IN THE MATTER OF SUO MOTO PUBLIC INTEREST LITIGATION vs STATE OF CHHATTISGARH

Court: Chhattisgarh High Court
Case type: WRIT PETITION PUBLIC INTEREST LITIGATION MATTER
Decided on: 06-04-2026

<div> 1 2026:CGHC:15521-DB NAFR Digitally signed by INDRAJEET SAHU Date: 2026.04.07 10:43:09 +0530 INDRAJEET SAHU HIGH COURT OF CHHATTISGARH AT BILASPUR WPPIL No. 92 of 2024 1 - In The Matter Of Suo Moto Public Interest Litigation Regarding Tiger Found Dead, Poaching Alarm In Unreserved Guru Ghasidas Park Poisoning Suspended, Second Tiger Death In Same Area In 2 Years At Park, Based On News Item Published In News Paper Times Of India Time City, Raipur Edition, Dated- 10-11-2024. ... Petitioner(s) versus 1 - State of Chhattisgarh Through Chief Secretary Mahanadi Bhawan, Atal Nagar, Nava Raipur, Chhattisgarh. 2 - National Tiger Conservation Authority (NTCA) Through Secretary A.D.G.F. And Mantralay, B-1, Wing 7th Floor, Dindayal Upadhyay Bhawan, C.G.O. Complex, Paryavaran Bhawan, Lodhi Road, New Delhi. 3 - State Of Chhattisgarh Through Additional Chief Secretary, Forest And Climate Change, Mahanadi Bhawan Atal Nagar, Nawa Raipur, Chhattisgarh. 4 - Principal Chief Conservator Of Forest Cum Chief Wild Life Warden Mahanadi Bhawan, Atal Nagar, Nawa Raipur, Chhattisgarh. 5 - Director Guru Ghashidas National Park, Baikunthpur, Chhattisgarh. 6 - Collector Koriya At Baikunthpur, Chhattisgarh. 7 - Superintendent Of Police Koriya At Baikunthpur, Chhattisgarh. 8 - Divisional Forest Officer Koriya Forest Division, Baikunthpur, Chhattisgarh. ... Respondent(s) For State : Shri Shashank Thakur, Addl. Advocate General. For Respondent 2 : Ms. Annpurna Tiwari, Advocate. Hon'ble Shri Justice Ramesh Sinha, CJ Hon’ble Shri Justice Ravindra Kumar Agrawal, J Order on Board 06.04.2026 Per, Ramesh Sinha, CJ. 1 Suo motu cognizance was taken by this court by way of present Public Interest Litigation on the basis of news item published in Time City, 2 Times of India, Raipur, dated 10.11.2024, with a heading “Tiger found dead; poaching alarm in unreserved Guru Ghasidas Park”. 2 As per said news clipping, the carcass was found at the location where the previous tiger poaching took place that is why, though death was suspected to be on account poisoning, however as the death seems to be revenge killing because half eaten Buffalo was found, therefore suo motu cognizance was taken by this court and concerned officials of the Forest Department was directed to file affidavit asking the steps and action taken to preserve wild life. In response thereto, the higher officials of Forest Department filed its affidavit mentioning details of death of Tiger and Elephant took place at various forest division and details of death and action plan taken thereafter. 3 Besides above, cognizance was also taken by this court on the news item published in Hindi Daily, Haribhoomi in the month of March, 2025 with a heading " c?kok ij f’kdkjh Hkkjh] nks ck?k ,d rsanq, dh ekSr] nks ds " , and sub-heading " uk[kwu nkaRk xk;c lwjtiqj ou eaMy esa feyk VkbZxj dk 'ko] [kSjkx<+ oueaMy esa ik;k x;k rasnq, dk 'ko] dkuu iasMkjh tw esa ckf?ku us rksM+k ne " , and in English Daily, The Times of India, with a heading “Tiger found dead in CG reserve, electrocution, poaching suspected”, and sub heading “canines and claws missing from carcass” , and Times Nation with a heading “Key tiger corridor hit; poaching feared as big cat carcass found.” 4 Taking these incidents to be very serious, despite statement made by the State on 10.12.2025 that no new instances of poaching came to light, again suo motu cognizance on the aforesaid issues were taken 3 by the court and vide order dated 16.12.2025 and 19.12.2025 the Principal Chief Conservator of Forest-cum-Wild Life Warden, Govt. of Chhattisgarh was again directed to file his detailed affidavit on the aforesaid news clipping and steps to be taken by the State Forest Department. 5 In response to above orders, affidavit dated 21.01.2026 has been filed by the Principal Chief Conservator of Forest-cum-Wild Life Warden, Govt. of Chhattisgarh, the relevant contents of which is reproduced hereinbelow: “A. Anti-Snare Measures Workshop- 4. It is humbly submitted that pursuant to the Hon'ble High Court's concern over electrocution-based poaching, a one-day "Anti-Snare for Combating Wildlife Crimes" workshop was conducted on 19.12.2025 at Timber Auction Hall, Kawardha Forest Division, Durg Circle. This workshop focused on building capacity to detect and remove snares/traps and prevent illegal were electrification in forests. It included technical training on wildlife preservation, types of snares and their working, and best practices for conducting anti-snare patrolling ("Snare Walk"). Inter-departmental inputs integrated notably, an Executive Engineer from the State Electricity Board gave a session on handling electrocution and power line tripping cases, and a legal expert provided awareness on wildlife offense cognizance and applicable laws. The forum also involved NGO participation for community outreach, and emphasized legal provisions under the Wildlife (Protection) Act, 1972 for prosecuting offenders. The workshop concluded with a Q&A and a call for sustained joint action. Copy of the workshop report dated 19.12.2025, along with photographs is annexed herewith and marked as Annexure A/1. B. Anti-Snare Walk in the State 5. Further, it is humbly submitted that the deponent, as Chief Wildlife Warden issued Letter No. 5864 dated 17.12.2025 mandating that all forest divisions conduct mandatory regular "Anti-Snare Walks" in their beats and record these in beat reports. 