Full Judgment Text
2025 INSC 1358
REPORTABLE
IN THE SUPREME COURT OF INDIA
EXTRA ORDINARY APPELLATE JURISDICTION
SPECIAL LEAVE PETITION (C) No (s).13374-13375 of 2025
NEW DELHI NATURE SOCIETY
THROUGH VERHAEN KHANNA ….PETITIONER(S)
VERSUS
DIRECTOR HOTRICULTURE
DDA & ORS. ….RESPONDENT(S)
O R D E R
Mehta, J.
Table of Contents
I. INTRODUCTION ......................................................... 2
II. BACKGROUND OF THE CASE .................................... 3
III. PROCEEDINGS BEFORE THIS COURT .................... 13
IV. DISCUSSION AND ANALYSIS .................................. 21
V. DIRECTIONS ........................................................... 27
VI. CONCLUSION ......................................................... 30
Digitally signed by
NEETU KHAJURIA
Date: 2025.11.26
16:43:15 IST
Reason:
Signature Not Verified
1
I. INTRODUCTION
1. The controversy in the instant case centres
around the proposed translocation of hundreds of
deer from the A.N. Jha Deer Park in Hauz Khas, New
1
Delhi , an urban green sanctuary for captive deer, to
different wildlife sanctuaries/Tiger reserves in the
State of Rajasthan as well as within New Delhi. The
translocation sought to be undertaken ostensibly on
the pretext of overcrowding, is alleged to be in
contravention of the norms established by the
Central Zoo Authority, Ministry of Environment,
2
Forest & Climate Change, Government of India ,
guidelines framed under the Wild Life (Protection)
Act, 1972, as well as the International Union for
Conservation of Nature Guidelines for
Reintroductions and Other Conservation
3
Translocations.
4
2. The Petitioner-New Delhi Nature Society filed a
5
public interest litigation Writ Petition before the High
1
Hereinafter, being referred to as 'Deer Park’.
2
Hereinafter, being referred to as 'Central Zoo Authority’.
3
Hereinafter, being referred to as ‘ICUN Guidelines’.
4
Hereinafter, being referred to as ‘petitioner-Society’.
5
Writ Petition (C) No. 12275 of 2023.
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SLP (C) No(s). 13374-13375 of 2025
6
Court of Delhi , challenging the proposal for
translocation of the deer mooted by the authorities,
th
which came to be disposed of vide order dated 19
7
July, 2024. A subsequent application seeking the
th
recall of the order dated 19 July, 2024, was
th
dismissed by the High Court vide order dated 24
January, 2025. These two orders form the subject
matter of challenge in the present special leave
petitions.
3. We now turn to the facts underlying the present
proceedings, the submissions advanced by the
parties, and the issues that emerge, to determine
whether the intervention of this Court is warranted
and whether any corrective or consequential
directions, are required.
II. BACKGROUND OF THE CASE
8
4. In 1968, the Delhi Development Authority
established the Deer Park, namely, Aditya Nath Jha
Deer Park (commonly called AN Jha Deer Park),
within the larger green expanse of Hauz Khas Park,
South Delhi. The total green area measures
6
Hereinafter, being referred to as ‘High Court’.
7
CM Application No. 49658 of 2024.
8
Hereinafter referred to as ‘DDA’.
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approximately 142.30 hectares, of which 10.26 acres
were originally earmarked for the deer enclosure,
subsequently increased to 10.97 acres by the year
2021. In 1968, the DDA introduced a population of
chital/spotted deer ( Axis axis ) brought from the State
of Uttarakhand, making the Deer Park, apart from
the Delhi Zoo ( a.k.a. National Zoological Park, New
Delhi), the only urban setting in the capital city where
the public could view spotted deer in a semi-natural
environment. Over the years, the Deer Park has
evolved into a significant ecological and recreational
space, attracting not only visitors but also a variety
of small mammals, birds, reptiles, insects, and
nocturnal species. It also has specific sections for
ducks and rabbits’ enclosures. The Deer Park, along
with adjacent public parks, makes up one of the
largest lush green areas in the capital city, for which
it is given the name of the ‘lungs of Delhi.’
5. The DDA operated the Deer Park under a license
issued by the Central Zoo Authority, a statutory body
constituted under the Wild Life (Protection) Act, 1972
and functioning under the Ministry of Environment,
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9
Forest and Climate Change. The Central Zoo
Authority is tasked with enforcing standards for the
upkeep, veterinary care, and management of captive
animals as outlined in the National Zoo Policy, 1998
and the Zoo Rules, 2009. In 2014, the Central Zoo
Authority cancelled DDA’s license due to persistent
mismanagement and non-compliance with the Zoo
guidelines. The licence was reinstated only upon
DDA’s assurance that it would adopt corrective
measures, including population control of deer,
regular veterinary checks, and the segregation of
males and females to prevent inbreeding.
6. Despite such assurances, the Evaluation
Reports of the Deer Park of 2014-2022 indicate
continued non-compliance with the applicable
guidelines and rules. The Central Zoo Authority, in
its evaluation report, noted multiple violations,
including the failure to contain the deer population
despite repeated advisories regarding sterilisation
and enclosure management. By 2021, DDA had only
one curator and one retired veterinary officer
assigned to monitor animal health. Although the
9
Hereinafter referred to as “MoEF&CC.”
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Central Zoo Authority granted interim extensions,
the last valid licence expired in 2021. While DDA
applied for a renewal, it concurrently informed the
Central Zoo Authority of its decision to close the Deer
Park and sought approval for the translocation of the
entire deer population to Rajasthan and Asola Bhatti
th
Wild Life Sanctuary, Delhi. On 19 May, 2022, the
DDA wrote a letter to the Chief Wild Life Warden,
10
Rajasthan , requesting to accept the translocation of
approximately 550 spotted deer to a designated
sanctuary in Rajasthan, citing administrative
incapacity to manage the growing population of deer.
th
The CWLWR vide letter dated 27 May, 2022,
conveyed assent to the request made by the DDA for
the translocation of approximately 550 spotted deer
from the A.N. Jha Deer Park, New Delhi, to
designated national parks or wildlife sanctuaries in
Rajasthan. The Rajasthan Wild Life Department,
prior to final approval, forwarded a checklist of
mandatory conditions to DDA, outlining procedural
and welfare safeguards to be followed during the
animal transfer. These conditions inter alia included
10
Hereinafter referred to as “CWLWR”.
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a prohibition on the transfer of pregnant, recently
bred, aged, or infirm animals as well as mandatory
adherence to the Guidelines for the Establishment
and Scientific Management of Zoos in India, 2008.
The Department, further, directed that the
transportation of deer be timed to minimize climate-
induced stress on the animals, particularly avoiding
peak summer periods.
7. After consideration of the translocation
proposal by the Technical Committee, Central Zoo
th
Authority vide order dated 8 June, 2023, issued
under Section 38H(6) of the Wild Life Act, cancelled
the recognition of A.N. Jha Deer Park, Hauz Khas,
New Delhi, citing persistent non-compliance with zoo
management norms, failure to control deer
population, and expiry of the licence in August, 2021.
After evaluating the DDA’s proposal and confirming
the translocation of approximately 600 spotted deer,
the Central Zoo Authority directed that the animals
be released into natural habitats in Rajasthan and
Delhi in a 70:30 ratio (70% in Rajasthan
sanctuaries/reserves and 30% in Asola Bhatti Wild
Life Sanctuary in the National Capital Territory of
Delhi), in accordance with IUCN guidelines.
