Supreme Court Approves Deer Translocation From A.N. Jha Deer Park To Rajasthan; Directs Statutory Framework For Wildlife Translocation

The Court, while accepting the findings of the Central Empowered Committee, observed that continued retention of a large deer population in the park was neither sustainable nor permissible in law.

The Court was hearing Special Leave Petitions challenging orders of the Delhi High Court, which had permitted relocation of deer based on a policy decision of the Delhi Development Authority, citing ecological constraints and management concerns.

A Bench of Justice Vikram Nath and Justice Sandeep Mehta observed: “In substance, the report of the Central Empowered Committee affirms the decision to translocate the deer to appropriate wildlife reserves. It notes that the Central Zoo Authority, in exercise of its powers under Section 38H(6) of the Wild Life (Protection) Act, 1972, has cancelled the recognition of A.N. Jha Deer Park as a “mini zoo”, on account of persistent non-compliance with zoo management norms, failure to regulate the deer population, and the expiry of its licence in August 2021. Under such circumstances, the continued retention of the deer at the said park is impermissible in law, there being no duly recognised statutory authority to ensure their proper management. The report further records that the deer population has increased exponentially due to the absence of effective population control and sterilisation measures, thereby necessitating their translocation”.

Background

The matter arose from the decision to translocate hundreds of deer from A.N. Jha Deer Park to tiger reserves in Rajasthan and other locations. The petitioner opposed the relocation, contending that adequate land was available within or around the park to accommodate the increased population and that translocation would expose the animals to ecological stress and survival risks.

Earlier, the Delhi High Court had accepted a proposal by the Delhi Development Authority to retain a limited number of deer within the park while relocating the surplus population to forest areas. This decision was based on concerns relating to carrying capacity, poaching risks, and infrastructural limitations.

The matter was subsequently examined by the Central Empowered Committee, which conducted a comprehensive study and submitted a detailed report addressing ecological capacity, animal welfare, and long-term management strategies.

Court’s Observation

The Court undertook a detailed evaluation of the Central Empowered Committee’s report and noted that the existing deer enclosure at A.N. Jha Deer Park had a scientifically assessed carrying capacity of approximately 38 deer, significantly lower than the existing population. It was observed that continued overcrowding, in the absence of population control measures, would adversely affect animal welfare and ecological balance.

The Court further noted that the Central Zoo Authority had cancelled the recognition of the Deer Park as a “mini zoo” due to non-compliance with statutory norms and failure to regulate the deer population. It held that in the absence of valid recognition and adequate infrastructure, continued retention of deer in such conditions was impermissible.

Addressing the petitioner’s contention regarding the expansion of habitat within Delhi, the Court accepted the CEC’s finding that intra-park or inter-park relocation within urban spaces would not resolve the underlying ecological issues. It was observed that such relocation would merely shift the problem without addressing deficiencies in habitat quality, veterinary infrastructure, and population management.

The Court placed reliance on the expert opinion that scientifically managed translocation to suitable wild habitats is a sustainable and ecologically sound solution. It noted that such translocation, when carried out in accordance with established guidelines, is “scientifically justified, ethically defensible, and consistent with the applicable national statutory framework as well as internationally accepted conservation norms.”

The Court also emphasised that natural predation of translocated deer by predators in wildlife reserves is an integral ecological process and does not render the translocation exercise invalid. It is observed that such processes contribute to maintaining ecological balance, regulating population growth, and strengthening natural habitats.

At the same time, the Court noted deficiencies in earlier translocation efforts, observing that relocation had been carried out in a manner not aligned with scientific protocols, particularly in relation to acclimatisation and animal welfare. It therefore stressed the need for a structured and scientifically informed framework governing future translocations.

The Court remarked: “The draft comprehensive guidelines prepared by the Central Empowered Committee for future wildlife translocations, incorporating scientific methodology, identification and tagging protocols, procedural safeguards, transportation and veterinary requirements, ecological feasibility assessment, and a post-release monitoring framework in conformity with the applicable statutory regime and IUCN Guidelines, shall be examined by the Ministry of Environment, Forest and Climate Change and implemented, with such modifications as may be deemed appropriate, within a period of six months. These guidelines deserve to be, and shall be, imparted statutory status. A compliance report shall be submitted to this Court in respect of this direction”.

Additionally, the Court directed that a limited number of deer may be retained at A.N. Jha Deer Park, provided that the requisite approvals from the Central Zoo Authority are obtained and compliance with prescribed standards is ensured, including maintaining an optimal population and infrastructure.

Conclusion

The Supreme Court upheld the decision permitting translocation of deer from A.N. Jha Deer Park and accepted the recommendations of the Central Empowered Committee in their entirety.

The Court directed time-bound relocation of surplus deer under expert supervision, permitted conditional retention of a limited population subject to statutory compliance, and mandated formulation of a comprehensive statutory framework governing wildlife translocation.

Cause Title: New Delhi Nature Society v. Director Horticulture, DDA & Ors. (Neutral Citation: 2026 INSC 419

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