6. That, consequently, a State-wide intensive anti-snare exercise was carried out, wherein forest teams across Chhattisgarh cumulatively patrolled approximately 5726 km of forest areas on foot to detect and remove illegal traps. This special drive took place in late December 2025 through January 2026, covering all territorial and wildlife divisions. Division-wise outcomes include significant seizures of prohibited hunting equipment and live wiring. Some of the outputs of the anti-snare walks conducted in the State of Chhattisgarh is as below: i. For instance, Balrampur Division (Surguja Forest Circle) reported seizing 17 meters of live electric wire laid as trap on 27.12.2025 and a further 70 meters of live wire on 05.01.2026 - these were promptly removed, seized and handed over to the Electricity Department. 4 a recent tiger ii. In Surguja forest circle, anti-snare patrols in Tamor Pingla area (Elephant Reserve) on 23.12.2024 had earlier uncovered a baited metal snare (fanda), which was seized and is under investigation. Following electrocution incident in Surajpur (Surguja Forest Circle), search operations led to the recovery of three bundles (~25 kg) of electric hooking wires and multiple snares from a suspect's house on 15.12.2025. iii. Likewise, in Khairagarh Division (Durg Forest Circle), where a leopard was killed by live-wire poaching in Dec 2025, swift action resulted in the arrest of 7 accused on 16.12.2025 and the seizure of an array of illicit items including electric wires, metal snares, an axe, an air gun, and wildlife parts (deer meat, leopard claws and teeth) - from the perpetrators' possession. Similar anti-snare walks were conducted in other divisions (Rajnandgaon, Kanker, Bastar, etc.), yielding numerous removed snares, confiscated wire traps, country-made weapons, and even live electric fencing materials. Field officers also activated local informant networks with secret rewards to uncover hidden poaching setups. A consolidated report of the State-wide Anti-Snare Walk exercise, detailing distances patrolled and items seized division-wise, is annexed as Annexure A/2. C. Inter-State Coordination 7. That, cross-border poaching threats have been addressed through coordinated action with neighboring states. To address this, the PCCF & HoFF, Chhattisgarh dated letter instructions issued 27.12.2025 to convene a joint meeting of forest officers of the adjoining districts of Chhattisgarh and Odisha by the end of December 2025. A copy of letter dated 27.12.2025 is attached and annexed herewith and marked as Annexure A/3. 8. That, an inter-state meeting with Odisha officials was held via video conference on 30.12.2025 to synchronize anti-poaching efforts along the Chhattisgarh-Odisha boundary. In this meeting, forest officers of Chhattisgarh and Odisha discussed joint strategies. 9. That, after the joint deliberations, the two States resolved to share intelligence on poaching gangs and illegal wildlife trade, and to ensure quick, coordinated legal action SO that offenders cannot evade enforcement by crossing the border. Other agenda items included addressing cross-border forest encroachment and fires (often set to aid poaching), and Improving communication between field officers for real-time response. A copy of the Minutes of the Inter-State Coordination Meeting dated 30.12.2025 with Odisha are annexed herewith as Annexure A/4. D. Inter-Departmental Coordination 10. That, the Hon'ble Court's directions underscored that combating electrocution poaching requires a multi-agency approach. Accordingly, the State has established a robust coordination mechanism between the Forest Department and other departments like Electricity and Home (Police), as well as local administration. 11. That, in compliance, a high-level inter-departmental meeting was convened on 14.01.2026 under the Chairmanship of the Additional Chief Secretary (Forest & Climate Change), with senior officials of the Energy Department (Chhattisgarh State Power Distribution Co.) and Home Department participating. In this meeting, it was reviewed that earlier efforts by the Energy Department (e.g. safety inspections, "loose wire" rectifications) were necessary. Concrete steps were laid down to institutionalize cooperation at the field level: for example, joint 5 Forest-Power "safety teams" are being formed to regularly inspect forest-adjoining electrical lines for any unauthorized hook connections or low-hanging wires. 