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8. Aggrieved by the decision of the Central Zoo
th
Authority dated 8 June, 2023, cancelling the
recognition of Deer Park and approving the
translocation of approximately 600 spotted deer to
Rajasthan and Asola Bhatti Wild Life Sanctuary,
Delhi, the petitioner-Society, which is an NGO
working on the promotion of nature awareness and
conservation in Delhi, filed a public interest litigation
via Writ Petition (C) No. 12275 of 2023 before the
High Court of Delhi under Article 226 of the
Constitution, contending inter alia that the
concerned authorities cancelled the license in gross
11 12
violation of Section 38H(4) and (6) of the Wild Life
(Protection) Act, particularly, as the order failed to
record reasons in writing for cancellation of the
licence. It was further alleged that the CWLWR, and
the Department of Forest and Wildlife, Government
of NCT of Delhi, had failed to comply with mandatory
conditions prescribed by the Central Zoo Authority
11
Section 38H(4): No recognition to a zoo shall be granted unless the
Authority, having due regard to the interests of protection and
conservation of wild life, and such standards, norms and other matters as
may be prescribed, is satisfied that recognition should be granted.
12
Section 38H (6): The Authority may, for reasons to be recorded by it,
suspend or cancel any recognition granted under sub-section (4): Provided
that no such suspension or cancellation shall be made except after giving
the person operating the zoo a reasonable opportunity of being heard.
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and the IUCN Guidelines for translocation of captive
wildlife. The petition, filed in public interest, sought
the following reliefs:
“(a) Direct the Respondent DDA to ensure strict
compliance with the CZA and IUCN guidelines
during the translocation of the deer;
(b) Direct the Respondents not to translocate
pregnant animals, newly bred young calves, or
antlered animals in velvet, and to ensure that
only animals in good health are transported;
(c) Direct the Respondents not to release the
animals in areas where they may become prey,
such as the Asola Sanctuary;
(d) Direct the DDA to retain the animals that
cannot be translocated within the Deer Park area
and not to close down the Park.”
9. During the course of hearing of the writ petition
before the High Court, the petitioner-Society pointed
out that around 80 deer had already been moved
without adherence to the 2014 IUCN Guidelines,
which prohibit the translocation of vulnerable
categories like pregnant or antlered deer. Vide order
th
dated 6 December, 2023, the High Court granted a
stay on the translocation of the deer, with the
following observations:
“5. This Court is of the prima facie view that at
least fifty (50) deers as originally envisaged
should be retained so that small children of this
city get to see them. The respondents may also
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SLP (C) No(s). 13374-13375 of 2025
consider relocating the excess population of
deers in forests and green areas of Delhi. This
Court is further of the prima facie view that as
Rajasthan has too many leopards, not many
deers may survive the relocation.
x-x-x
8. Till further orders, there shall be a stay of
translocation of deers from A.N. Jha Deer Park,
Hauz Khas, New Delhi.”
th
10. The High Court vide Order dated 19 July,
2024, disposed of the above writ petition, while
taking into consideration an Additional Affidavit filed
th
by the DDA on 18 July, 2024. The Affidavit stated
that, as a policy decision approved by the Vice
Chairman of DDA and endorsed by the Lieutenant
Governor of Delhi, about two dozen deer would be
retained at the Deer Park, subject to the renewal of
its mini-zoo status by the Central Zoo Authority. The
DDA would approach the Central Zoo Authority for
requisite approvals, while the remaining deer could
be relocated to forest areas in neighbouring states.
The affidavit also highlighted concerns around
Delhi’s limited carrying capacity and the risks of
poaching if deer were relocated within the city. In
view of the DDA’s willingness to abide by the
guidelines, the High Court allowed the DDA to
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SLP (C) No(s). 13374-13375 of 2025
resume the translocation process in accordance with
the terms stated in the affidavit and disposed of the
matter accordingly. The relevant paragraphs of the
order are extracted hereinbelow:
“3. Learned counsel for DDA, has today in Court,
th
handed over an additional affidavit dated 18 July
2024, wherein it has been averred as under: -
“III. That pursuant to the Orders passed
by this Hon'ble Court in this case, the
matter has been examined by DDA. The
Vice Chairman, DDA being the competent
authority has approved the proposal of
retaining some deer in the A.N. Jha Mini
Zoo at Hauz Khas, New Delhi (the Deer
Park) after taking necessary approvals
from the Central Zoo Authority (CZA) vide
File No. HORT/PC/0020/ 2020/DHSE/-
O/o DY.DIR(HORT. DIV-IV) (Computer
No.7673) # Note 92. It has been approved
that as a policy decision in supersession
of earlier decisions on the subject, the
DDA would retain some deer in the Deer
Park and for that purpose, DDA shall
move the CZA for the necessary approvals
and compliance would be made as per the
requirements of CZA guidelines. This
matter has also stands verbally discussed
with the Hon'ble Lieutenant Governor,
Delhi / Chairman, DDA and the Hon'ble
LG has also agreed to the proposal.
IV. That in these circumstances, it is
submitted that the DDA will retain about
two dozen of deer in the Deer Park subject
to the renewal of recognition of mini zoo
status of A.N. Jha Mini Zoo by the CZA.
The remaining deer can be transferred to
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neighbouring states forest areas as per
the earlier decision on the subject. DDA
shall accordingly move the necessary
proposal before the CZA for approval and
renewal of recognition.
V. That it is respectfully submitted that
subject to above, this Hon'ble Court may
allow to resume translocation of deer so
that overcrowding of deer may be
managed at A.N. Jha Mini Zoo at Hauz
Khas, New Delhi.”
4. Learned counsel for the petitioner is satisfied with
the additional affidavit dated 18th July 2024 filed by
the DDA.
5. Keeping in view the aforesaid additional affidavit
dated 18th July 2024 as well as the consent of
learned counsel for the petitioner, the present writ
petition is disposed of in accordance with
paragraphs III, IV and V of the said affidavit. It is
clarified that DDA is at liberty to act in accordance
with the said additional affidavit.”
11 . Following the disposal of the writ petition on
th 13
19 July, 2024, an application was filed seeking the
recall of the above order on the ground that the
petitioner-Society’s lawyer had conveyed its consent
without informing the petitioner-Society. However,
the High Court, after examining the entire record,
found no justifiable grounds to recall its earlier order
th
and accordingly vide Order dated 24 January, 2025,
13
Supra note 7.
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dismissed the recall application. Consequently, in
light of this dismissal, the High Court also held that
no further orders were necessary in the connected
14
application seeking stay.
th
12 . The aforesaid orders dated 19 July, 2024, and
th
24 January, 2024 passed by the High Court in Writ
Petition (C) No. 12275 of 2023, are subject matter of
challenge in the present special leave petitions.
III. PROCEEDINGS BEFORE THIS COURT
13. During the pendency of these petitions, this
Court, taking into consideration the gravity of the
matter and the fact that a total of 261 deer were
translocated to Rajasthan, directed the Central Zoo
Authority to visit the locations where 261 deer have
already been transferred and ascertain the present
condition of the said deer. The relevant paragraphs of
the order are reproduced hereinbelow:
“ We are informed that so far 261 deers have
been shifted to Rajasthan. The learned
counsel appearing for the petitioner makes a
grievance that many of these deers are no
longer surviving. We direct a team of officers
of the Central Zoo Authority (the second
14
The Application, seeking stay, is CM Application No. 48098 of 2024.
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respondent) to immediately visit the place or
places where the 261 deers have been
transferred. They shall ascertain the present
condition of the said deers.
The officers of the Central Zoo Authority will give
an advance notice of their visits to the petitioner
so that a representative of the petitioner can
remain present.
A report to be submitted by the Central Zoo
Authority about the condition of the deers within
a period of two weeks from today. A copy of the
report shall be furnished to the learned counsel
appearing for the petitioner. In the event it is
found that either the deers are not surviving
or they are in bad condition, we grant liberty
to the petitioner to move this Court by filing
an appropriate application.
x-x-x
In the meanwhile, we direct the Delhi
Development Authority and the Central Zoo
Authority (the first and the second respondents
respectively) to consider the suggestion made in
paragraph 11 of the application made by the
petitioner at Annexure P-10 and file a response
to the same within a period of six weeks from
today.”
