Supreme Court’s Landscape-Level, Satellite-Aided Restoration Mandate for the Agasthyamalai Tiger Landscape: An Ecocentric Turn in A. John Kennedy v. State of Tamil Nadu (2025 INSC 443)

Introduction

In A. John Kennedy v. State of Tamil Nadu, 2025 INSC 443 (order dated 24 March 2025), a two-Judge Bench of the Supreme Court of India (Vikram Nath, J. and Sandeep Mehta, J.; order authored by Mehta, J.) issued a reportable interim order that does three things at once:

Prioritizes the conservation and restoration of the Agasthyamalai landscape—encompassing reserve forests, wildlife sanctuaries and tiger habitats in Tamil Nadu—through a time-bound survey and restoration blueprint;
Operationalizes an ecocentric, landscape-scale approach by directing the Central Empowered Committee (CEC) to conduct a scientific, satellite-aided audit of “non-forestry activities” and recommend restoration measures for reserved forests, core critical tiger habitats, elephant corridors, and other protected areas; and
Segregates and schedules, for later hearing, the rehabilitation issues of displaced tea estate workers from the erstwhile Bombay Burma(h) Trading Corporation Ltd. (BBTCL) operations in the Singampatti Zamin area.

The case arose from multiple writ petitions before the Madras High Court: some public interest petitions sought restoration of degraded forests following cessation of plantation activities; others were by displaced tea estate workers seeking employment, compensation, and rehabilitation following eviction from forest lands now notified as Reserved Forest/Wildlife Sanctuary/Tiger Reserve. The High Court’s common order dated 3 December 2024 closed the matters with general directions regarding worker rehabilitation, but left the core forest-restoration issues inconclusive. The Supreme Court has now stepped in to carry the restoration mandate forward.

Against a backdrop of dwindling national forest cover (21.76% as per India State of Forest Report 2023) and alarming encroachments (~13,000 sq km as reported to the National Green Tribunal), the Court explicitly re-centers forest protection as a constitutional and ecological imperative. It invokes the continuing mandamus in T.N. Godavarman Thirumulpad, reiterates the ecocentric approach from State of Telangana v. Mohd. Abdul Qasim (2024), and underscores the apex ecological role of tigers—citing recent iterations of Godavarman—to justify robust, science-led enforcement.

Summary of the Judgment/Order

The Supreme Court’s order—issued in Special Leave Petitions (Civil) Nos. 999-1001 of 2025—has two principal strands:

A. Forest conservation and restoration (interim directions)

The Court directs the Central Empowered Committee (CEC) to conduct an “extensive survey” of the entire Agasthyamalai landscape, expressly including Periyar Tiger Reserve, Srivilliputhur Grizzled Squirrel Wildlife Sanctuary, Meghamalai Wildlife Sanctuary, and Thirunelveli Wildlife Sanctuary.
The CEC must:
- Identify and report all instances of non-forestry activities contrary to the Forest (Conservation) Act, 1980 and the Wildlife (Protection) Act, 1972 across the landscape;
- Provide comparative data on forest cover (earlier versus current) to gauge depletion/degradation;
- Recommend restoration measures for: (a) reserved forests, (b) tiger habitats (core critical tiger habitats), (c) elephant corridors, and (d) other wildlife sanctuaries;
- Employ scientific tools including Remote Sensing Satellite Imagery and geospatial mapping to expedite and ensure accuracy.
The State’s district administration, police, and forest officials are directed to provide complete assistance to the CEC. A 12-week timeline is fixed, and the matter is listed for 15 July 2025 for the CEC’s report and further directions.

B. Worker rehabilitation

The petitions by displaced tea estate workers (from the BBTCL-leased Singampatti Zamin lands) seeking compensation, re-employment, and rehabilitation are kept pending; the Supreme Court will hear these issues on 22 April 2025.

While the Amicus Curiae sought additional directions (such as stopping government facilities within reserved forests and protection of forest personnel from malicious prosecutions during evictions), the Court has, at this stage, confined itself to the survey-and-recommend blueprint via the CEC, with further orders to follow upon receipt of the report.

