In re Corbett (T.N. Godavarman): Supreme Court mandates ESZs and Silence Zones for all Tiger Reserves; bans Tiger Safaris in core habitats and confines them to non‑forest/degraded buffer areas with co‑located rescue centres; imposes enforceable TCP and governance deadlines

Citation: 2025 INSC 1325 | Court: Supreme Court of India (Civil Original Jurisdiction) | Date: 17 November 2025

Bench: B.R. Gavai, CJI; Augustine George Masih, J.; A.S. Chandurkar, J.

Proceedings: In Re: Corbett, IAs in W.P. (C) No. 202 of 1995 (T.N. Godavarman Thirumulpad v. Union of India)

Introduction

This judgment is a transformative addition to India’s tiger conservation jurisprudence under the long-running T.N. Godavarman proceedings. It builds directly on the Court’s 6 March 2024 order (reported in (2025) 2 SCC 641) that scrutinized the legality of Tiger Safaris and the ecological violations at Corbett Tiger Reserve (CTR), set up an Expert Committee, directed a CBI probe, and sought disciplinary action against errant forest officials.

On the basis of the Expert Committee’s multi‑meeting, field‑verified report, the Court now issues a suite of binding, pan‑India directions that recast how Tiger Reserves are zoned, regulated, policed and funded. The case touches four interlinked axes:

Corbett-specific ecological restoration, supervision and accountability;
A national code for Tiger Safaris—what is absolutely prohibited, and when a safari is permitted in buffers;
Landscape-level safeguards around Tiger Reserves via mandatory Eco‑Sensitive Zones (ESZs) and Silence Zones;
Systemic governance reforms—time-bound Tiger Conservation Plans (TCPs), empowered oversight, human resources, funding, human–wildlife conflict management, and regulation of religious tourism and infrastructure.

Parties and participants included the Union of India (MoEF&CC), NTCA, CEC, WII, the State of Uttarakhand, the applicant (Mr. Gaurav Kumar Bansal), the learned Amicus Curiae (Mr. K. Parameshwar), and the ASG (Ms. Aishwarya Bhati).

Summary of the Judgment

The Court accepts and operationalizes the Expert Committee’s recommendations, and issues directions that establish new baselines for tiger governance:

Corbett Tiger Reserve (CTR) – Restoration and Oversight

Uttarakhand must submit an ecological restoration plan conforming to the Expert Committee’s blueprint within 2 months (para 44.1.1).
Unauthorised structures must be cleared/demolished within 3 months (para 44.1.2).
Compliance affidavit within 1 year (para 44.1.3).
CEC will supervise restoration; only native, indigenous species may be used and no alien species introduced (para 44.1.4).
On quantification of damage: the Court does not adjudicate competing figures (Rs 29.8 crore) because the criminal trial and CBI prosecution are pending, but directs restoration under CEC oversight; costs may be recovered from delinquent officers post disciplinary proceedings (paras 44.4–44.6).

Tiger Safaris – Absolute Prohibitions and Conditional Permissions

Absolute ban on Tiger Safaris in core/critical tiger habitats (proviso to Section 33(a), Explanation (ii) to Section 38‑V(4) WLP Act; para 45.1).
Safaris may be permitted only on non‑forest land or degraded forest land within buffer areas, and never in tiger corridors (para 45.2).
Each permitted Safari must be paired with a full-fledged rescue and rehabilitation centre for conflict/injured/orphaned tigers from the same landscape (paras 45.3, 46.1.2–46.1.3).
Additional mandatory guardrails: CZA approval of enclosures; no contact between in‑situ and ex‑situ populations; Field Director management; earnings to TCFs; carrying capacity norms; EV/solar/hybrid vehicles; zero wastewater discharge; and strict sourcing consistent with Godavarman (2019 clause allowing zoo sourcing stands quashed) (para 46.1).