14 . In pursuance of this order, the DDA, through its
authorised officer, has filed a short affidavit. In the
said affidavit, the DDA has submitted that:
i) It has no objection to the relocation of the
remaining deer from the A.N. Jha Deer Park
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to any suitable location, including the
proposed Deer Park at Noida, subject to
obtaining prior approval and directions
from the Central Zoo Authority, which is a
mandatory prerequisite for any
translocation of captive animals. Letters
seeking such approval and clarification
were sent to the Central Zoo Authority on
th th
30 May, 2025 and 8 July, 2025,
respectively.
ii) The decision to translocate the deer was
prompted by overpopulation in the Deer
Park, which was causing strain on available
resources and affecting the health and well-
being of the animals. A total of 261 deer
have been translocated to forest areas in
Rajasthan using the BOMA method, an
internationally recognised technique for
safe wildlife capture and relocation. This
process was undertaken with the
assistance of the Rajasthan Forest
Department and a senior veterinary expert,
ensuring compliance with the guidelines
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SLP (C) No(s). 13374-13375 of 2025
issued by the Central Zoo Authority and
IUCN Guidelines.
iii) The DDA further submitted that the
remaining deer population in the park
continues to receive routine veterinary care,
including regular deworming and provision
of daily rations and green fodder as per the
recommendations of the Central Zoo
Authority. It was reiterated that no deer has
been translocated to the Asola Bhatti Wild
Life Sanctuary, Delhi thus far, and that the
DDA has acted strictly in accordance with
applicable legal and regulatory framework,
prioritising both animal welfare and
ecological balance.
15 . In pursuance of the liberty granted by this
th
Court vide order dated 16 May, 2025, the petitioner-
15
Society has filed an application seeking directions
in view of alarming findings during the Court-
permitted field survey of the deer translocation
project from A.N. Jha Deer Park, Hauz Khas, Delhi to
Mukundara Hills Tiger Reserve (Rajasthan) and
15
Interlocutory Application No. 164887 of 2025.
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Ramgarh Vishdhari Tiger Reserve (Rajasthan). In its
application for direction, the petitioner-Society has
submitted that:
i) The petitioner-Society was permitted to join
the Central Zoo Authority in its post-
translocation field inspections at A.N. Jha
Deer Park, Mukundara Hills Tiger Reserve
(Rajasthan) and Ramgarh Vishdhari Tiger
Reserve (Rajasthan). Based on the field
observations, the petitioner-Society avers
that serious discrepancies exist between
the number of deer stated to have been
translocated and the number actually
sighted. Of the 100 deer claimed to be
translocated to Ramgarh Vishdhari Tiger
Reserve (Rajasthan), only 60-62 were seen,
and of the 161 said to be sent to
Mukundara Hills Tiger Reserve (Rajasthan),
only 52-53 were visible. Further, there were
no visible tags or chips on any deer, making
it impossible to ascertain their origin or to
conduct post-release monitoring.
ii) The application highlights critical violations
in the process of transportation and release.
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Several deer were transported in
overcrowded trucks, including an instance
rd
on 3 November, 2023, when 40 deer and a
fawn were stuffed into one vehicle. No
photographic record or documentation of
vehicle dimensions or welfare compliance
was submitted by DDA. The deer endured
long journeys without veterinary
assistance, sedation, food, or water. The
petitioner-Society contends that many deer
perished due to stress, starvation, or
predation post-release, a claim further
substantiated by findings of scattered
16
bones and a rope tied to a deer bone ,
suggesting use of deer as live bait in
predator-inhabited zones.
iii) The petitioner-Society specifically points
out that contrary to express assurances in
th
the DDA’s affidavit dated 30 October,
2023, pregnant female deer and juvenile
deer were translocated. The officials not
only failed to identify and segregate
16
Annexure 1 of the Application.
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vulnerable animals, but also translocated
them, including the juveniles being
transported with 40 adults in a single truck.
These acts constitute contempt of this
Court’s previous orders and breach of
guidelines issued by the Central Zoo
Authority and the IUCN Guidelines.
iv) The application further alleges that the
reserves to which the deer were
translocated lacked basic ecological
support, such as grasslands or shrubs for
grazing. Google Maps analysis and on-site
inspection revealed that vegetation was
sparse and water sprinklers, though
claimed in reports, were not operational. No
habitat suitability study appears to have
been conducted prior to translocation,
violating fundamental prerequisites laid
down under the guidelines. The Central Zoo
Authority’s claims that no tigers existed in
the reserves were refuted by government
data and newspaper reports showing the
presence of multiple tigers in Mukundara
Hills Tiger Reserve (Rajasthan) and
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Ramgarh Vishdhari Tiger Reserve
(Rajasthan), thus directly endangering the
deer.
v) Turning to the Deer Park itself, the
application alleges gross mismanagement
and possible corruption. While the Central
Zoo Authority report claims that 393 deer
were housed in the park as of May, 2025,
petitioner-Society’s on-ground investigation
showed only 70-80 deer visible at feeding
time. Moreover, the food provided per day
amounted to only 260 kg (green fodder and
grain), which suffices for merely 84 deer,
assuming a minimum requirement of 3 kg
per deer per day. This discrepancy, the
petitioner-Society argues, either reflects
mass starvation or falsified deer counts for
inflated funding. Additionally, basic
facilities such as water troughs were empty,
with only one out of four having water, and
the grains therein were fermenting, raising
fears of deaths from enterotoxaemia .
vi) Lastly, the application criticises the Central
Zoo Authority field survey as perfunctory,
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opaque, and dismissive of the petitioner-
Society’s right to participate in the said
survey. The leadership of the survey team
excluded representatives of the petitioner-
Society from meetings, refused to share
documents, and appeared to rubber-stamp
the narrative advanced by the respondents.
In light of the grave irregularities, statutory
violations, and acts of cruelty disclosed in the present
application, the petitioner-Society respectfully
prayed that this Court may be pleased to grant: (i) a
permanent stay on further translocation of deer; (ii) a
third-party wildlife expert survey of A.N. Jha Park;
(iii) restoration and safety measures for already
translocated deer; (iv) penal action against erring
officials; and (v) an investigation into financial and
administrative irregularities.
IV. DISCUSSION AND ANALYSIS
16. We have given our thoughtful consideration to
the submissions advanced at the bar and have gone
through the impugned orders. With the assistance of
learned counsel for the parties, we have also perused
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the pleadings, affidavits, and material placed on
record.
17. The material placed on record reveals that the
A.N. Jha Deer Park, despite its historical and
ecological significance, has for several years suffered
from chronic managerial deficiencies. The repeated
extensions granted by the Central Zoo Authority and
the warnings issued from time to time demonstrate
that the Deer Park was operating 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 Evaluation
Reports of 2014-2022 underscores persistent non-
compliance relating to enclosure maintenance,
veterinary infrastructure, record-keeping, population
control, and habitat enrichment. The absence of
adequate segregation, sterilisation, and monitoring
mechanisms inevitably led to an exponential increase
in the deer population, far exceeding the carrying
capacity of the 10.97-acre enclosure. In such
circumstances, the need for scientific population
management through regulated translocation was
not only foreseeable but also indispensable for the
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health, welfare, and sustainability of the deer
population.
18. It is equally evident that the DDA lacked the
requisite logistical and veterinary
preparedness/capacity to manage a population that
fluctuated between 350 to 600 deer over the past
decade. The Deer Park’s spatial limitations and the
scarcity of foraging resources meant that natural
behaviours, such as browsing, territoriality, and herd
structuring, could not be accommodated within the
confined enclosure. Overcrowding in captive
ungulate species is known to heighten stress, weaken
immunity, and precipitate outbreaks of disease. The
insufficiency of fodder, irregular water supply, and
dearth of veterinary supervision, as reflected from the
petitioner-Society’s assertions and supported by field
reports/observations, raise serious concerns about
the welfare of the remaining population. In these
circumstances, continued retention of entirety of the
remaining population of deer at the Deer Park would
be contrary to the very principles of animal welfare
enshrined under domestic laws and international
conservation protocols.
