Supreme Court Directs Jharkhand to Notify Saranda as Wildlife Sanctuary, Excluding Six Mining Compartments

A bench of Chief Justice B.R. Gavai and Justice K. Vinod Chandran heard applications arising from Writ Petition (C) No. 202 of 1995 (In Re: T.N. Godavarman Thirumulpad) dealing with the long-pending proposal to declare the Saranda forest area in West Singhbhum, Jharkhand, as a wildlife sanctuary. The matters before the Court included multiple interlocutory applications filed by environmental activists, intervenors including Steel Authority of India Ltd. (SAIL), and state authorities, challenging delay and seeking directions to complete statutory steps under the Wildlife (Protection) Act, 1972 (WP Act).

The Court directed the State of Jharkhand to notify the area comprising the 126 compartments identified in the 1968 notification as a wildlife sanctuary, subject to exclusion of six compartments (KP-2, KP-10, KP-11, KP-12, KP-13 and KP-14), within three months. The Court found that the State had given inconsistent stands and had “dilly dally[ed]” in processing the proposal despite earlier undertakings. The Court recorded that “it is not in dispute that the said area consists of pristine forest and it is a repository of some of the finest Sal trees in the country.” It further emphasised that tribal and community rights would remain protected under the Forest Rights Act, 2006 (FRA) and that ancillary activities lawful before notification would continue in accordance with statutory provisions. The Court reiterated earlier directions barring mining within national parks, wildlife sanctuaries and within one kilometre of their boundaries.

The Court, in its reasoning, observed: “We, therefore, have no hesitation in saying that in view of the mandate of Articles 48A and 51A(g) of the Constitution, Section 26A of the WP Act and particularly in the light of the report of the WII, the State cannot run away from its duty to declare the extent of 31,468.25 hectares as Saranda Wildlife Sanctuary.”

Background The dispute arose after a 1968 Bihar notification recorded approximately 31,468.25 hectares in the Saranda forest as a Game Sanctuary. In 2020 a petition to the National Green Tribunal (NGT) alleged lack of an Eco‑Sensitive Zone and adverse impact of nearby iron‑ore mining. The NGT, in July 2022, directed the State to consider declaring the area as a sanctuary, observing that the forest “is nevertheless a repository of some of the finest Sal Forest in the country” and required protection.

Despite those directions, the State delayed. Multiple affidavits filed by State officials recorded differing figures and approaches—initially indicating the 1968 notified area and later proposing an expanded area of 57,519.41 hectares based on an interim communication from the Wildlife Institute of India (WII). The WII was directed to examine the proposal; it submitted a report in May 2025 asserting the region’s “immense ecological, biodiversity (floral and faunal), and geomorphological significance” and its role as a wildlife corridor within the Singhbhum Elephant Reserve.

The Chief Justice took strong note of the State’s changing positions and the constitution of an internal committee that delayed finalisation. The Court summoned the Chief Secretary and extracted an undertaking. After hearings where the State cited tribal habitation, infrastructure and mining interests, and where intervenors including SAIL sought protection for operational leases and ancillary infrastructure, the Court examined statutory provisions—Sections 18, 19, 24 and 26A of the WP Act—and the FRA. The Court accepted the WII’s findings, relied on environmental policy documents and the Management Plan for Sustainable Mining (MPSM) and the Justice M.B. Shah Commission findings cautioning against unregulated mining in sensitive forest.

The Court concluded that declaration of the 31,468.25 hectares (subject to limited exclusions of six compartments identified in the MPSM as mining zones) was required. It clarified that the Collector’s powers under Section 24(2)(c) and FRA protections would safeguard individual and community forest rights, and that lawful ancillary activities and existing operational leases would be dealt with under statutory safeguards. The Court also reiterated its earlier pan‑India direction that mining within protected areas and within one kilometre of their boundaries was not permissible. The State was directed to give wide publicity that tribal and community rights would remain protected. Applications by SAIL seeking specific protections were disposed of on the basis that the statutory framework and the Court’s directions addressed their concerns.

Case Details: Case No.: Writ Petition (C) No. 202 of 1995 (IN RE: T.N. GODAVARMAN THIRUMULPAD) Case Title: IN RE: T.N. GODAVARMAN THIRUMULPAD …PETITIONERS VERSUS UNION OF INDIA AND OTHERS …RESPONDENTS Appearances: For the Petitioner(s)/Applicant(s): Ms. Shibani Ghosh (Counsel for Dr. Dayanand Shankar Srivastava / Applicant) For the Respondent(s): Shri Kapil Sibal, Senior Counsel (for State of Jharkhand); Shri Tushar Mehta, Solicitor General of India (appearing for Steel Authority of India Ltd.); Shri K. Parameshwar (Amicus Curiae)