Eco‑Sensitive Zones (ESZs) and Silence Zones – Landscape Protection

All States must notify ESZs around every Tiger Reserve within 1 year. The minimum ESZ extent shall be the entire buffer/fringe area; where buffer is disjunct/absent, a radial cushion of 1 km from the critical habitat must be included (paras 47.1.3–47.1.4 referencing MoEF&CC letter dated 23 April 2018).
ESZs around Tiger Reserves will be subject to the same safeguards as the 9 February 2011 ESZ Notification, including a complete ban on mining within 1 km from the tiger habitat or buffer area or the notified ESZ, whichever is larger (para 47.1.5).
The entire Tiger Reserve and its ESZ must be notified as a Silence Zone under the 2000 Noise Rules within 3 months (para 49.1). Governments should also consider declaring all protected areas and their ESZs as Silence Zones (para 49.2).

Tourism, Resorts, Noise and Night Movement

Ecotourism cannot mirror mass tourism; NTCA guidelines must be strictly enforced (para 48.1).
New eco‑friendly resorts may be allowed only in buffers, never in identified corridors (para 48.2); homestays/community establishments encouraged; zero‑waste practices mandatory (paras 48.3–48.4).
Mobile phones prohibited in tourism zones within core habitats (para 48.5).
Vehicular carrying capacity norms to be enforced (para 48.6); night tourism is completely banned (para 48.7); dusk‑to‑dawn traffic through roads in core/critical habitats is restricted to emergencies (para 48.8).
Detailed prohibited and regulated activities listed for buffers/fringes, including bans on commercial mining, sawmills, polluting industries, discharge of waste, low‑flying aircraft/drones, and exotic species introduction; regulated establishment of hotels/resorts strictly as per TCP and ESZ Master Plans (para 47.2).

Governance Architecture and Deadlines

Delineate core and buffer areas for all Tiger Reserves within 6 months (para 50.1.1).
Prepare/update TCPs. The judgment states both 3 months (para 50.1.2) and 6 months (para 50.2.1); until clarified, stakeholders should endeavour to meet the earlier 3‑month deadline.
Constitute Steering Committees where absent within 2 months; they must meet at least twice a year; NTCA to monitor TCPs and committee functionality (paras 50.1.3–50.1.4).
States must adhere to NTCA tourism guidelines; community‑based tourism is the preferred model; night tourism is prohibited (para 50.1.5).

Human Resources, Funding, Conflict Management, Infrastructure, Religious Tourism

Special Cell (MoEF&CC + CEC) to assess staffing patterns/cadre needs for all Tiger Reserves within 1 year; States must fill vacancies thereafter; no outsourcing of core patrolling/scientific roles (paras 50.3.1–50.3.2, 50.3.3(a)).
Create dedicated cadres for veterinarians and wildlife biologists; sociologists for community engagement; enhance allowances, ex gratia parity with paramilitary, housing, medical care, and insurance for all frontline staff including daily wagers; institute recognition/medal systems (para 50.3.3(b)–(t)).
MoEF&CC, NTCA and CEC must frame a funding policy framework with SOPs within 6 months; CSS‑IDWH funding to be linked to approved TCPs (paras 50.2.2, 50.4).
NTCA to issue Model Guidelines on human‑wildlife conflict within 6 months; States to implement within a further 6 months; ex gratia of Rs 10 lakh to be paid as per CSS‑IDWH; classify HWC as “natural disaster” should be actively considered (para 50.5).
Green infrastructure: prioritise avoidance; upload critical ecological layers to Gati Shakti; implement WII/NTCA/NBWL mitigation; insulate/underground transmission lines, where feasible (para 50.6).
Religious tourism: regulate access and crowding, promote CNG/electric multi‑seaters, fix historical boundaries/routes, prohibit new constructions, restrict cooking, and replicate best practices from reserves like Sariska (para 50.7).

All governments must issue necessary rules, memoranda and circulars to implement these directions within 6 months (para 51). States may make minor context‑specific modifications after consulting WII and NTCA (para 52).