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19. At the same time, the submissions and field-
survey based averments made by the petitioner-
Society regarding irregularities in the translocation
already undertaken cannot be lightly brushed aside.
Allegations that vulnerable categories of deer,
including pregnant females, juveniles, and
antlered males, were transported; that
overcrowding occurred inside vehicles; that post-
release monitoring mechanisms were inadequate;
and that the chosen release sites lacked assured
habitat suitability, are all matters that strike at
the core of scientific translocation practice. The
IUCN Guidelines emphasize that any relocation of
captive wildlife must be supported by ecological
feasibility studies, veterinary screening, tagging
or identification processes, and structured post-
release surveillance. These safeguards appear,
prima facie , to have been applied in a perfunctory or
incomplete manner, thereby undermining the
legitimacy of the exercise and the welfare of the
animals involved.
20. It is evident from the record that the
translocation protocol and best practices
incorporated in the guidelines issued by the Central
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Zoo Authority and IUCN Guidelines were not adhered
to during the translocation of deer from Deer Park to
Ramgarh Vishdhari Tiger Reserve and Mukundra
Hills Tiger Reserve in the State of Rajasthan. There is
no documentary evidence of pre-translocation genetic
screening, tagging, tranquilisation protocols,
veterinary fitness certification, or behavioural
acclimatisation, all of which are internationally
recognised preconditions for release. Notably, no
scientific assessment was carried out with respect to
the carrying capacity of the recipient sanctuaries in
Rajasthan, the predator-prey dynamics, or the
impact of introducing semi-captive deer into those
ecosystems. The translocated deer, many of whom
were zoo-bred, and some reportedly pregnant or
juvenile, were moved to tiger-bearing sanctuaries,
without any indication of whether they possessed the
necessary survival skills or ecological fitness.
Photographic and field evidence brought on record by
the petitioner-Society points to a distressing pattern
of negligence. Deer were allegedly loaded into
overcrowded trucks, sometimes in groups as large as
40-50, without proper ventilation, padding, or
segregation. In one instance, a blue rope used to tie
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the limbs of a deer was reportedly recovered from the
relocation site, raising serious concerns about the
use of force and the absence of ethical handling
procedures. Moreover, no tracking mechanisms such
as telemetry collars, radio chips, or post-release
surveys were done to monitor the well-being or
survival of the released animals. Without such data,
it is not possible to determine how many deer
survived the journey or successfully adapted to their
new environments.
21. Given the competing claims and the absence of
a verified factual foundation regarding (i) the actual
number of deer presently in the Deer Park, (ii) the
number of deer translocated and surviving at the
release sites, and (iii) the ecological viability of
further translocation of deer, this Court is of the view
that an independent, scientifically-grounded
assessment is essential before any further steps can
be permitted. In our opinion, the Central
Empowered Committee (CEC) , constituted by this
Court [now working under a Statute, namely,
Environment (Protection) Act, 1986] vested with
expertise in forest-wildlife governance, is best placed
to undertake such an evaluation. A comprehensive
26
SLP (C) No(s). 13374-13375 of 2025
assessment is required not only to ascertain
compliance with statutory norms but also to restore
confidence in the decision-making process and
ensure that any future translocation conforms
strictly to the ethical, ecological, and legal standards
binding upon all agencies.
V. DIRECTIONS
22. In light of the foregoing discussion, and to
ensure that the welfare of the deer population is
secured in accordance with the statutory framework
prevailing in India and internationally accepted
conservation guidelines/norms, we issue the
following directions:
A. The Central Empowered Committee (CEC)
shall conduct an on-ground survey of A.N. Jha
Deer Park and file a detailed report before this
Court within eight weeks. The report shall
specifically enumerate:
i. the present population of deer in the Deer
Park;
ii. the ecological carrying capacity of the
Deer Park, based on space, fodder
27
SLP (C) No(s). 13374-13375 of 2025
availability, veterinary infrastructure, and
enclosure design;
iii. the maximum number of deer that can be
sustainably and humanely maintained at
the Deer Park; and
iv. the surplus population, if any, that must
be considered for translocation.
B. The CEC shall further undertake an inspection
of the release sites, i.e., Ramgarh Vishdhari
Tiger Reserve and Mukundra Hills Tiger Reserve
in the State of Rajasthan and file a status report
within eight weeks. The report shall specifically
enumerate:
i. the number of deer actually present and
surviving;
ii. habitat suitability, availability of forage
and water, predation risks, and mitigation
measures;
iii. veterinary monitoring mechanisms and
post-release protocols;
iv. compliance with guidelines issued by the
Central Zoo Authority and the IUCN
Guidelines.
28
SLP (C) No(s). 13374-13375 of 2025
C. The CEC shall also prepare a comprehensive
roadmap for any future translocation, detailing
the scientific methodology, identification and
tagging processes, procedural safeguards,
transportation protocols, veterinary
requirements, ecological feasibility studies, and
post-release monitoring framework, in strict
conformity with the domestic statutory regime
and IUCN Guidelines.
D. All concerned authorities shall extend full
cooperation to the CEC , ensuring timely
support, information sharing, and access to
necessary sites, required for implementing
these directions. Any failure or delay in
compliance shall invite appropriate action.
E. The DDA shall, within eight weeks, 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 the Evaluation Reports.
F. The DDA is directed to refrain from organizing,
permitting, or facilitating any commercial
events, private parties, or non-conservation
29
SLP (C) No(s). 13374-13375 of 2025
related gatherings within the premises of the
A.N. Jha Deer Park or its surrounding ecological
buffer zones. The use of the said park for such
purposes is inconsistent with its designation as
an urban ecological zone and captive animal
enclosure. Instead, DDA may develop and
implement a non-commercial public outreach
programme, which shall include periodic
educational visits for school and college
students, guided nature walks in collaboration
with recognized environmental NGOs, and
biodiversity awareness campaigns, in order to
foster a culture of ecological sensitivity and civic
participation in conservation efforts.
G. Until further orders of this Court, no additional
translocation of deer from A.N. Jha Deer Park
shall be carried out by the respondents or any
other authority.
VI. CONCLUSION
23. The aforesaid directions are being issued for
securing the constitutional regime that governs
environmental protection and the humane treatment
of wildlife in this country. Articles 48A and 51A(g) of
30
SLP (C) No(s). 13374-13375 of 2025
the Constitution of India embody a collective
commitment to safeguard forests and wildlife and to
act with compassion for all living beings, while Article
21 has been judicially recognized as encompassing
the right to a clean and ecologically balanced
environment. The concerns arising from
overcrowding, resource constraints, and managerial
lapses at the A.N. Jha Deer Park, coupled with
questions regarding the scientific rigour of past
translocation efforts, underscore that wildlife
management cannot be approached as a matter of
administrative convenience. It must be anchored in
scientific assessment, ecological prudence, and
fidelity to constitutional values.
24. The present controversy also reflects the
broader pressures faced by urban ecological spaces,
where the coexistence of wildlife and expanding
human habitats demands heightened responsibility
and foresight. The deer population at the Deer Park
is a reminder that conservation is not merely the
relocation of animals but an exercise in stewardship:
preserving species, habitats, and the environmental
ethos enshrined in our constitutional framework. The
Court’s intervention is therefore guided by the
31
SLP (C) No(s). 13374-13375 of 2025
imperative that decisions affecting wildlife must
reinforce the principles of dignity, ecological integrity,
and intergenerational equity that lie at the heart of
this Court’s environmental jurisprudence.
th
25.
List again on 17 March, 2026, for receiving the
reports of the Central Empowered Committee and
the DDA.
….……………………J.
(VIKRAM NATH)
...…………………….J.
(SANDEEP MEHTA)
NEW DELHI;
NOVEMBER 26, 2025.
32
SLP (C) No(s). 13374-13375 of 2025
REPORTABLE
IN THE SUPREME COURT OF INDIA
EXTRA ORDINARY APPELLATE JURISDICTION
SPECIAL LEAVE PETITION (C) No (s).13374-13375 of 2025
NEW DELHI NATURE SOCIETY
THROUGH VERHAEN KHANNA ….PETITIONER(S)
VERSUS
DIRECTOR HOTRICULTURE
DDA & ORS. ….RESPONDENT(S)
O R D E R
Mehta, J.
