Corbett Tiger Reserve – Illegal construction and tree felling – Establishment of Tiger Safari at Pakhrau – Directions issued earlier in judgment dated 06-03-2024 – Expert Committee constituted pursuant thereto – Committee report submitted – Recommendations accepted by Supreme Court – Held, Tiger Safaris strictly prohibited in core/critical tiger habitat; may be permitted only on non-forest or degraded forest land in buffer areas and not forming part of tiger corridors; only injured/conflict/orphaned tigers from same landscape may be housed; mandatory existence of full-fledged rescue and rehabilitation centre.

T.N. Godavarman Thirumulpad … Petitioner
Versus
Union of India & Others … Respondents

In Re : Corbett
I.A. No. 20650 of 2023 (CEC Report No. 3 of 2023)
With I.A. No. 75033 of 2023
And I.A. No. 199355 of 2024 (CEC Report No. 16 of 2024)
In Writ Petition (C) No. 202 of 1995

Citation: 2025 INSC 1325 (Supreme Court of India)
Coram: B.R. Gavai, CJI; Augustine George Masih, J.; A.S. Chandurkar, J.
Date: 17 November 2025
Reportable

HEADNOTES 

Environment Law – Tiger Reserves – Corbett Tiger Reserve – Illegal construction and tree felling – Establishment of Tiger Safari at Pakhrau – Directions issued earlier in judgment dated 06-03-2024 – Expert Committee constituted pursuant thereto – Committee report submitted – Recommendations accepted by Supreme Court – Held, Tiger Safaris strictly prohibited in core/critical tiger habitat; may be permitted only on non-forest or degraded forest land in buffer areas and not forming part of tiger corridors; only injured/conflict/orphaned tigers from same landscape may be housed; mandatory existence of full-fledged rescue and rehabilitation centre.

Environment Law – Eco-Sensitive Zones (ESZ) – Tiger Reserves – Directions – Held, all States directed to notify ESZs around all Tiger Reserves within 1 year; ESZ to include buffer and fringe areas; restrictions of MoEF&CC Notification 09-02-2011 applicable in full, including ban on mining within 1 km of critical habitat/buffer/ESZ.

Forest Law – Restoration – Corbett Tiger Reserve – Ecological restoration – Expert Committee quantified damage (~Rs. 29.8 crores) – State of Uttarakhand directed to undertake full restoration under CEC supervision irrespective of dispute over quantum – Restoration plan to be submitted in 2 months; demolition of unauthorised structures within 3 months; compliance affidavit within 1 year.

Wildlife Conservation – Pan-India directions – TCPs/Steering Committees – Human-wildlife conflict – Wildlife crime control – Green infrastructure – Religious tourism management – Directions issued to all States, NTCA, MoEF&CC and CEC with strict timelines.

Criminal Law – CBI investigation – Illegal activities in Corbett – CBI filed final report/chargesheet under IPC, PC Act, Forest Act, Forest Conservation Act, Wildlife Protection Act – Directions to CBI concluded.

FACTS OF THE CASE 

1. By judgment dated 6 March 2024, the Supreme Court considered illegal construction and felling of trees in the Corbett Tiger Reserve, particularly relating to the Tiger Safari at Pakhrau.

2. The Court constituted an Expert Committee to:

   • recommend restoration measures,

   • assess and quantify ecological damage,

   • identify officials responsible, and

   • recommend guidelines for Tiger Safaris, resorts, noise regulation, tourism, and buffer zone governance.

3. The Expert Committee was constituted by MoEF&CC Office Memorandum dated 15 March 2024, and consisted of representatives of NTCA, WII, CEC, and MoEF&CC, later co-opting former NTCA and CZA officials.

4. The Committee held meetings, conducted a field visit, examined documents and reports, and submitted a comprehensive Report with:

   • specific recommendations for Corbett, and

   • general pan-India recommendations on Tiger Safaris, ESZs, TCPs, human-resource, funding, wildlife crime, tourism, and religious movement inside reserves.

5. Meanwhile, pursuant to directions of 06-03-2024:

   • CBI conducted investigation, filed chargesheet under IPC, Prevention of Corruption Act, Forest Act, FCA 1980, and Wildlife Protection Act; CBI directions were disposed of on 29-05-2025.

   • State of Uttarakhand initiated disciplinary proceedings; Court expressed dissatisfaction with slow progress.

FINDINGS OF THE COURT

The Supreme Court, after considering the Expert Committee Report, held:

1. Restitution and ecological restoration must guide the Court’s approach, consistent with Article 21, 48A, 51A(g) of the Constitution, CBD 1992 (Art. 8), and established jurisprudence (Indian Council for Enviro-Legal Action, S. Jagannath, Bajri Lease LoI Holders).

2. The Court accepted the Expert Committee’s scientific and regulatory findings, subject to minor modifications.

3. Tiger Safari Regulation Findings:

   • Tiger Safaris cannot be permitted in core/critical tiger habitat.

   • May be established only on non-forest or degraded forest land in buffer area and not in tiger corridors.

