Tiger Safaris Not Permitted in Core Habitats; Corbett Restoration and ESZ Notifications Directed

A bench of Chief Justice B.R. Gavai and Justices Augustine George Masih and A.S. Chandurkar heard the consolidated proceedings arising from writ petition (C) No. 202 of 1995 (In Re: Corbett) concerning illegal construction, tree felling and the regulatory framework for Tiger Safaris in Corbett Tiger Reserve. The matter originated from an application by Gaurav Kumar Bansal and involved consideration of the Expert Committee report constituted pursuant to this Court’s judgment dated 6 March 2024, as well as parallel CBI and departmental disciplinary processes.

The Court accepted the Expert Committee’s report and issued comprehensive directions on ecological restoration, regulation of Tiger Safaris and pan‑India measures for tiger reserve management. It emphasised a restitutive approach to environmental damage and reiterated that “Tiger Safari shall not be permitted in the core or a critical tiger habitat area.” The Court, in its reasoning, observed: The Court further directed that Tiger Safaris, if allowed, must be on non‑forest or degraded forest land in the buffer and must be linked with fully operational rescue and rehabilitation centres, with enclosure designs approved by the Central Zoo Authority and strict zero discharge and carrying‑capacity norms.

Background The dispute arose from extensive unauthorized works in the Pakhrau area of Corbett Tiger Reserve to establish a Tiger Safari, alleged illegal felling of trees and construction by forest officials. This Court’s order of 6 March 2024 had preserved existing safaris subject to stricter standards and had directed constitution of an Expert Committee to examine restoration, governance and operational protocols, and to identify officials personally liable. The Expert Committee (constituted by MoEF&CC on 15 March 2024) inspected the site, consulted specialists including IIFM and WII, and submitted recommendations after field visits and meetings.

Parallelly, the CBI completed field investigation and filed a chargesheet under multiple provisions (including Sections 120‑B, 218, 409, 467, 471 IPC; corruption statutes; Indian Forest Act; Forest Conservation Act; and Wildlife Protection Act) against a number of forest officers; the Court recorded that CBI matters had reached a logical end and those applications were disposed of as regards the CBI on 29 May 2025. Disciplinary proceedings against delinquent officers remained pending and States were directed to conclude them expeditiously.

The Expert Committee quantified restoration needs: in‑situ ecological restoration costs at Rs. 4,30,89,110; potential ecological loss at Rs. 22,95,06,306 with net market value of felled timber at Rs. 6,80,00,000, totalling approximately Rs. 29.8 crore. The Court declined to adjudicate contested quantification given ongoing prosecution, but directed the State of Uttarakhand to implement restoration under supervision of the Central Empowered Committee (CEC), to demolish unauthorised construction within three months, submit a restoration plan within two months and file a compliance affidavit within one year. The Court held that proportionate costs could be recovered from delinquent officers after disciplinary processes.

The Court ordered broader measures: all States to notify ESZs around tiger reserves (including buffer and fringe) within one year, notify core and buffer areas within six months, and prepare/submit Tiger Conservation Plans (TCPs) within prescribed timelines (three to six months as directed). It directed declaration of Tiger Reserve areas and ESZs as “Silence Zones” within three months, prohibition of night tourism, restrictions on resorts in corridors, mandatory zero‑waste practices, promotion of community‑managed tourism, and NTCA to frame model human‑wildlife conflict guidelines. The Court also accepted multiple institutional recommendations on staffing, funding, firearms and crime investigation, and directed MoEF&CC, NTCA and CEC to prepare a policy framework on funding within six months.

Case Details: Case No.: 2025 INSC 1325 Case Title: IN RE : CORBETT (Writ Petition (C) No. 202 of 1995 — T. N. Godavarman Thirumulpad v. Union of India & Ors.; In the matter of Gaurav Kumar Bansal) Appearances: For the Petitioner(s): Mr. Gaurav Kumar Bansal (applicant in person); Mr. K. Parameshwar (Amicus Curiae assisting the Court) For the Respondent(s): Ms. Aishwarya Bhati, Additional Solicitor General of India; Shri Abhishek Attrey, Standing Counsel, State of Uttarakhand

(New Delhi; Judgment dated November 17, 2025)