Table of Contents
I. INTRODUCTION ......................................................... 2
II. BACKGROUND OF THE CASE .................................... 3
III. PROCEEDINGS BEFORE THIS COURT .................... 13
IV. DISCUSSION AND ANALYSIS .................................. 21
V. DIRECTIONS ........................................................... 27
VI. CONCLUSION ......................................................... 30
Digitally signed by
NEETU KHAJURIA
Date: 2025.11.26
16:43:15 IST
Reason:
Signature Not Verified
1
I. INTRODUCTION
1. The controversy in the instant case centres
around the proposed translocation of hundreds of
deer from the A.N. Jha Deer Park in Hauz Khas, New
1
Delhi , an urban green sanctuary for captive deer, to
different wildlife sanctuaries/Tiger reserves in the
State of Rajasthan as well as within New Delhi. The
translocation sought to be undertaken ostensibly on
the pretext of overcrowding, is alleged to be in
contravention of the norms established by the
Central Zoo Authority, Ministry of Environment,
2
Forest & Climate Change, Government of India ,
guidelines framed under the Wild Life (Protection)
Act, 1972, as well as the International Union for
Conservation of Nature Guidelines for
Reintroductions and Other Conservation
3
Translocations.
4
2. The Petitioner-New Delhi Nature Society filed a
5
public interest litigation Writ Petition before the High
1
Hereinafter, being referred to as 'Deer Park’.
2
Hereinafter, being referred to as 'Central Zoo Authority’.
3
Hereinafter, being referred to as ‘ICUN Guidelines’.
4
Hereinafter, being referred to as ‘petitioner-Society’.
5
Writ Petition (C) No. 12275 of 2023.
2
SLP (C) No(s). 13374-13375 of 2025
6
Court of Delhi , challenging the proposal for
translocation of the deer mooted by the authorities,
th
which came to be disposed of vide order dated 19
7
July, 2024. A subsequent application seeking the
th
recall of the order dated 19 July, 2024, was
th
dismissed by the High Court vide order dated 24
January, 2025. These two orders form the subject
matter of challenge in the present special leave
petitions.
3. We now turn to the facts underlying the present
proceedings, the submissions advanced by the
parties, and the issues that emerge, to determine
whether the intervention of this Court is warranted
and whether any corrective or consequential
directions, are required.
II. BACKGROUND OF THE CASE
8
4. In 1968, the Delhi Development Authority
established the Deer Park, namely, Aditya Nath Jha
Deer Park (commonly called AN Jha Deer Park),
within the larger green expanse of Hauz Khas Park,
South Delhi. The total green area measures
6
Hereinafter, being referred to as ‘High Court’.
7
CM Application No. 49658 of 2024.
8
Hereinafter referred to as ‘DDA’.
3
SLP (C) No(s). 13374-13375 of 2025
approximately 142.30 hectares, of which 10.26 acres
were originally earmarked for the deer enclosure,
subsequently increased to 10.97 acres by the year
2021. In 1968, the DDA introduced a population of
chital/spotted deer ( Axis axis ) brought from the State
of Uttarakhand, making the Deer Park, apart from
the Delhi Zoo ( a.k.a. National Zoological Park, New
Delhi), the only urban setting in the capital city where
the public could view spotted deer in a semi-natural
environment. Over the years, the Deer Park has
evolved into a significant ecological and recreational
space, attracting not only visitors but also a variety
of small mammals, birds, reptiles, insects, and
nocturnal species. It also has specific sections for
ducks and rabbits’ enclosures. The Deer Park, along
with adjacent public parks, makes up one of the
largest lush green areas in the capital city, for which
it is given the name of the ‘lungs of Delhi.’
5. The DDA operated the Deer Park under a license
issued by the Central Zoo Authority, a statutory body
constituted under the Wild Life (Protection) Act, 1972
and functioning under the Ministry of Environment,
4
SLP (C) No(s). 13374-13375 of 2025
9
Forest and Climate Change. The Central Zoo
Authority is tasked with enforcing standards for the
upkeep, veterinary care, and management of captive
animals as outlined in the National Zoo Policy, 1998
and the Zoo Rules, 2009. In 2014, the Central Zoo
Authority cancelled DDA’s license due to persistent
mismanagement and non-compliance with the Zoo
guidelines. The licence was reinstated only upon
DDA’s assurance that it would adopt corrective
measures, including population control of deer,
regular veterinary checks, and the segregation of
males and females to prevent inbreeding.
6. Despite such assurances, the Evaluation
Reports of the Deer Park of 2014-2022 indicate
continued non-compliance with the applicable
guidelines and rules. The Central Zoo Authority, in
its evaluation report, noted multiple violations,
including the failure to contain the deer population
despite repeated advisories regarding sterilisation
and enclosure management. By 2021, DDA had only
one curator and one retired veterinary officer
assigned to monitor animal health. Although the
9
Hereinafter referred to as “MoEF&CC.”
5
SLP (C) No(s). 13374-13375 of 2025
Central Zoo Authority granted interim extensions,
the last valid licence expired in 2021. While DDA
applied for a renewal, it concurrently informed the
Central Zoo Authority of its decision to close the Deer
Park and sought approval for the translocation of the
entire deer population to Rajasthan and Asola Bhatti
th
Wild Life Sanctuary, Delhi. On 19 May, 2022, the
DDA wrote a letter to the Chief Wild Life Warden,
10
Rajasthan , requesting to accept the translocation of
approximately 550 spotted deer to a designated
sanctuary in Rajasthan, citing administrative
incapacity to manage the growing population of deer.
th
The CWLWR vide letter dated 27 May, 2022,
conveyed assent to the request made by the DDA for
the translocation of approximately 550 spotted deer
from the A.N. Jha Deer Park, New Delhi, to
designated national parks or wildlife sanctuaries in
Rajasthan. The Rajasthan Wild Life Department,
prior to final approval, forwarded a checklist of
mandatory conditions to DDA, outlining procedural
and welfare safeguards to be followed during the
animal transfer. These conditions inter alia included
10
Hereinafter referred to as “CWLWR”.
6
SLP (C) No(s). 13374-13375 of 2025
a prohibition on the transfer of pregnant, recently
bred, aged, or infirm animals as well as mandatory
adherence to the Guidelines for the Establishment
and Scientific Management of Zoos in India, 2008.
The Department, further, directed that the
transportation of deer be timed to minimize climate-
induced stress on the animals, particularly avoiding
peak summer periods.
7. After consideration of the translocation
proposal by the Technical Committee, Central Zoo
th
Authority vide order dated 8 June, 2023, issued
under Section 38H(6) of the Wild Life Act, cancelled
the recognition of A.N. Jha Deer Park, Hauz Khas,
New Delhi, citing persistent non-compliance with zoo
management norms, failure to control deer
population, and expiry of the licence in August, 2021.
After evaluating the DDA’s proposal and confirming
the translocation of approximately 600 spotted deer,
the Central Zoo Authority directed that the animals
be released into natural habitats in Rajasthan and
Delhi in a 70:30 ratio (70% in Rajasthan
sanctuaries/reserves and 30% in Asola Bhatti Wild
Life Sanctuary in the National Capital Territory of
Delhi), in accordance with IUCN guidelines.