Background and Procedural Posture

The Singampatti Zamin forest lands (3388.78 hectares) in Tamil Nadu were leased in 1929 by the then Zamindar to BBTCL for plantation crops (tea/coffee/spices/rubber). Key legal milestones followed:

1978: The area declared “Reserved Forest” (Government Order dated 23 March 1978).
2007: Declared “Core Critical Tiger Habitat” (GO No. 145 dated 28 December 2007).
2012: Notified as Wildlife Sanctuary and Tiger Reserve under the Wildlife (Protection) Act, 1972 (G.O.s dated 12 August 2012).
2018: Included in Kalakkad–Mundanthurai Reserve Forest (GO (Ms) No. 03 dated 12 January 2018; declaration under Section 16, Tamil Nadu Forest Act, 1882).

BBTCL filed W.P. No. 16921/2014 challenging the declarations; this remains pending. Meanwhile, multiple petitions in the Madras High Court raised (i) public-interest forest restoration issues and (ii) worker rehabilitation claims following eviction from the forested plantations. The High Court’s common order (3 December 2024) focused on rehabilitation, leaving broader restoration issues unresolved. The present SLPs bring both strands to the Supreme Court, which bifurcates the hearings and, as an interim measure, seizes the forest-restoration agenda through a CEC-led scientific survey.

Precedents Cited and Their Influence

1. T.N. Godavarman Thirumulpad v. Union of India (continuing mandamus)

The Court explicitly situates this matter within the long-running Godavarman jurisprudence, which created and sustained a continuing mandamus to protect forests nationally and established the CEC as an expert supervisory body. The present order:

Leverages the CEC’s institutional expertise and neutrality to conduct a landscape-scale audit;
Adopts the Godavarman template of iterative, data-backed directions rather than one-off adjudication;
Emphasizes compliance with statutory embargoes on “non-forestry activity” under the Forest (Conservation) Act, 1980.

The order also references a 2025 SCC report in the Godavarman line concerning tigers: the vitality of forests and tigers is reciprocal; protecting apex predators is a proxy for ecosystem health. This informs the priority accorded to Core Critical Tiger Habitats (CCTH).

2. State of Telangana v. Mohd. Abdul Qasim (2024) 6 SCC 461

Relying on paragraphs authored by M.M. Sundresh, J., the Court recites the core philosophy of ecocentrism:

Forests are vital for regulating carbon, water, soil, and biodiversity; their degradation disproportionately harms the vulnerable (implicating Article 14 equality concerns).
The judiciary calls for a shift from an anthropocentric to an ecocentric approach—recognizing inherent ecological rights and inter-species trusteeship responsibilities.

This philosophical anchor justifies a landscape-scale, rights-infused, science-led judicial intervention.

3. Bombay Burmah (Burma) Trading Corporation Ltd. v. State of Tamil Nadu (2018) 1 CTC 733

The Madras High Court judgment (authored by M.M. Sundresh, J., as he then was) recognized the Agasthyamalai landscape as a high-biodiversity, river-rich ecosystem and mandated evacuation from critical forest areas. It underlined the climate imperative and inter-generational equity in preserving pristine forests. The present order builds upon that foundation:

Extends the lens beyond an individual estate to the entire Agasthyamalai landscape;
Converts qualitative imperatives into quantitative, actionable steps via remote sensing, geo-mapping, and comparative forest-cover analytics;
Reiterates that in CCTH and tiger reserves, commercial activities—including plantations—cannot be permitted to undermine inviolate status.

Legal Reasoning and Principles Applied

1. Ecocentric constitutionalism and the climate imperative

The Court foregrounds the climate crisis and comparative forest-cover deficits, casting forests as the “lungs of the ecosystem.” It adopts ecocentrism, imposing a trustee duty on humans to protect non-human nature (rivers, forests, mountains) and recognizes that the burdens of environmental degradation fall most heavily on the poor—a constitutional equality dimension.

2. Statutory architecture and compliance

Tamil Nadu Forest Act, 1882 (Section 16): The Singampatti lands stand finally notified as Reserved Forests—a status carrying strict limitations on rights and activities. The order records that a due claims-settlement process preceded notification.
Forest (Conservation) Act, 1980 (Section 2): Any assignment or lease/use of forest land for non-forest purposes requires prior Central Government approval; the affidavit evidence before the High Court emphasized this mandate.
Wildlife (Protection) Act, 1972: The lands are within a Tiger Reserve and notified as Core Critical Tiger Habitat (CCTH)—a category envisaging “inviolate” areas for tiger conservation, with relocation protocols. The order underscores CCTH meriting the “highest level of protection.”

