Supreme Court Directs Jharkhand to Notify 126 Compartments as Saranda Wildlife Sanctuary, Emphasizes Protection of Tribal Rights

New Delhi: In a landmark decision, the Supreme Court of India on Thursday directed the Jharkhand government to formally notify 126 compartments in the ecologically rich Saranda forest region as a wildlife sanctuary within a period of three months. The apex court also issued a clear prohibition against any mining activities within a one-kilometer radius of the sanctuary boundary, underscoring the need for conservation of wildlife and protection of biodiversity in the area. The bench, comprising Chief Justice of India BR Gavai and Justice K Vinod Chandran, however, excluded six compartments designated for mining from the notification. These six compartments—KP-2, KP-10, KP-11, KP-12, KP-13, and KP-14—would not form part of the sanctuary due to existing mineral extraction activities.

Compartments are administrative divisions within wildlife sanctuaries and forests, designed to facilitate effective management, monitoring, and protection of flora and fauna. The Saranda forest, located in the West Singhbhum districtof Jharkhand, is renowned for its rich biodiversity and dense sal tree coverage, often referred to as the “Sal Forest of India.” The area spans several tens of thousands of hectares and is home to a variety of wildlife species, including elephants, leopards, and numerous endemic species of birds and plants. The Supreme Court noted that the state government cannot evade its statutory duty to declare the area of 31,468.25 hectares as Saranda Wildlife Sanctuary, a responsibility that had been pending for decades.

In its ruling, the court emphasized that mining within one kilometer of a protected area poses a serious threat to wildlife. While similar directions were previously issued for the State of Goa in a case involving the Goa Foundation, the court observed that such restrictions are necessary on a pan-India basis, given the potential ecological damage and disruption to the natural habitat. Accordingly, the bench made it explicit that mining activities within national parks and wildlife sanctuaries, as well as within one kilometer from their boundaries, would not be permissible under any circumstances.

The matter before the Supreme Court revolved around a long-pending proposal by the Jharkhand government to notify portions of the Saranda and Sasangdaburu forest areas as a wildlife sanctuary and conservation reserve, respectively. Initially, the state government had sought to exclude a larger area of 57,519.41 hectares, arguing that it had been inhabited for centuries by Ho, Munda, Uraon, and allied Adivasi communities. The state contended that excluding these areas would help safeguard forest rights and protect existing infrastructure such as schools, roads, and other educational and public facilities.

However, in an affidavit before the apex court, the Jharkhand government revised its proposal, stating that the larger area figure of 57,519.41 hectares was erroneously calculated, and that 31,468.25 hectares would actually be notified as a wildlife sanctuary. The Supreme Court rejected the state government’s submission, holding that the rights of tribals and forest dwellers are adequately protected under the Wildlife Protection Act (WPA), particularly Section 24, and under the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 (FRA), specifically Section 3 read with Section 4. The bench made it clear that the declaration of the area as a wildlife sanctuary does not result in the loss of individual or community rights of the tribals and forest dwellers residing in the region.

“The bogey that, upon declaration of the wildlife sanctuary, the habitations and rights of the tribals and traditional forest dwellers will be lost, and that vital public infrastructures such as educational institutions and roads would need to be demolished, is purely a figment of the imagination of the State,” the court noted. Instead of opposing the sanctuary notification, the court observed, the state government should have taken steps to educate the residents of the Saranda forest area about the rights available to them under the FRA and the WPA. By raising awareness and providing guidance, the government could have ensured a smoother process for sanctuary notification while protecting the interests of local communities.

The apex court further directed the Jharkhand government to give wide publicity to the fact that, following this judgment, neither individual rights nor community rights of the tribals and forest dwellers in the area would be adversely affected. “The State shall also give wide publicity to the fact that, in view of the provisions of Section 3 read with sub-section of Section 4 of the FRA, all rights of tribals and forest dwellers, both individually as well as of the community, shall stand protected,” the bench stated. This directive ensures that the residents are well informed and reassured regarding the security of their rights and the legality of the sanctuary notification process.

The Supreme Court had earlier asked the Jharkhand government to make a decision regarding the declaration of the Saranda region as a reserve forest, highlighting the ecological importance of the area. The court’s interventions were prompted by the long-standing delay in formalizing the sanctuary, despite repeated notifications and proposals dating back decades. In September 2025, the bench had pulled up the state government for what it described as totally unfair conduct and dilly-dallying tactics in notifying the Saranda forest as a wildlife sanctuary. At that time, the court had also directed the chief secretary of Jharkhand, Avinash Kumar, to appear in person to explain why the state had failed to act on the long-pending proposal.

The Saranda region, often called the Sal Forest of India, is recognized for its unique ecology, dense sal tree cover, and rich wildlife population, including elephants, leopards, deer, and several rare bird species. It is a critical habitat for the conservation of these species and for maintaining ecological balance in the region. The Supreme Court, in issuing its judgment, highlighted that mining and other industrial activities in and around such sensitive zones can have hazardous effects on wildlife and must be strictly controlled to prevent environmental degradation.

By mandating the notification of the Saranda compartments as a wildlife sanctuary and restricting mining activity within one kilometer of its boundaries, the apex court has reinforced the principle that conservation of biodiversity and ecological protection must be prioritized alongside developmental and economic interests. At the same time, the judgment reflects a balanced approach by ensuring that tribal rights and traditional forest dwellers’ rights remain fully protected under existing legal frameworks.

The Supreme Court’s directions also carry significant implications for other states in India, particularly those with ecologically sensitive forests and tribal populations. By stating that similar restrictions on mining and industrial activities are warranted on a pan-India basis, the bench has set a precedent for strengthening wildlife conservation policies across the country. This judgment may serve as a reference for future cases where tribal rights, ecological protection, and development interests intersect, ensuring that the law recognizes both environmental imperatives and human rights.

In conclusion, the Supreme Court’s directive to the Jharkhand government represents a critical step in preserving the Saranda forest ecosystem while safeguarding the legal and community rights of indigenous populations. The notification of 126 compartments as a wildlife sanctuary, exclusion of six compartments for mining, and prohibition of mining within one kilometer of the sanctuary boundaries are measures aimed at achieving a balance between conservation and livelihood protection. The court has made it clear that proper communication and awareness among forest-dwelling communities are essential to ensure the smooth implementation of such conservation measures. With this judgment, the Saranda forest region is poised to receive legal protection, ensuring that its unique biodiversity and ecological significance are preserved for generations to come.

This ruling underscores the Supreme Court’s commitment to environmental conservation while upholding the rights of tribal communities, demonstrating the delicate yet necessary equilibrium between development, ecology, and human rights in India.

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