7
SLP (C) No(s). 13374-13375 of 2025
8. Aggrieved by the decision of the Central Zoo
th
Authority dated 8 June, 2023, cancelling the
recognition of Deer Park and approving the
translocation of approximately 600 spotted deer to
Rajasthan and Asola Bhatti Wild Life Sanctuary,
Delhi, the petitioner-Society, which is an NGO
working on the promotion of nature awareness and
conservation in Delhi, filed a public interest litigation
via Writ Petition (C) No. 12275 of 2023 before the
High Court of Delhi under Article 226 of the
Constitution, contending inter alia that the
concerned authorities cancelled the license in gross
11 12
violation of Section 38H(4) and (6) of the Wild Life
(Protection) Act, particularly, as the order failed to
record reasons in writing for cancellation of the
licence. It was further alleged that the CWLWR, and
the Department of Forest and Wildlife, Government
of NCT of Delhi, had failed to comply with mandatory
conditions prescribed by the Central Zoo Authority
11
Section 38H(4): No recognition to a zoo shall be granted unless the
Authority, having due regard to the interests of protection and
conservation of wild life, and such standards, norms and other matters as
may be prescribed, is satisfied that recognition should be granted.
12
Section 38H (6): The Authority may, for reasons to be recorded by it,
suspend or cancel any recognition granted under sub-section (4): Provided
that no such suspension or cancellation shall be made except after giving
the person operating the zoo a reasonable opportunity of being heard.
8
SLP (C) No(s). 13374-13375 of 2025
and the IUCN Guidelines for translocation of captive
wildlife. The petition, filed in public interest, sought
the following reliefs:
“(a) Direct the Respondent DDA to ensure strict
compliance with the CZA and IUCN guidelines
during the translocation of the deer;
(b) Direct the Respondents not to translocate
pregnant animals, newly bred young calves, or
antlered animals in velvet, and to ensure that
only animals in good health are transported;
(c) Direct the Respondents not to release the
animals in areas where they may become prey,
such as the Asola Sanctuary;
(d) Direct the DDA to retain the animals that
cannot be translocated within the Deer Park area
and not to close down the Park.”
9. During the course of hearing of the writ petition
before the High Court, the petitioner-Society pointed
out that around 80 deer had already been moved
without adherence to the 2014 IUCN Guidelines,
which prohibit the translocation of vulnerable
categories like pregnant or antlered deer. Vide order
th
dated 6 December, 2023, the High Court granted a
stay on the translocation of the deer, with the
following observations:
“5. This Court is of the prima facie view that at
least fifty (50) deers as originally envisaged
should be retained so that small children of this
city get to see them. The respondents may also
9
SLP (C) No(s). 13374-13375 of 2025
consider relocating the excess population of
deers in forests and green areas of Delhi. This
Court is further of the prima facie view that as
Rajasthan has too many leopards, not many
deers may survive the relocation.
x-x-x
8. Till further orders, there shall be a stay of
translocation of deers from A.N. Jha Deer Park,
Hauz Khas, New Delhi.”
th
10. The High Court vide Order dated 19 July,
2024, disposed of the above writ petition, while
taking into consideration an Additional Affidavit filed
th
by the DDA on 18 July, 2024. The Affidavit stated
that, as a policy decision approved by the Vice
Chairman of DDA and endorsed by the Lieutenant
Governor of Delhi, about two dozen deer would be
retained at the Deer Park, subject to the renewal of
its mini-zoo status by the Central Zoo Authority. The
DDA would approach the Central Zoo Authority for
requisite approvals, while the remaining deer could
be relocated to forest areas in neighbouring states.
The affidavit also highlighted concerns around
Delhi’s limited carrying capacity and the risks of
poaching if deer were relocated within the city. In
view of the DDA’s willingness to abide by the
guidelines, the High Court allowed the DDA to
10
SLP (C) No(s). 13374-13375 of 2025
resume the translocation process in accordance with
the terms stated in the affidavit and disposed of the
matter accordingly. The relevant paragraphs of the
order are extracted hereinbelow:
“3. Learned counsel for DDA, has today in Court,
th
handed over an additional affidavit dated 18 July
2024, wherein it has been averred as under: -
“III. That pursuant to the Orders passed
by this Hon'ble Court in this case, the
matter has been examined by DDA. The
Vice Chairman, DDA being the competent
authority has approved the proposal of
retaining some deer in the A.N. Jha Mini
Zoo at Hauz Khas, New Delhi (the Deer
Park) after taking necessary approvals
from the Central Zoo Authority (CZA) vide
File No. HORT/PC/0020/ 2020/DHSE/-
O/o DY.DIR(HORT. DIV-IV) (Computer
No.7673) # Note 92. It has been approved
that as a policy decision in supersession
of earlier decisions on the subject, the
DDA would retain some deer in the Deer
Park and for that purpose, DDA shall
move the CZA for the necessary approvals
and compliance would be made as per the
requirements of CZA guidelines. This
matter has also stands verbally discussed
with the Hon'ble Lieutenant Governor,
Delhi / Chairman, DDA and the Hon'ble
LG has also agreed to the proposal.
IV. That in these circumstances, it is
submitted that the DDA will retain about
two dozen of deer in the Deer Park subject
to the renewal of recognition of mini zoo
status of A.N. Jha Mini Zoo by the CZA.
The remaining deer can be transferred to
11
SLP (C) No(s). 13374-13375 of 2025
neighbouring states forest areas as per
the earlier decision on the subject. DDA
shall accordingly move the necessary
proposal before the CZA for approval and
renewal of recognition.
V. That it is respectfully submitted that
subject to above, this Hon'ble Court may
allow to resume translocation of deer so
that overcrowding of deer may be
managed at A.N. Jha Mini Zoo at Hauz
Khas, New Delhi.”
4. Learned counsel for the petitioner is satisfied with
the additional affidavit dated 18th July 2024 filed by
the DDA.
5. Keeping in view the aforesaid additional affidavit
dated 18th July 2024 as well as the consent of
learned counsel for the petitioner, the present writ
petition is disposed of in accordance with
paragraphs III, IV and V of the said affidavit. It is
clarified that DDA is at liberty to act in accordance
with the said additional affidavit.”
11 . Following the disposal of the writ petition on
th 13
19 July, 2024, an application was filed seeking the
recall of the above order on the ground that the
petitioner-Society’s lawyer had conveyed its consent
without informing the petitioner-Society. However,
the High Court, after examining the entire record,
found no justifiable grounds to recall its earlier order
th
and accordingly vide Order dated 24 January, 2025,
13
Supra note 7.
12
SLP (C) No(s). 13374-13375 of 2025
dismissed the recall application. Consequently, in
light of this dismissal, the High Court also held that
no further orders were necessary in the connected
14
application seeking stay.
th
12 . The aforesaid orders dated 19 July, 2024, and
th
24 January, 2024 passed by the High Court in Writ
Petition (C) No. 12275 of 2023, are subject matter of
challenge in the present special leave petitions.
III. PROCEEDINGS BEFORE THIS COURT
13. During the pendency of these petitions, this
Court, taking into consideration the gravity of the
matter and the fact that a total of 261 deer were
translocated to Rajasthan, directed the Central Zoo
Authority to visit the locations where 261 deer have
already been transferred and ascertain the present
condition of the said deer. The relevant paragraphs of
the order are reproduced hereinbelow:
“ We are informed that so far 261 deers have
been shifted to Rajasthan. The learned
counsel appearing for the petitioner makes a
grievance that many of these deers are no
longer surviving. We direct a team of officers
of the Central Zoo Authority (the second
14
The Application, seeking stay, is CM Application No. 48098 of 2024.
13
SLP (C) No(s). 13374-13375 of 2025
respondent) to immediately visit the place or
places where the 261 deers have been
transferred. They shall ascertain the present
condition of the said deers.
The officers of the Central Zoo Authority will give
an advance notice of their visits to the petitioner
so that a representative of the petitioner can
remain present.
A report to be submitted by the Central Zoo
Authority about the condition of the deers within
a period of two weeks from today. A copy of the
report shall be furnished to the learned counsel
appearing for the petitioner. In the event it is
found that either the deers are not surviving
or they are in bad condition, we grant liberty
to the petitioner to move this Court by filing
an appropriate application.
x-x-x
In the meanwhile, we direct the Delhi
Development Authority and the Central Zoo
Authority (the first and the second respondents
respectively) to consider the suggestion made in
paragraph 11 of the application made by the
petitioner at Annexure P-10 and file a response
to the same within a period of six weeks from
today.”
