SC Allows Shifting Of Deer From Delhi To Wildlife Reserves In Rajasthan

The Supreme Court has upheld the relocation of deer from A.N. Jha Deer Park to wildlife reserves in Rajasthan, noting that the park lacks the necessary carrying capacity to support such a large deer population.

A bench of Justice Vikram Nath and Justice Sandeep Mehta heard Special Leave Petitions challenging the translocation of hundreds of deer from A.N. Jha Deer Park, Hauz Khas, New Delhi and the related administrative decisions concerning the Park and its recognition, and considered whether the animals should be retained in the urban enclosure or translocated to tiger reserves.

The Court allowed the expert findings and directed implementation of the Central Empowered Committee's recommendations for a time-bound, scientifically managed translocation programme while permitting regulated retention of a limited number of deer subject to statutory approval. The Court recorded that the Central Zoo Authority had cancelled recognition of the Park and that local authorities lacked resources and capacity to sustainably manage the entire population, and therefore accepted the CEC's roadmap for translocation and improved on-site management.

The Court has following directions:

“A. All the recommendations contained in the report of the Central Empowered Committee, quoted supra, are hereby accepted.

B. The concerned authorities are directed to take necessary steps for the relocation of the deer from A.N. Jha Deer Park in a time-bound manner, under the supervision of the Central Empowered Committee, and in strict adherence to the draft guidelines on Animal Translocation as framed by the Central Empowered Committee.

C. It is directed that retention of up to 38 deer at A.N. Jha Deer Park as recommended by the Central Empowered Committee shall be permissible only subject to the grant of requisite approvals and clearances by the Central Zoo Authority. The DDA shall ensure that it develops and upgrades the necessary logistical capacity, infrastructure, and adequately trained human resources for the upkeep and management of the said deer population. The DDA shall ensure that the retained population has an optimal sex ratio of 15 males to 23 females. Such retention shall be effected only upon and in accordance with the permissions granted by the Central Zoo Authority. In case, the DDA is unable to attain these mandatory compliances, appropriate application may be moved in this Court for clarification/further directions.

D. The concerned authorities shall take all necessary and proactive steps to comply with the other recommendations made by the Central Empowered Committee.

E. In view of the fact that the area comprising the A.N. Jha Deer Park, Hauz Khas, New Delhi stands declared as a protected forest, it is hereby directed that, under no circumstances, shall the nature or status of the said area be altered, and the same shall continue to be maintained as a protected forest at all times in the future.

 F. 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.

G. The Registry is directed to forthwith transmit a copy of this order, along with the report of the Central Empowered Committee, to the Ministry of Environment, Forest and Climate Change for necessary compliance.”

 Background:
 

The petitions arose from the translocation exercise that moved deer from A.N. Jha Deer Park to Mukundara Hills Tiger Reserve and Ramgarh Vishdhari Tiger Reserve, following an earlier order that constrained further translocations until a CEC survey. The Court considered a 428-page CEC report and annexed draft Guidelines on Animal Translocation which assessed carrying capacity, habitat suitability and post-release protocols and recommended that the enclosure could sustainably retain only 38 spotted deer if recognised and regulated by the Central Zoo Authority; the surplus was to be translocated under strict scientific protocols. The Court noted that the Central Zoo Authority had exercised its statutory power under Section 38H(6) of the Wild Life (Protection) Act, 1972 to cancel recognition of the Park as a mini zoo, a fact that weighed heavily in determining that local retention of the entire population was impermissible in law in the absence of a duly recognised statutory management authority. The petitioner argued for intra-park expansion and alternative urban sites, but the CEC had found that relocation within Delhi without substantive habitat and management improvements would only replicate welfare and ecological problems, and that properly planned translocation to ecologically suitable wild landscapes constituted a rational and sustainable management response.

The Court accepted the CEC's recommendations in full, directed the concerned authorities to implement the roadmap and the draft translocation guidelines in strict conformity with statutory requirements and IUCN norms, and ordered that the Ministry of Environment, Forest and Climate Change examine and implement the draft guidelines within six months so that "these guidelines deserve to be, and shall be, imparted statutory status." The Court permitted retention of up to 38 deer at A.N. Jha Deer Park only upon formal recognition and full compliance with the Central Zoo Authority's conditions and required the DDA to develop requisite infrastructure and fill sanctioned posts; in default, the DDA was to seek further clarification from this Court. The Court also directed that the area remain a protected forest and sought a compliance report on issuance of statutory guidelines within six months, listing the matter for receiving the compliance report on 19th January, 2027.

Case Details:
Case No.: SPECIAL LEAVE PETITION (CIVIL) NO(S). 13374-13375 OF 2025
NeutralCitation: 2026 INSC 419
Case Title: NEW DELHI NATURE SOCIETY THROUGH VERHAEN KHANNA v. DIRECTOR HORTICULTURE DDA & ORS.

Source: 2026 CaseBase(SC) 368