explained that 71% of the designated area (approximately 610.34 acres) shall be maintained as green cover, and dedicated efforts shall be made to minimize tree felling through translocation. It is also submitted that invasive species will be replaced by native species for the eco-restoration of the area... The existing zoo area does not serve as a wildlife corridor and does not fall within the vicinity of any protected area."

To prevent any environmental degradation on the ground, the Supreme Court has set up a strict supervisory mechanism, directing the Member Secretary of the CEC to periodically visit the project site and monitor compliance.

Cause Title: Ashok Kumar Sharma, Indian Forest Service (Retd.) v. Union of India & Ors. [W.P.(C) No.1164/2023]

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