3. Landscape-scale lens and scientific methods

The defining feature of the order is its shift from parcel-specific disputes (a single estate) to a landscape-scale intervention that:

Spans multiple protected units (Periyar TR, Srivilliputhur Grizzled Squirrel WLS, Meghamalai WLS, Thirunelveli WLS);
Insists on comprehensive, satellite-backed mapping (remote sensing, geo-mapping) to identify encroachments and non-forest uses;
Demands comparative data (past vs present cover) to quantify degradation;
Links tiger habitats with elephant corridors and reserved forests into an integrated restoration blueprint.

4. Institutional design and phased adjudication

The Court re-embraces the CEC as an expert, field-oriented arm that can gather evidence, validate facts, and propose measures. It fixes a timeline and schedules future hearings—typical of continuing mandamus—to enable iterative, calibrated, and enforceable directions. Worker rehabilitation is not ignored; it is sequenced for separate, focused adjudication.

Key Directions at a Glance

CEC to survey the entire Agasthyamalai landscape, including Periyar TR, Srivilliputhur Grizzled Squirrel WLS, Meghamalai WLS, and Thirunelveli WLS.
Identify all non-forestry activities contrary to the FCA, 1980 and WLPA, 1972.
Supply comparative forest cover data (historical vs current) for degradation assessment.
Recommend restoration measures for reserved forests, core tiger habitats, elephant corridors, and other sanctuaries.
Use scientific tools: remote sensing, satellite imagery, geo-mapping.
State/district administrations, police, and forest officials to fully assist the CEC.
Timeframe: 12 weeks; list on 15 July 2025 for CEC report; worker rehabilitation issues on 22 April 2025.

Impact and Implications

1. A template for landscape-scale, data-driven enforcement

By explicitly mandating a landscape-level audit that integrates multiple protected areas and corridors, the Court sets a workable template for other biodiversity hotspots. Expect replication in the Western Ghats (Nilgiris–Anamalai), Eastern Himalayas, Central Indian tiger landscapes, and Aravallis—where fragmented enforcement has historically undermined ecological integrity.

2. Strengthening the “inviolate” character of Core Critical Tiger Habitats

The order’s framing reaffirms that CCTH must receive the highest protection, operationalizing statutory intent under the WLPA. This bolsters administrative resolve to phase out incompatible uses, including plantations, from core habitats, subject to lawful rehabilitation and resettlement.

3. Renewed emphasis on geospatial evidence and accountability

Requiring remote sensing and comparative cover datasets embeds objectivity into encroachment detection and restoration baselining. This can reduce factual contestation and accelerate corrective action, including boundary demarcation and fence/beat realignment.

4. Worker rights: sequenced but not sidelined

The Court consciously separates ecological restoration from socio-economic rehabilitation, ensuring each gets focused adjudication. The April 2025 hearing will be crucial for devising humane, lawful, and durable solutions—particularly where plantations overlapped with reserved forests and tiger habitats. The State’s submission that relocation/rehabilitation is “complete,” if accurate, will be tested against statutory standards and fairness benchmarks.

5. Implications for legacy leases and zamindari-era conversions

The case flags a broader problem: historical conversions of forest lands into “revenue” lands or plantations under zamindari-era leases. The FCA’s 1980 embargo, read with reserved forest notifications and WLPA protections, will likely drive a legal reckoning across similarly situated estates. Pending challenges (like BBTCL’s) will need to reckon with this reinforced ecocentric and statutory compliance matrix.

6. Institutional coordination and field protection

While the Court has not yet directed the cessation/removal of government facilities within reserved forests, it has signaled an enforcement pivot. The Amicus’s prayer for protecting forest staff from malicious prosecutions during evictions is a reminder: meaningful restoration often hinges on frontline safety and coordinated district-level support. Future directions may address these operational safeguards after the CEC’s findings.

