The Supreme Court found prima facie violations of the Wild Life (Protection) Act, 1972, CZA norms, and IUCN translocation guidelines. It directed the Central Empowered Committee to conduct an independent scientific assessment of carrying capacity, post-release survival, and regulatory compliance. The Court prohibited further translocation pending expert evaluation, emphasizing constitutional duties under Articles 48A, 51A(g), and 21.
Facts Of The Case:
The A.N. Jha Deer Park, established in 1968 by the Delhi Development Authority in Hauz Khas, New Delhi, operated as a captive zoo facility under a license issued by the Central Zoo Authority under the Wild Life (Protection) Act, 1972. Despite repeated extensions and warnings, evaluation reports from 2014 to 2022 revealed persistent non-compliance with zoo management norms, including failure to control deer population, inadequate veterinary infrastructure, and poor enclosure maintenance. The last valid license expired in 2021. In May 2022, the DDA sought approval from the Chief Wild Life Warden, Rajasthan, to translocate approximately 550 spotted deer, citing administrative incapacity to manage overpopulation. The Central Zoo Authority, on 8th June, 2023, cancelled the Deer Park’s recognition and approved translocation of 600 deer to Rajasthan and Asola Bhatti Wildlife Sanctuary in a 70:30 ratio. The petitioner, New Delhi Nature Society, filed a writ petition before the Delhi High Court challenging the decision. The High Court initially stayed translocation on 6th December, 2023, but disposed of the petition on 19th July, 2024, recording DDA’s undertaking to retain about two dozen deer and approach the Central Zoo Authority for license renewal. A recall application was dismissed on 24th January, 2025. Meanwhile, 261 deer were translocated to Ramgarh Vishdhari and Mukundara Hills Tiger Reserves in Rajasthan, prompting the petitioner to approach the Supreme Court alleging gross violations of statutory guidelines and animal welfare norms during the translocation process.
Procedural History:
The New Delhi Nature Society initially filed a public interest litigation, Writ Petition (C) No. 12275 of 2023, before the High Court of Delhi under Article 226 of the Constitution, challenging the Central Zoo Authority’s order dated 8th June, 2023 which cancelled the recognition of A.N. Jha Deer Park and approved the translocation of approximately 600 spotted deer to Rajasthan and Asola Bhatti Wildlife Sanctuary. On 6th December, 2023, the High Court granted an interim stay on further translocation. The writ petition was thereafter disposed of by the High Court on 19th July, 2024, recording the DDA’s additional affidavit undertaking to retain about two dozen deer and seek renewal of the zoo license from the Central Zoo Authority. The petitioner subsequently filed an application seeking recall of the said order, which was dismissed by the High Court on 24th January, 2025. Aggrieved by both the order of disposal dated 19th July, 2024 and the dismissal of the recall application dated 24th January, 2025, the petitioner approached the Supreme Court of India by way of Special Leave Petitions (C) Nos. 13374-13375 of 2025. During the pendency of these petitions, the Supreme Court on 16th May, 2025 directed the Central Zoo Authority to conduct a field inspection of the translocation sites in Rajasthan and permitted the petitioner’s representative to participate. Pursuant thereto, the petitioner filed an application before the Supreme Court on 11th August, 2025, bringing on record serious discrepancies observed during the joint inspection, including missing deer, absence of identification tags, overcrowded transportation, and lack of post-release monitoring. After hearing the parties, the Supreme Court on 26th November, 2025, passed the final order referring the matter to the Central Empowered Committee for comprehensive scientific assessment and issuing comprehensive directions while declining to interfere with the impugned High Court orders.
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Court Observation:
The Supreme Court observed that the A.N. Jha Deer Park, despite its historical and ecological significance, had suffered from chronic managerial deficiencies and operated far below statutory standards prescribed under the Wild Life (Protection) Act, 1972, the National Zoo Policy, 1998, and the Guidelines for the Establishment and Scientific Management of Zoos in India, 2008. The Court noted that evaluation reports from 2014 to 2022 underscored persistent non-compliance relating to enclosure maintenance, veterinary infrastructure, population control, and habitat enrichment, which led to exponential increase in deer population exceeding the carrying capacity of the 10.97-acre enclosure. The Court observed that the DDA lacked requisite logistical and veterinary preparedness to manage the population and that overcrowding in captive ungulate species was known to heighten stress, weaken immunity, and precipitate disease outbreaks.Critically, the Court observed that the translocation protocol and best practices incorporated in the Central Zoo Authority guidelines and IUCN Guidelines were not adhered to during the translocation exercise. There was no documentary evidence of pre-translocation genetic screening, tagging, tranquilisation protocols, veterinary fitness certification, or behavioural acclimatisation. The Court noted that no scientific assessment was carried out regarding carrying capacity of recipient sanctuaries, predator-prey dynamics, or impact of introducing semi-captive deer into tiger-bearing ecosystems. The Court further observed that deer were transported in overcrowded trucks without proper ventilation, padding, or segregation, and that a blue rope used to tie the limbs of a deer was recovered from the relocation site, raising serious concerns about use of force and absence of ethical handling procedures. The Court noted that no tracking mechanisms such as telemetry collars or radio chips were deployed, and no post-release surveys were conducted to monitor survival or adaptation. The Court emphasised that wildlife management cannot be approached as a matter of administrative convenience but must be anchored in scientific assessment, ecological prudence, and fidelity to constitutional values embodied in Articles 48A, 51A(g), and 21 of the Constitution.
Final Decision & Judgement:
The Supreme Court disposed of the special leave petitions while declining to interfere with the impugned orders of the Delhi High Court dated 19th July, 2024 and 24th January, 2025. However, finding that the translocation exercise had been undertaken without adherence to statutory norms and internationally accepted conservation guidelines, the Court issued a comprehensive set of directions to secure the welfare of the deer population and ensure future compliance with the legal framework. The Court directed the Central Empowered Committee to conduct an on-ground survey of A.N. Jha Deer Park within eight weeks, enumerating the present population of deer, the ecological carrying capacity of the enclosure based on space, fodder availability, veterinary infrastructure, and enclosure design, the maximum number of deer that can be sustainably maintained, and the surplus population requiring translocation. The CEC was further directed to undertake inspection of the release sites at Ramgarh Vishdhari Tiger Reserve and Mukundra Hills Tiger Reserve in Rajasthan and file a status report within eight weeks enumerating the number of deer actually surviving, habitat suitability, forage and water availability, predation risks, veterinary monitoring mechanisms, and compliance with Central Zoo Authority and IUCN guidelines. The Court additionally directed the CEC to prepare a comprehensive roadmap for any future translocation detailing scientific methodology,identification and tagging processes, procedural safeguards, transportation protocols, veterinary requirements, ecological feasibility studies, and post-release monitoring framework in strict conformity with domestic statutory regime and IUCN guidelines. The Court directed the DDA to place on record a comprehensive report detailing the past and present status of land formerly designated for deer enclosures, including the unexplained reduction of more than 20 acres reported in evaluation reports. The DDA was restrained from organizing or permitting any commercial events, private parties, or non-conservation related gatherings within the premises of the Deer Park, and was instead directed to develop a non-commercial public outreach programme including educational visits, guided nature walks, and biodiversity awareness campaigns. The Court imposed an interim stay on any further translocation of deer from A.N. Jha Deer Park until further orders, and listed the matter on 17th March, 2026 for receiving the reports of the Central Empowered Committee and the DDA.
Case Details:
Download The Judgement Here