Supreme Court Strengthens Wildlife Protection: States Directed to Notify ESZs and Regulate Tiger Safaris

November 19, 2025by Primelegal Team

INTRODUCTION

The Hon’ble Supreme Court of India issued an extensive set of directions aimed at strengthening tiger conservation, restoring ecological damage, and regulating tourism and infrastructure activities around Tiger Reserves particularly the Corbett Tiger Reserve in Uttarakhand. Through the present judgement, the Court reiterated the constitutional commitment to the environmental protection under Articles 48A and 51A(g) and clarified the minimum standards of ecological safeguards applicable to core, buffer, and fringe areas of Tiger Reserves across the country. The ruling also existed with statutory mechanisms under the Wildlife (Protection) Act 1972, Forest (Conservation) Act 1980, Environment (Protection) Act 1986 and the NTCA Guidelines, creating a uniform national framework for tiger habitat protection and responsible eco-tourism.

BACKGROUND

The case originated from extensive illegal construction, misuse of forest land, and ecologically damaging activities within the Jim Corbett Tiger Reserve. The Apex Court appointed an Expert Committee which found large – scale violations including non – forest use land and breaches of the NTCA guidelines. The judgment addresses three interlinked concerns, they are as follows:

  1. Restoration of the Corbett landscape 
  2. Regulation of Tiger Safaris
  3. The need for a uniform, enforceable framework governing activities in buffer and fringe zones of Tiger Reserves nationwide.

By integrating ecological science, statutory protections and administrative accountability, the Court delivered one of the most detailed tiger – conservation rulings in recent years.

KEY POINTS

1.Ecological Restoration of Corbett Tiger Reserve

The Court directed the State of Uttarakhand to undertake ecological restoration of the Corbett landscape by submitting a comprehensive restoration plan within two months and removing all unauthorised constructions within three months. The Central Empowered Committee, with the Field Director was given responsibility of overseeing the entire process and to submit progress reports on a regular basis. 

2. Strict Framework for Tiger Safaris

Tiger Safaris were completely prohibited in core or critical tiger habitats. They may only be set on non – forest or degraded forest land in buffer areas, and never inside tiger corridors. Every Safari must be linked to a rescue and rehabilitation centre and must follow NTCA guidelines, including CZA – approved enclosure design, zero wastewater discharge, and use of eco – friendly vehicles under the control of the Field Director.

3. Mandatory Notification of Eco-Sensitive Zones (ESZs)

All States were directed to notify ESZs around Tiger Reserves within one year, covering at least the buffer or fringe areas. These ESZs must carry the minimum protections under the 2011 Notification, including a complete ban on mining within one kilometre. The Court approved MoEF&CC’s 2018 guidelines and reiterated that all listed prohibited and regulated activities apply uniformly to Tiger Reserve buffer zones.

4. Regulation of Tourism and Resort Activities

The Court held eco – tourism must remain low – impact and cannot resemble mass tourism. Eco – friendly tourist facilities may be established only in buffer zones, not wildlife corridors, with preference given to homestays and community – run ventures. Night tourism in core areas is fully banned, vehicle limits must be enforced, and the entire Reserve including ESZ must be declared a “Silence Zone” under the Noise Pollution Rules.

5. Strengthening of Tiger Conservation Governance

States must notify core and buffer areas and prepare Tiger Conservation Plans within six months. Steering Committees must meet at least twice a year, and NCTA will monitor compliance with tourism and conservation guidelines. The Court also called for Model Guidelines on human wildlife conflict management and directed States to uniformly provide ₹10 lakh ex – gratia compensation for such incidents.

6. Regulation of Infrastructure and Funding Mechanisms

The Court mandated that transmission lines passing through Tiger Reserves should be underground. It further directed that the Funding under Project Tiger must be in accordance with approved Tiger Conservation Plans, and CAMPA funds should support voluntary relocation of villages from sensitive zones. Additionally the MoEF&CC, NTCA and CEC must jointly frame a funding policy within six months, and all Tiger Reserve data must be uploaded to the Gati Shakti portal to aid national-level planning.

RECENT DEVELOPMENTS

The judgments build on a growing body of environment jurisprudence emphasising ecosystem integrity, wildlife corridors, and conservation – centric development. In the case of T.N. Godavarman Thirumulpad v. Union of India [2012 (3) SCC 277] the Supreme Court’s long – running forest litigation set the foundation for regulating diversion of forest land, protection of wildlife habitats, and oversight through the CEC. Similarly in another case of Centre for Environmental Law, WWF v. Union of India [(2013) 8 SCC 234], The Court recognised the importance of inviolate spaces for tiger conservation and upheld relocation of villages from core areas while balancing rights of forest dwellers. These precedents show the judiciary’s consistent approach towards ecological preservation outweighs commercial or infrastructural considerations in sensitive landscapes.

CONCLUSION

The Hon’ble Supreme Court’s judgment represents a transformative moment in tiger conservation jurisdiction in India. By addressing ecological restoration, regulating tourism, harmonising ESZ norms, strengthening administration and mandating scientific management across all Tiger Reserves, the Court has created a uniform national framework for safeguarding tiger habitats. 

“PRIME LEGAL is a full-service law firm that has won a National Award and has more than 20 years of experience in an array of sectors and practice areas. Prime legal falls into the category of best law firm, best lawyer, best family lawyer, best divorce lawyer, best divorce law firm, best criminal lawyer, best criminal law firm, best consumer lawyer, best civil lawyer.”

WRITTEN BY- SUSMITA ROYCHOWDHURY