SC directs Jharkhand to notify 126 compartments of Saranda Forest as wildlife sanctuary

The Supreme Court has today directed the Jharkhand state government to notify the area comprising of 126 compartments in Saranda Forest as a wildlife sanctuary within a period of three months.

"We further direct the State of Jharkhand to give wide publicity to the fact that by this judgment, neither the individual rights nor the community rights of the tribals and the forest dwellers in the said area would be adversely affected. The State shall also give wide publicity to the fact that in view of the provision of Section 3 read with sub-Section (1) of Section 4 of the FRA all the rights of the tribals and the forest dwellers both individually as well as of community shall stand protected", a bench of CJI BR Gavai and Justice Vinod Chandran has ordered.

The judgment adds that even after the declaration of the area as a Wildlife Sanctuary, ancillary mining activities as sought to be carried out by SAIL would be continued to be permitted. 

Saranda forest area in the State of Jharkhand is undisputedly one of the most pristine Sal forests in the world. The region is rich in biodiversity and wildlife and includes within its confines the critically endangered and endemic Sal Forest Tortoise, four horned antelope, Asian palm civet, wild elephants, leopards, sambar and chital deer, bison, barking deer, and numerous species of birds and reptiles. 

By a notification bearing No. 1168F dated 16th February 1968, the State of Bihar had declared an extent of 31,468.25 hectares (approx. 314 sq. kms) in the Saranda forest area as the “Saranda Game Sanctuary”. This was done pursuant to relevant provisions of the Bihar Forest, Hunting, Shooting and Fishing Rules, 1958. On bifurcation of the then State of Bihar into States of Bihar and Jharkhand, this area now fell within the State of Jharkhand. 

One Dr. R.K. Singh, a distinguished wildlife scientist, being aggrieved by the fact that the Government of Jharkhand and Ministry of Environment, Forests and Climate Change had failed to declare the Eco-Sensitive Zone in respect of Sasangada/Saranda Sanctuary, had approached the NGT. In 2022, the NGT had asked the state government to consider the same.

Since no action was taken by Jharkhand in this respect, an application was filed before the Supreme Court by one Dr. Daya Shankar Srivastava, a resident of Palama, Jharkhand, seeking directions to the State of Jharkhand to declare the Saranda Game Sanctuary with area of 314.68 sq. km. as notified by the 1968 Notification by the erstwhile State of Bihar as a deemed sanctuary.

Before the Supreme Court, the main opposition of the State was on the ground that the rights of the tribals and the traditional forest dwellers residing in the area proposed to be declared as wildlife sanctuary would be adversely affected.

On this the court said, "The bogey that on declaration of wildlife sanctuary, the habitations and rights of the tribals and traditional forest dwellers will be lost and vital public infrastructures like educational institutions, roads, etc., will have to be demolished is only a figment of imagination of the State. Rather than taking such a stand before this court, we are of the considered view that the State should have educated the tribals/forest dwellers residing in the said areas about the rights available to them under the FRA as well as the WPA."

Court further noted that the State had been changing its stand time and again. "Earlier, it had clearly admitted that in 126 compartments which were notified as the Saranda Game Sanctuary vide 1968 Notification, neither any kind of mining excavation operations nor any diversion of Forest Land for mining purposes have been undertaken except in part of the area approximately measuring 4.31 hectares. Subsequently, the stand had been changed wherein the State submitted that it is considering declaration of area measuring 57,519.41 hectare as against the original area measuring 31,468.25 hectare as a wildlife sanctuary. This stand was, yet again, changed and finally the State now proposes to notify only an area of 24,941.64 hectare as wildlife sanctuary",  court has recorded in its judgment.

Case Title: IN RE: SARANDA WILDLIFE SANCTUARY

Judgment Date: November 13, 2025

Bench: CJI Gavai and Justice Chandran