14 . In pursuance of this order, the DDA, through its
authorised officer, has filed a short affidavit. In the
said affidavit, the DDA has submitted that:
i) It has no objection to the relocation of the
remaining deer from the A.N. Jha Deer Park
14
SLP (C) No(s). 13374-13375 of 2025
to any suitable location, including the
proposed Deer Park at Noida, subject to
obtaining prior approval and directions
from the Central Zoo Authority, which is a
mandatory prerequisite for any
translocation of captive animals. Letters
seeking such approval and clarification
were sent to the Central Zoo Authority on
th th
30 May, 2025 and 8 July, 2025,
respectively.
ii) The decision to translocate the deer was
prompted by overpopulation in the Deer
Park, which was causing strain on available
resources and affecting the health and well-
being of the animals. A total of 261 deer
have been translocated to forest areas in
Rajasthan using the BOMA method, an
internationally recognised technique for
safe wildlife capture and relocation. This
process was undertaken with the
assistance of the Rajasthan Forest
Department and a senior veterinary expert,
ensuring compliance with the guidelines
15
SLP (C) No(s). 13374-13375 of 2025
issued by the Central Zoo Authority and
IUCN Guidelines.
iii) The DDA further submitted that the
remaining deer population in the park
continues to receive routine veterinary care,
including regular deworming and provision
of daily rations and green fodder as per the
recommendations of the Central Zoo
Authority. It was reiterated that no deer has
been translocated to the Asola Bhatti Wild
Life Sanctuary, Delhi thus far, and that the
DDA has acted strictly in accordance with
applicable legal and regulatory framework,
prioritising both animal welfare and
ecological balance.
15 . In pursuance of the liberty granted by this
th
Court vide order dated 16 May, 2025, the petitioner-
15
Society has filed an application seeking directions
in view of alarming findings during the Court-
permitted field survey of the deer translocation
project from A.N. Jha Deer Park, Hauz Khas, Delhi to
Mukundara Hills Tiger Reserve (Rajasthan) and
15
Interlocutory Application No. 164887 of 2025.
16
SLP (C) No(s). 13374-13375 of 2025
Ramgarh Vishdhari Tiger Reserve (Rajasthan). In its
application for direction, the petitioner-Society has
submitted that:
i) The petitioner-Society was permitted to join
the Central Zoo Authority in its post-
translocation field inspections at A.N. Jha
Deer Park, Mukundara Hills Tiger Reserve
(Rajasthan) and Ramgarh Vishdhari Tiger
Reserve (Rajasthan). Based on the field
observations, the petitioner-Society avers
that serious discrepancies exist between
the number of deer stated to have been
translocated and the number actually
sighted. Of the 100 deer claimed to be
translocated to Ramgarh Vishdhari Tiger
Reserve (Rajasthan), only 60-62 were seen,
and of the 161 said to be sent to
Mukundara Hills Tiger Reserve (Rajasthan),
only 52-53 were visible. Further, there were
no visible tags or chips on any deer, making
it impossible to ascertain their origin or to
conduct post-release monitoring.
ii) The application highlights critical violations
in the process of transportation and release.
17
SLP (C) No(s). 13374-13375 of 2025
Several deer were transported in
overcrowded trucks, including an instance
rd
on 3 November, 2023, when 40 deer and a
fawn were stuffed into one vehicle. No
photographic record or documentation of
vehicle dimensions or welfare compliance
was submitted by DDA. The deer endured
long journeys without veterinary
assistance, sedation, food, or water. The
petitioner-Society contends that many deer
perished due to stress, starvation, or
predation post-release, a claim further
substantiated by findings of scattered
16
bones and a rope tied to a deer bone ,
suggesting use of deer as live bait in
predator-inhabited zones.
iii) The petitioner-Society specifically points
out that contrary to express assurances in
th
the DDA’s affidavit dated 30 October,
2023, pregnant female deer and juvenile
deer were translocated. The officials not
only failed to identify and segregate
16
Annexure 1 of the Application.
18
SLP (C) No(s). 13374-13375 of 2025
vulnerable animals, but also translocated
them, including the juveniles being
transported with 40 adults in a single truck.
These acts constitute contempt of this
Court’s previous orders and breach of
guidelines issued by the Central Zoo
Authority and the IUCN Guidelines.
iv) The application further alleges that the
reserves to which the deer were
translocated lacked basic ecological
support, such as grasslands or shrubs for
grazing. Google Maps analysis and on-site
inspection revealed that vegetation was
sparse and water sprinklers, though
claimed in reports, were not operational. No
habitat suitability study appears to have
been conducted prior to translocation,
violating fundamental prerequisites laid
down under the guidelines. The Central Zoo
Authority’s claims that no tigers existed in
the reserves were refuted by government
data and newspaper reports showing the
presence of multiple tigers in Mukundara
Hills Tiger Reserve (Rajasthan) and
19
SLP (C) No(s). 13374-13375 of 2025
Ramgarh Vishdhari Tiger Reserve
(Rajasthan), thus directly endangering the
deer.
v) Turning to the Deer Park itself, the
application alleges gross mismanagement
and possible corruption. While the Central
Zoo Authority report claims that 393 deer
were housed in the park as of May, 2025,
petitioner-Society’s on-ground investigation
showed only 70-80 deer visible at feeding
time. Moreover, the food provided per day
amounted to only 260 kg (green fodder and
grain), which suffices for merely 84 deer,
assuming a minimum requirement of 3 kg
per deer per day. This discrepancy, the
petitioner-Society argues, either reflects
mass starvation or falsified deer counts for
inflated funding. Additionally, basic
facilities such as water troughs were empty,
with only one out of four having water, and
the grains therein were fermenting, raising
fears of deaths from enterotoxaemia .
vi) Lastly, the application criticises the Central
Zoo Authority field survey as perfunctory,
20
SLP (C) No(s). 13374-13375 of 2025
opaque, and dismissive of the petitioner-
Society’s right to participate in the said
survey. The leadership of the survey team
excluded representatives of the petitioner-
Society from meetings, refused to share
documents, and appeared to rubber-stamp
the narrative advanced by the respondents.
In light of the grave irregularities, statutory
violations, and acts of cruelty disclosed in the present
application, the petitioner-Society respectfully
prayed that this Court may be pleased to grant: (i) a
permanent stay on further translocation of deer; (ii) a
third-party wildlife expert survey of A.N. Jha Park;
(iii) restoration and safety measures for already
translocated deer; (iv) penal action against erring
officials; and (v) an investigation into financial and
administrative irregularities.
IV. DISCUSSION AND ANALYSIS
16. We have given our thoughtful consideration to
the submissions advanced at the bar and have gone
through the impugned orders. With the assistance of
learned counsel for the parties, we have also perused
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the pleadings, affidavits, and material placed on
record.
17. The material placed on record reveals that the
A.N. Jha Deer Park, despite its historical and
ecological significance, has for several years suffered
from chronic managerial deficiencies. The repeated
extensions granted by the Central Zoo Authority and
the warnings issued from time to time demonstrate
that the Deer Park was operating 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 Evaluation
Reports of 2014-2022 underscores persistent non-
compliance relating to enclosure maintenance,
veterinary infrastructure, record-keeping, population
control, and habitat enrichment. The absence of
adequate segregation, sterilisation, and monitoring
mechanisms inevitably led to an exponential increase
in the deer population, far exceeding the carrying
capacity of the 10.97-acre enclosure. In such
circumstances, the need for scientific population
management through regulated translocation was
not only foreseeable but also indispensable for the
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health, welfare, and sustainability of the deer
population.