   • Only injured/conflict/orphaned tigers from same landscape may be housed.

   • A fully functional Rescue and Rehabilitation Centre is mandatory.

4. ESZ Findings:

   • ESZs must extend at least to buffer & fringe areas.

   • ESZ restrictions under 09-02-2011 Notification must apply in full.

5. Corbett-specific Findings:

   • Restoration is mandatory and must occur under CEC supervision.

   • The quantification of ecological damage (~Rs. 29.8 crores) by Expert Committee noted; Court declined to re-examine tree-felling numbers due to pending criminal trial but directed complete restoration.

6. Pan-India Tiger Reserve Governance Findings:

   • TCPs are missing or not updated in many states — Court mandated immediate preparation.

   • Steering Committees not meeting regularly — Court directed strict compliance.

   • Human resource deficits, outsourcing, lack of technical cadres, absence of welfare measures for frontline forest staff require correction.

   • Tourism is inadequately regulated; must follow eco-tourism principles & NTCA guidelines; eliminate night tourism.

   • Religious tourism requires regulation to balance wildlife protection with devotees’ rights.

FINAL DECISION / DIRECTIONS OF THE COURT

A. CORBETT TIGER RESERVE

1. Restoration Plan: State of Uttarakhand (CWW) to submit complete restoration plan within 2 months.

2. Demolition: Begin clearing/demolition of unauthorised construction within 3 months.

3. Monitoring: CEC to supervise and monitor restoration; Field Director to report periodically.

4. Affidavit: Compliance affidavit to be filed within 1 year.

5. Species: Only native and indigenous species to be used in afforestation; no alien species.

6. Cost Recovery: After disciplinary proceedings, State may recover proportionate costs from errant officers.

B. TIGER SAFARIS (PAN-INDIA)

1. Prohibited in Core: No Tiger Safari in core/critical tiger habitat.

2. Permitted Only: on non-forest land or degraded forest land in buffer, not forming part of corridor.

3. Animal Sourcing: Only injured, conflict, or orphaned tigers from same reserve/landscape.

4. Rescue Centre: Mandatory rescue & rehabilitation centre adjoining Safari.

5. Management: Field Director + CWW supervision.

6. CZA Approval: Mandatory for enclosure design.

7. Zero wastewater discharge, carrying capacity norms, electric/hybrid vehicles only.

C. ESZ NOTIFICATION (PAN-INDIA)

• All States must notify ESZs around all Tiger Reserves within 1 year.

• ESZ must include buffer & fringe areas.

• All restrictions of 09-02-2011 Notification applicable.

D. ACTIVITIES IN BUFFER/FRINGE AREAS

• Prohibited: mining, sawmills, polluting industry, major hydro projects, exotics, hazardous substances, drones <300m, etc.

• Regulated: hotels/resorts per TCP; groundwater use per plan; road widening; fencing; night vehicular movement (regulated).

• TCP must demarcate tourism zones; eco-friendly tourism permitted only on non-forest land.

E. TOURISM & RESORTS

• No mass tourism; only eco-tourism.

• New eco-resorts allowed only in buffer, not in corridors.

• Homestays encouraged.

• Zero-waste mandatory.

• No mobile phones in tourism zones of core.

• Complete ban on night tourism.

• Strict vehicular carrying capacity.

F. NOISE REGULATION

• Entire Tiger Reserve + ESZs to be notified as Silence Zones within 3 months.

• Same for other protected areas in the State.

G. GOVERNANCE / TCPs

• All States to delineate core & buffer within 6 months.

• All States to prepare TCPs within 3–6 months.

• Steering Committees to be constituted in 2 months and meet twice yearly.

• NTCA to monitor compliance.

H. HUMAN RESOURCE REFORMS

• MoEF&CC + CEC to form Special Cell for staffing norms — complete in 1 year.

• States to fill all vacancies accordingly.

• No outsourcing of core forest functions.

• Create cadres of veterinarians, wildlife biologists, sociologists.

• Improve allowances, insurance, ex-gratia, housing, medical care—comparable to paramilitary norms.

• Enhance camp infrastructure, safety, and amenities.

I. FUNDING

• MoEF&CC + NTCA + CEC to frame Funding Policy Framework for tiger reserves within 6 months.

• Tiger Conservation Foundations to receive revenue directly.

J. HUMAN–WILDLIFE CONFLICT

• NTCA to frame Model Guidelines in 6 months; States to implement in 6 months thereafter.

• Ex-gratia of Rs. 10 lakh for human death to be granted by all States.

K. GREEN INFRASTRUCTURE

• Avoid infrastructure in wildlife forests wherever possible.

• Upload all tiger reserve/corridor/ESZ data on Gati Shakti portal.

• Transmission lines must use insulated/bunched/underground cabling where feasible.

L. RELIGIOUS TOURISM

• Regulate pedestrian & vehicular movement; allow only electric/CNG vehicles.

• No new construction; restrict arrangements to pre-notification limits.

• Cooking prohibited during mass feasts except solar-based preparation of small prasad quantities.