Supreme Court Orders Independent Scientific Assessment Before Any Further Translocation of Deer from A.N. Jha Deer Park

A bench of Justices Vikram Nath and Sandeep Mehta heard special leave petitions brought by New Delhi Nature Society challenging two orders of the Delhi High Court that dealt with the proposed translocation of hundreds of spotted deer from the A.N. Jha Deer Park, Hauz Khas, and the dismissal of a recall application. The petitions raised questions of non-compliance with the Wild Life (Protection) Act, Central Zoo Authority (CZA) norms and IUCN translocation guidelines, and alleged cruelty and procedural lapses in the translocation exercise to reserves in Rajasthan and within the National Capital Territory.

The Court directed an independent, expert assessment before any further removals and stayed additional translocations until further orders. It appointed the Central Empowered Committee (CEC) to carry out an on-ground survey of the Deer Park and the release sites and to file detailed reports within eight weeks, and it required the CEC to prepare a comprehensive roadmap for any future translocation addressing tagging, veterinary protocols, habitat suitability and post-release monitoring. The Court noted serious management deficiencies at the Deer Park and significant gaps in documentation and monitoring of already translocated animals, and it emphasised institutional accountability and scientific rigour. The Court, in its reasoning, observed: “Given the competing claims and the absence of a verified factual foundation regarding (i) the actual number of deer presently in the Deer Park, (ii) the number of deer translocated and surviving at the release sites, and (iii) the ecological viability of further translocation of deer, this Court is of the view that an independent, scientifically-grounded assessment is essential before any further steps can be permitted. In our opinion, the Central Empowered Committee (CEC), constituted by this Court [now working under a Statute, namely, Environment (Protection) Act, 1986] vested with expertise in forest-wildlife governance, is best placed to undertake such an evaluation. A comprehensive assessment is required not only to ascertain compliance with statutory norms but also to restore confidence in the decision-making process and ensure that any future translocation conforms strictly to the ethical, ecological, and legal standards binding upon all agencies.” The Court also ordered that “no additional translocation of deer from A.N. Jha Deer Park shall be carried out by the respondents or any other authority” until further orders.

Background The dispute arose from DDA’s proposal to translocate a large population of chital (spotted deer) from the 10.97-acre A.N. Jha Deer Park, an urban mini-zoo within Hauz Khas Park, citing overcrowding and management incapacity. The CZA cancelled the Park’s recognition in June 2023 and approved translocation in a 70:30 ratio to Rajasthan reserves and Asola Bhatti Sanctuary, after which the New Delhi Nature Society filed a public interest writ in the Delhi High Court challenging the CZA order and seeking protections for vulnerable animals. The High Court granted an interim stay in December 2023, and thereafter, following an affidavit by DDA undertaking to retain about two dozen deer and to seek CZA approvals, it disposed of the petition on 19 July 2024 allowing resumption in terms of that affidavit. A recall application was dismissed on 24 January 2025. Meanwhile, 261 deer had already been translocated to Rajasthan; concerns about mortality, overcrowded transport, absence of tagging or post-release monitoring, and purported release into predator-bearing reserves prompted further litigation in this Court.

Before the Supreme Court, the petitioner alleged translocation of pregnant and juvenile deer, overcrowding in vehicles, absence of veterinary supervision, lack of habitat suitability studies and failures of post-release monitoring in violation of CZA and IUCN guidelines. The DDA maintained that the moves responded to an unsustainable population, that translocations used recognised methods and were undertaken with Rajasthan Forest Department assistance, and that routine veterinary care continued in the Park. After examining affidavits and field reports, the Court found prima facie deficiencies in managerial capacity, procedural safeguards and documentation, and held that scientific and independent verification was required to determine (i) the present Deer Park population, (ii) the number and survival of translocated deer, and (iii) ecological viability of further relocations. Recalling constitutional mandates, the Court observed that “Articles 48A and 51A(g) … and Article 21” informed its intervention. It granted liberty to the petitioner to move the Court if the CEC’s inspection disclosed deaths or severe ill‑treatment, directed DDA to place certain land‑use records on file, restrained commercial events in the Park, and listed the matter for receipt of reports on 17 March 2026.

Case Details: Case No.: 2025 INSC 1358 Case Title: New Delhi Nature Society through Verhaen Khanna v. Director Horticulture, Delhi Development Authority & Ors. Appearances: For the Petitioner(s): [Not indicated in the judgment] For the Respondent(s): [Not indicated in the judgment]