Analysis

Precedents and Sources the Court Relied Upon

T.N. Godavarman Thirumulpad v. Union of India, (2025) 2 SCC 641 (6 March 2024): The foundation for the current directions—quashed the 2019 NTCA guideline that allowed sourcing of tigers from zoos; mandated an Expert Committee; emphasised ecocentrism, precautionary principle, and in‑situ conservation in Tiger Reserves.
Wildlife (Protection) Act, 1972: Chapter IV/IV‑A/IV‑B; Section 33(a) (proviso); Section 38‑V (definition and architecture of core and buffer, and the science‑anchored “inviolate” standard for core/critical tiger habitats).
Ajay Dubey v. NTCA, (2019) 11 SCC 538: Reinforced that tourism in core/critical tiger habitats must adhere strictly to NTCA guidelines.
Polluter Pays and Restitution cases: Indian Council for Enviro‑Legal Action v. Union of India, (1996) 3 SCC 212; S. Jagannath v. Union Of India, (1997) 2 SCC 87; applied in Bajri Lease LoI Holders Welfare Society v. State of Rajasthan, (2022) 16 SCC 581 (Gavai, J.). These decisions endorsed compensation beyond mere value of illegally extracted resources, extending to restoration costs and ecological services loss.
International law: Convention on Biological Diversity, 1992 (Art. 8—restoration obligations); Factory at Chorzów (PCIJ, 1928) and Certain Activities (Nicaragua), I.C.J. (2018)—reparations principles adapted for ecological restoration.
MoEF&CC ESZ Notification (9 February 2011) and MoEF&CC letter (23 April 2018) extending ESZ logic to Tiger Reserves—now judicially endorsed and made binding.
NTCA Tourism Guidelines (2012/2016/2019): 2016’s in‑situ focus supplies the baseline; 2019’s Clause 9 (zoo sourcing) stands quashed by the Court; the present judgment tightens and constitutionalizes the safari regime.

Legal Reasoning

The Court’s reasoning is anchored in three normative pillars already surfaced in the 2024 decision and reinforced here:

Ecocentrism over anthropocentrism: The tiger is a keystone species; governance must prioritize ecological integrity, not tourist convenience or revenue (para 41).
Precautionary principle: Where science flags risk (e.g., disease transmission or genetic contamination from ex‑situ stock; disturbance from noise/light/night traffic), regulation must err on the side of protection—hence complete prohibition of safaris in core, Silence Zones, and blanket night tourism ban.
Restitution/remediation: Constitutionalized under Articles 21, 48A, 51A(g) and mirrored in Section 15(4) of the NGT Act; therefore, ecological restoration is the default remedy, supervised by CEC, and costs are recoverable from culpable officers (paras 37–43, 44.6).

Statutorily, Section 38‑V establishes a higher pedestal for Tiger Reserves and demarcates “inviolate” core/critical habitats. This directly supports the categorical prohibition on Tiger Safaris in core. The judgment harmonizes the WLP Act’s Tiger Reserve architecture with the ESZ regime (traditionally applied to National Parks/Sanctuaries), judicially extending ESZ logic to Tiger Reserve buffers and fringes with minimum spatial envelopes and 1 km mining bans. By also requiring Silence Zones for entire reserves and ESZs, the Court links noise regulation under the 2000 Rules to wildlife protection, recognizing acoustic disturbance as a conservation threat.

On tourism, the Court expressly distinguishes ecotourism from mass tourism and repudiates practices that magnify disturbance (e.g., night stays/trips, vehicle crowding at sightings, mobile phone use in core tourism zones). The detailed permitted/prohibited activity matrix harmonizes TCPs, ESZ Master Plans, and NTCA prescriptions—creating a multi‑layered planning hierarchy that leaves less room for ad hocism.

Corbett-specific remedies: restitution over retribution

On Corbett, the Court privileges ecological outcomes over immediate monetary quantification because criminal prosecution is pending. By putting CEC in supervisory control, requiring a plan in 2 months, demolition within 3 months, and a 1‑year compliance affidavit, the Court ensures time‑bound remediation while preserving the State’s right to recover costs post‑discipline (paras 44.1–44.6). This approach also avoids prejudicing the CBI’s case, even as it ensures that ecological time is not lost.

