Supreme Court Mandates Notification of 31,468.25 ha Saranda Forest as Wildlife Sanctuary Under Wildlife Protection Act (2025)

Case Name: In Re: Saranda Wildlife Sanctuary (Proceedings in Writ Petition (Civil) No. 202 of 1995 – T.N. Godavarman Thirumulpad)
Citation: 2025 INSC 1311
Date of Judgment/Order: 13 November 2025
Bench: Hon’ble Chief Justice B.R. Gavai, K. Vinod Chandran

Held: The Supreme Court held that the State of Jharkhand is statutorily and constitutionally bound to notify the entire 31,468.25 hectares of Saranda Forest—already recognized as a Game Sanctuary under the 1968 Notification—as a Wildlife Sanctuary under Section 26A of the Wildlife Protection Act, 1972. The Court rejected Jharkhand’s subsequent attempt to reduce the notified area to 24,941.64 hectares, finding the State’s shifting positions unjustified, inconsistent, and in contempt of earlier orders. Relying heavily on constitutional duties under Articles 48A and 51A(g), the Wildlife Protection Act framework, the National Forest Policy, and the Wildlife Institute of India’s detailed 2025 report establishing high ecological value, the Court mandated full protection of the originally identified habitat and held that no impediment existed for issuing the notification.

Summary: The proceedings arose from repeated delays and contradictory affidavits filed by the State of Jharkhand regarding the declaration of the Saranda Forest area as a Wildlife Sanctuary. Although multiple affidavits from 2024–2025 confirmed that 31,468.25 hectares comprising 126 compartments had no mining activity and possessed significant ecological and wildlife importance, the State attempted to alter its position by constituting committees, citing confusion, and proposing a reduced sanctuary area. The Court found this conduct evasive and contrary to earlier commitments made to the Court. The Wildlife Institute of India’s 2025 report confirmed that the Saranda Forest constitutes a vital elephant corridor, a biodiversity hotspot with rich mammalian, avian, and herpetofaunal presence, and an ecologically critical zone requiring statutory protection. The Court reiterated that under Section 26A of the Wildlife Protection Act and the constitutional mandate to safeguard forests and wildlife, the State cannot dilute protection obligations nor justify reduction of ecologically significant areas based on administrative or mining-related considerations.

Decision: The Supreme Court directed the State of Jharkhand to file an undertaking within one week and proceed to notify the full 31,468.25 hectares as the Saranda Wildlife Sanctuary, as earlier assured to the Court. The Court clarified that if the State intends to include any additional area, it is free to do so through the statutory process, but it cannot reduce the already identified area. The Court warned that failure to comply would invite a mandamus compelling notification and potential contempt action against senior officials. The matter was listed for monitoring compliance.