18. It is equally evident that the DDA lacked the
requisite logistical and veterinary
preparedness/capacity to manage a population that
fluctuated between 350 to 600 deer over the past
decade. The Deer Park’s spatial limitations and the
scarcity of foraging resources meant that natural
behaviours, such as browsing, territoriality, and herd
structuring, could not be accommodated within the
confined enclosure. Overcrowding in captive
ungulate species is known to heighten stress, weaken
immunity, and precipitate outbreaks of disease. The
insufficiency of fodder, irregular water supply, and
dearth of veterinary supervision, as reflected from the
petitioner-Society’s assertions and supported by field
reports/observations, raise serious concerns about
the welfare of the remaining population. In these
circumstances, continued retention of entirety of the
remaining population of deer at the Deer Park would
be contrary to the very principles of animal welfare
enshrined under domestic laws and international
conservation protocols.
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19. At the same time, the submissions and field-
survey based averments made by the petitioner-
Society regarding irregularities in the translocation
already undertaken cannot be lightly brushed aside.
Allegations that vulnerable categories of deer,
including pregnant females, juveniles, and
antlered males, were transported; that
overcrowding occurred inside vehicles; that post-
release monitoring mechanisms were inadequate;
and that the chosen release sites lacked assured
habitat suitability, are all matters that strike at
the core of scientific translocation practice. The
IUCN Guidelines emphasize that any relocation of
captive wildlife must be supported by ecological
feasibility studies, veterinary screening, tagging
or identification processes, and structured post-
release surveillance. These safeguards appear,
prima facie , to have been applied in a perfunctory or
incomplete manner, thereby undermining the
legitimacy of the exercise and the welfare of the
animals involved.
20. It is evident from the record that the
translocation protocol and best practices
incorporated in the guidelines issued by the Central
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Zoo Authority and IUCN Guidelines were not adhered
to during the translocation of deer from Deer Park to
Ramgarh Vishdhari Tiger Reserve and Mukundra
Hills Tiger Reserve in the State of Rajasthan. There is
no documentary evidence of pre-translocation genetic
screening, tagging, tranquilisation protocols,
veterinary fitness certification, or behavioural
acclimatisation, all of which are internationally
recognised preconditions for release. Notably, no
scientific assessment was carried out with respect to
the carrying capacity of the recipient sanctuaries in
Rajasthan, the predator-prey dynamics, or the
impact of introducing semi-captive deer into those
ecosystems. The translocated deer, many of whom
were zoo-bred, and some reportedly pregnant or
juvenile, were moved to tiger-bearing sanctuaries,
without any indication of whether they possessed the
necessary survival skills or ecological fitness.
Photographic and field evidence brought on record by
the petitioner-Society points to a distressing pattern
of negligence. Deer were allegedly loaded into
overcrowded trucks, sometimes in groups as large as
40-50, without proper ventilation, padding, or
segregation. In one instance, a blue rope used to tie
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the limbs of a deer was reportedly recovered from the
relocation site, raising serious concerns about the
use of force and the absence of ethical handling
procedures. Moreover, no tracking mechanisms such
as telemetry collars, radio chips, or post-release
surveys were done to monitor the well-being or
survival of the released animals. Without such data,
it is not possible to determine how many deer
survived the journey or successfully adapted to their
new environments.
21. Given the competing claims and the absence of
a verified factual foundation regarding (i) the actual
number of deer presently in the Deer Park, (ii) the
number of deer translocated and surviving at the
release sites, and (iii) the ecological viability of
further translocation of deer, this Court is of the view
that an independent, scientifically-grounded
assessment is essential before any further steps can
be permitted. In our opinion, the Central
Empowered Committee (CEC) , constituted by this
Court [now working under a Statute, namely,
Environment (Protection) Act, 1986] vested with
expertise in forest-wildlife governance, is best placed
to undertake such an evaluation. A comprehensive
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assessment is required not only to ascertain
compliance with statutory norms but also to restore
confidence in the decision-making process and
ensure that any future translocation conforms
strictly to the ethical, ecological, and legal standards
binding upon all agencies.
V. DIRECTIONS
22. In light of the foregoing discussion, and to
ensure that the welfare of the deer population is
secured in accordance with the statutory framework
prevailing in India and internationally accepted
conservation guidelines/norms, we issue the
following directions:
A. The Central Empowered Committee (CEC)
shall conduct an on-ground survey of A.N. Jha
Deer Park and file a detailed report before this
Court within eight weeks. The report shall
specifically enumerate:
i. the present population of deer in the Deer
Park;
ii. the ecological carrying capacity of the
Deer Park, based on space, fodder
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availability, veterinary infrastructure, and
enclosure design;
iii. the maximum number of deer that can be
sustainably and humanely maintained at
the Deer Park; and
iv. the surplus population, if any, that must
be considered for translocation.
B. The CEC shall further undertake an inspection
of the release sites, i.e., Ramgarh Vishdhari
Tiger Reserve and Mukundra Hills Tiger Reserve
in the State of Rajasthan and file a status report
within eight weeks. The report shall specifically
enumerate:
i. the number of deer actually present and
surviving;
ii. habitat suitability, availability of forage
and water, predation risks, and mitigation
measures;
iii. veterinary monitoring mechanisms and
post-release protocols;
iv. compliance with guidelines issued by the
Central Zoo Authority and the IUCN
Guidelines.
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C. The CEC shall also prepare a comprehensive
roadmap for any future translocation, detailing
the scientific methodology, identification and
tagging processes, procedural safeguards,
transportation protocols, veterinary
requirements, ecological feasibility studies, and
post-release monitoring framework, in strict
conformity with the domestic statutory regime
and IUCN Guidelines.
D. All concerned authorities shall extend full
cooperation to the CEC , ensuring timely
support, information sharing, and access to
necessary sites, required for implementing
these directions. Any failure or delay in
compliance shall invite appropriate action.
E. The DDA shall, within eight weeks, 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 the Evaluation Reports.
F. The DDA is directed to refrain from organizing,
permitting, or facilitating any commercial
events, private parties, or non-conservation
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related gatherings within the premises of the
A.N. Jha Deer Park or its surrounding ecological
buffer zones. The use of the said park for such
purposes is inconsistent with its designation as
an urban ecological zone and captive animal
enclosure. Instead, DDA may develop and
implement a non-commercial public outreach
programme, which shall include periodic
educational visits for school and college
students, guided nature walks in collaboration
with recognized environmental NGOs, and
biodiversity awareness campaigns, in order to
foster a culture of ecological sensitivity and civic
participation in conservation efforts.
G. Until further orders of this Court, no additional
translocation of deer from A.N. Jha Deer Park
shall be carried out by the respondents or any
other authority.
VI. CONCLUSION
23. The aforesaid directions are being issued for
securing the constitutional regime that governs
environmental protection and the humane treatment
of wildlife in this country. Articles 48A and 51A(g) of
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the Constitution of India embody a collective
commitment to safeguard forests and wildlife and to
act with compassion for all living beings, while Article
21 has been judicially recognized as encompassing
the right to a clean and ecologically balanced
environment. The concerns arising from
overcrowding, resource constraints, and managerial
lapses at the A.N. Jha Deer Park, coupled with
questions regarding the scientific rigour of past
translocation efforts, underscore that wildlife
management cannot be approached as a matter of
administrative convenience. It must be anchored in
scientific assessment, ecological prudence, and
fidelity to constitutional values.
24. The present controversy also reflects the
broader pressures faced by urban ecological spaces,
where the coexistence of wildlife and expanding
human habitats demands heightened responsibility
and foresight. The deer population at the Deer Park
is a reminder that conservation is not merely the
relocation of animals but an exercise in stewardship:
preserving species, habitats, and the environmental
ethos enshrined in our constitutional framework. The
Court’s intervention is therefore guided by the
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imperative that decisions affecting wildlife must
reinforce the principles of dignity, ecological integrity,
and intergenerational equity that lie at the heart of
this Court’s environmental jurisprudence.
th
25.
List again on 17 March, 2026, for receiving the
reports of the Central Empowered Committee and
the DDA.
….……………………J.
(VIKRAM NATH)
...…………………….J.
(SANDEEP MEHTA)
NEW DELHI;
NOVEMBER 26, 2025.
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