Governance, capacity and finance: operationalizing conservation

The Court’s directions on TCPs, Steering Committees and NTCA monitoring convert what were often paper obligations into enforceable timelines. The human resource package is unusually concrete: no outsourcing for core roles; specialist cadres for veterinarians/biologists/sociologists; parity‑oriented allowances and ex gratia; housing, insurance and medical protections for frontline staff—including daily wagers. Funding reform is tied to approved TCPs and a forthcoming policy framework (within 6 months) by MoEF&CC, NTCA and CEC. Human‑wildlife conflict management is elevated through a centrally authored model, with State implementation deadlines and standard ex gratia.

On infrastructure, the Court codifies an avoidance‑first rule, layered with mandated disclosure on the Gati Shakti platform and best‑practice mitigation (including insulation/undergrounding of lines). Religious tourism receives a calibrated regime: preserve historical limits, regulate access through cleaner public transport, disallow new/temporary structures or cooking that spawns fuelwood extraction—thus balancing faith and fauna.

What the Court deferred or left to policy

Damage quantification at Corbett was expressly not adjudicated at this stage (para 44.5).
Some Expert Committee suggestions (e.g., provisioning of firearms with licensing waivers, CDR access for wildlife crime units, special prosecution wings) are not explicitly part of the operative directions; States may still adopt them through policy, and future orders may revisit them.
TCP deadline ambiguity: The judgment states both 3 months (para 50.1.2) and 6 months (para 50.2.1). Until the Court or NTCA clarifies, agencies should strive to meet the shorter deadline.

Safari regime—integrating and tightening 2016/2019 guidelines

The Court cements the shift to in‑situ, buffer‑anchored safaris initiated in 2016 by:

Prohibiting core/critical tiger habitat safaris absolutely;
Restricting buffer safaris to non‑forest or degraded forest land, outside corridors, and mandating co‑located rescue/rehab centres;
Limiting animals to the same landscape (conflict/injured/orphaned)—reiterating that 2019’s zoo‑sourcing clause is quashed;
Requiring CZA approval of enclosure designs, physical separation of wild and captive populations, carrying capacity limits, clean vehicles, and zero wastewater discharge;
Keeping management with the Field Director and recycling revenues to the Tiger Conservation Foundation.

Impact

Immediate and medium‑term consequences

Uniform landscape buffers: All Tiger Reserves must have ESZs defined at a minimum as their entire buffer/fringe (plus 1 km cushions where buffers are disjunct), with 2011‑Notification safeguards and categorical mining bans in the 1 km protection belt. This will significantly curtail extractive pressures around core habitats nationwide.
Acoustic protection: Declaring entire reserves and their ESZs as Silence Zones within 3 months will require rapid recalibration of tourism operations, religious congregations, festivals, and road traffic management.
Tourism recalibration: Night tourism is over; vehicle and visitor loads must respect carrying capacity; mobile‑phone restrictions apply in core tourism zones; homestays/community establishments will likely see demand; resorts cannot be sited in corridors.
Planning discipline: With TCPs and Steering Committees on the clock and NTCA oversight mandated, States will need to standardize zoning, corridors, and tourism prescriptions.
Human resource uplift: Codified commitments to specialist cadres, allowances, housing, insurance and recognition will help professionalize and stabilize frontline conservation workforces.
Corbett restoration: Demolition deadlines and CEC supervision should deliver visible ecological gains within a year, setting a precedent for remedial governance in protected areas.

Sectors affected

Mining and infrastructure: The 1 km no‑mining rule around tiger habitats/buffers/ESZs and avoidance‑first mandates will impact project siting, design and approvals.
Hospitality and tourism: Relocation or redesign of facilities to buffer‑compatible zones; stricter water, waste, noise, fencing and mobility rules; community models incentivized over mass‑tourism lodgings.
Religious institutions and local administrations: Movement management, infrastructure rationalization and cooking restrictions within reserves.
State Forest/Wildlife Departments: New compliance calendars for zoning, planning, funding applications, staffing, and field infrastructure upgrades.

Doctrinal consolidation

Reaffirms Tiger Reserves’ “higher pedestal” vis‑à‑vis other protected areas under the WLP Act.
Makes ecocentrism, precaution, and restoration the operating logic for tiger‑land governance.
Judicially extends the ESZ and Silence Zone regimes to Tiger Reserves—an important harmonization of wildlife and environmental law frameworks.