Complex Concepts Simplified

Reserved Forest: A legal category under state forest laws (here, Tamil Nadu Forest Act, 1882, Section 16) for lands formally notified as forests after settling claims. Activities are heavily regulated; unauthorized occupation/cultivation constitutes encroachment.
Forest (Conservation) Act, 1980 (FCA): A central law that requires prior approval of the Central Government for any diversion of forest land to non-forestry purposes and for leasing/assignment of forest land. It is a cornerstone against post-1980 diversions.
Wildlife (Protection) Act, 1972 (WLPA): Provides for declaring wildlife sanctuaries, national parks, and tiger reserves; regulates activities within these protected areas.
Critical Tiger Habitat (CCTH): The “core” of a notified Tiger Reserve under Section 38V, WLPA—an area identified to be kept inviolate for tiger conservation. Human habitation is ordinarily relocated pursuant to law, with due process and compensation/rehabilitation.
Tiger Reserve: A legally designated area for conserving tigers, typically with a core (CCTH) and a buffer, managed under WLPA and NTCA guidelines.
Elephant Corridor: A functional, often linear habitat connecting elephant ranges. Fragmentation or obstruction can cause human–elephant conflict and ecological harm; protection is an increasingly recognized conservation priority.
Non-forestry Activity: Under the FCA, activities not ancillary to forest conservation/management, including cultivation, settlements, infrastructure (unless permitted), mining, etc., require central approval; in protected areas and CCTH, the restrictions are even stricter.
Central Empowered Committee (CEC): An expert committee created under Supreme Court directions in the Godavarman matters to assist with monitoring, fact-finding, and recommending measures in forest/wildlife cases.
Continuing Mandamus: A judicial device whereby the court retains seisin of a matter and issues iterative directions over time, often involving expert reports, to secure compliance in complex public law contexts.
Landscape Approach: Conservation planning that treats ecologically connected units (forests, sanctuaries, corridors) as a single functional system, rather than dealing with isolated parcels; it aligns with modern conservation science.
Agasthyamalai Biosphere Reserve: Part of the Western Ghats, recognized under UNESCO’s Man and Biosphere Programme; contains high endemism, river systems, and critical habitats (including Kalakkad–Mundanthurai Tiger Reserve).
Traditional Forest Dwellers (context note): The affidavit before the High Court claimed plantation workers were largely migrants and not “traditional forest dwellers.” Under the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006, “other traditional forest dwellers” must prove residence and resource-dependence for at least three generations (75 years) prior to 13 December 2005, apart from other criteria. The Supreme Court has not adjudicated FRA claims here; that question remains open.

How the Court Balanced Competing Concerns

The order delicately balances immediate ecological imperatives with socio-economic realities:

It accelerates landscape-scale restoration via the CEC’s scientific audit and recommendations, recognizing CCTH as paramount.
It reserves and schedules the distinct, rights-sensitive inquiry into worker compensation and rehabilitation for a dedicated hearing, signaling that ecological protection and human dignity are not mutually exclusive but must be addressed through lawful sequencing.

Potential Next Steps and Compliance Considerations

Boundary Demarcation: High-resolution satellite mapping, ground-truthing, and GPS demarcation of reserved forest and CCTH boundaries.
Encroachment Inventory: Classification of non-forestry uses by type (plantations, habitations, infrastructure) with legal status and timelines.
Restoration Plan: Prioritized ecological restoration for core areas; phased withdrawal of incompatible uses; native species reforestation, riparian restoration, and invasive control.
Human Dimensions: For any required relocations, adherence to WLPA/NTCA protocols; fair compensation; livelihood-linked rehabilitation; community participation.
Institutional Safeguards: Protocols for field staff protection during sensitive operations; district-level coordination cells; grievance redress; public communication.
Monitoring and Verification: Periodic satellite audits to measure canopy recovery, corridor functionality, and wildlife use; transparent reporting to the Court.

Conclusion

The Supreme Court’s order in A. John Kennedy v. State of Tamil Nadu crystallizes a crucial evolution in India’s forest jurisprudence: from parcel-specific disputes to landscape-scale, data-driven, ecocentric enforcement. By deploying the CEC to conduct a satellite-aided audit and produce a restoration blueprint covering reserved forests, core tiger habitats, elephant corridors, and sanctuaries, the Court both reaffirms and operationalizes the Godavarman legacy.

Equally notable is the Court’s institutional sensitivity: it separates ecological restoration from worker rehabilitation—ensuring neither is eclipsed, and both proceed through lawful, evidence-based processes. With climate change as a framing reality, and India’s forest cover lagging behind regional peers, this order lays down a replicable pathway for integrated conservation enforcement—anchored in statute, guided by science, and accountable to constitutional values.

Key takeaways:

Ecocentrism is not merely rhetorical; it is actioned through landscape-level mandates and scientific tools.
CCTH enjoys the highest protection—commercial plantations cannot undermine inviolate tiger habitats.
Remote sensing and comparative datasets will become standard in judicially supervised forest governance.
Continuing mandamus remains the judiciary’s preferred vehicle for complex environmental compliance.

The forthcoming CEC report and the April 2025 hearing on rehabilitation will shape the next phase. For now, the Court has set a clear direction: restoration first, grounded in evidence, to secure the long-term vitality of one of India’s most treasured landscapes.