Complex Concepts Simplified

Core/Critical Tiger Habitat: The inviolable heart of a Tiger Reserve, identified scientifically and notified under Section 38‑V; meant to be free from disturbance—no Safari or tourism in contravention of NTCA norms is allowed.
Buffer/Peripheral Area: Surrounds the core; a multiple‑use landscape that must nevertheless secure tiger dispersal and ecological integrity; tightly regulated to harmonize human use and wildlife movement.
Tiger Corridor: Natural movement pathways linking tiger populations; siting of resorts and safaris in corridors is prohibited to maintain connectivity and genetic flow.
Eco‑Sensitive Zone (ESZ): A protective ring around protected areas that regulates development to cushion ecological impacts; now mandatory around Tiger Reserves at minimum as the entire buffer/fringe.
Silence Zone: Under Noise Rules, an area with stringent noise limits; by Court direction, the entire Tiger Reserve and its ESZ must be notified as Silence Zones.
Tiger Safari (in‑situ): A controlled, fenced facility in the buffer that houses only conflict/injured/orphaned tigers from the same landscape—paired with a rescue centre—subject to strict ecological, veterinary, design and visitor controls.
Tiger Conservation Plan (TCP): A statutory, science‑based plan for each reserve detailing habitat, corridors, protection, tourism, and community prescriptions; a prerequisite for central funding.
CEC/NTCA/CZA/WII: Key national institutions—the CEC supervises compliance/restoration; NTCA is the tiger regulator; CZA approves ex‑situ/zoo‑related designs; WII provides scientific inputs.
Polluter Pays & Restitution: Those who damage the environment must fund full restoration and compensate for lost ecological services; courts prioritize returning ecosystems to their original state.

Conclusion

This decision is a watershed in India’s tiger conservation jurisprudence. It does four things of lasting significance:

Landscape-secures tiger habitats by mandating ESZs around all Tiger Reserves and declaring entire reserves and ESZs as Silence Zones—thus tackling extractive and acoustic pressures beyond core boundaries.
Purifies the safari concept by banning it in core habitats, confining it to strictly conditioned buffer settings on non‑forest/degraded land, and tying it inseparably to rescue/rehabilitation of conflict animals within the same landscape.
Institutionalizes planning and people with enforceable timelines for TCPs, working Steering Committees, NTCA oversight, and a comprehensive uplift of frontline conservation staffing, protection, and welfare.
Centers restoration—with CEC supervision—over punitive accounting at this stage, ensuring Corbett’s ecological repair proceeds without waiting on criminal process outcomes, while preserving cost recovery from delinquent officers.

In one stroke, the Supreme Court has aligned statutory wildlife protections with environmental governance tools (ESZs and Silence Zones), welded tourism to ecocentric limits, and set measurable administrative expectations. If faithfully implemented, these directions will enhance connectivity, reduce disturbance, and professionalize conservation practice across India’s tiger landscapes—precisely the ingredients required to secure the country’s global custodianship of Panthera tigris.

Key Compliance Timelines at a Glance

CTR restoration plan: 2 months; demolition: 3 months; compliance affidavit: 1 year.
Silence Zones (entire reserve + ESZ): 3 months.
Core/buffer notification: 6 months.
TCPs: 3 months (also stated as 6 months elsewhere—agencies should target 3 months pending clarification).
Steering Committees: constitute in 2 months; meet at least twice a year; NTCA to monitor.
ESZs for all Tiger Reserves: notify within 1 year (minimum coverage: entire buffer/fringe; 1 km cushion if buffer is disjunct/absent; 1 km mining ban around tiger habitat/buffer/ESZ).
Funding policy framework (MoEF&CC + NTCA + CEC): 6 months.
HR Special Cell assessment (MoEF&CC + CEC): complete within 1 year; States to fill vacancies thereafter.
Model Guidelines on human‑wildlife conflict (NTCA): 6 months; State implementation: within 6 months thereafter.
Governmental rules/memos/circulars to implement this judgment: 6 months.