12. It is respectfully submitted that in the meeting held on 14.01.2026, the officials of the Electricity Department, informed that out of 2490 loose point locations received from the Forest Department, a joint survey was conducted in respect of all such locations. As on 31.12.2025, the joint survey revealed 2285 loose point locations, out of which 1781 locations have already been rectified, while corrective action in respect of the remaining 504 locations is presently underway. It was further informed that continuous checking of electricity connections is being carried out in elephant-affected areas to ensure electrical safety and prevent wildlife hazards. 13. It was further apprised that during the period from 01.12.2019 to 31.12.2025, a total of 7671 electricity connections were inspected, pursuant to which 3148 temporary connections were converted into permanent connections. Additionally, 1101 illegal electricity connections were detected, out of which 441 cases have been placed before the Special Court in accordance with law, and appropriate action in the remaining cases is being taken as per the prescribed procedure. E. Action Taken Reports of Forest Circles 14. That, the Department has gathered Action Taken Reports from all territorial and wildlife forest circles detailing the preventive and enforcement measures after the hearing dated 19.12.2025. A summary of the key actions in each circle is as follows: a. Raipur Circle: Intensive anti-snare drives were carried out in divisions under Raipur Circle, which includes Udanti-Sitanadi Tiger Reserve (Gariaband) and surrounding forests. In Kulhadighat Range of Udanti-Sitanadi, 5 cases of illegal hunting (poaching of sambar, hare, etc.) were detected between 17.12.2025 and 06.01.2026, leading to prosecution of over 20 accused poachers. All accused were arrested and produced before the competent courts in Gariaband. Forest staff also rescued an injured civet cat in Sitapur Range (Surguja Division) on 22.12.2025, though it unfortunately did not survive despite treatment. Raipur Circle teams have increased night patrolling in elephant movement zones and coordinated with the electricity authorities to fix low-sagging lines in Mahasamund and Baloda Bazar districts. b . Surguja Circle: This northern circle, home to elephants and recent poaching incidents, undertook massive enforcement operations. After the electrocution of a tiger in Surajpur Division (on 13.12.2025), a special investigation team used sniffer dogs and village informants to track down suspects. As noted above, 7 persons were arrested in that case and tiger body parts along with large quantities of electric wire and snares were seized. Similarly, in Balrampur Division, forest squads conducting anti-snare walks recovered live wires before they could cause harm. Awareness campaigns were launched in villages across Surguja, Balrampur, and Jashpur districts emphasizing that setting electrified traps is a serious wildlife crime and also endangers human lives. Local tribal communities (whose totemic traditions protect species like tiger, turtle, snake, etc.) have been involved to spread the message against poaching. c. Durg Circle: In Durg Circle (which covers areas like Rajnandgaon, Khairagarh, Mohla-Manpur), efforts have been focused on the incident in Khairagarh Range where a leopard was poached. All accused in 6 that case were apprehended within two days, and departmental inquiries were initiated against any staff negligence (the concerned Beat Guard was suspended on 16.12.2025 for dereliction). The Circle has since formed quick-response units in each range to respond to any tip-offs about live wires or snares. Over 50 kilometers of additional foot patrols were conducted in December-January in Durg and Rajnandgaon divisions, leading to seizure of various hunting snares and disconnection of illegal fence wires. The District Police in Kabirdham (Kawardha) and Rajnandgaon have been roped in to conduct joint raids on known poachers' hideouts, resulting in seizure of firearms and batteries used for electrocution. d. Kanker Circle : Kanker Circle (which includes Kanker and adjoining forests in North Bastar) intensified ground patrols in vulnerable forest beats bordering Odisha. The staff identified traditional poaching hotspots and removed several crude wire snares and jaw-traps set for wild boar and deer. Although no major electrocution incident was reported in this period from Kanker, preventive steps were taken in coordination with local electricity officials - e.g. a joint survey of farm fences in fringes of Kanker and Kondagaon ranges was done to ensure no live wires are being laid. The circle office also organized community meetings in villages of Kanker and Keshkal region, to warn of the legal consequences of wildlife offenses. e. Jagdalpur Circle (Bastar) : In the southern forests under Jagdalpur (which covers Bastar, Dantewada, Bijapur, etc.), efforts have combined wildlife protection with security challenges. Indravati Tiger Reserve (Bijapur) teams carried out anti-snare combing operations in collaboration with CRPF and local police, given the naxal-affected areas. They found and destroyed multiple electrical trap setups (hooks connected to nearby power lines) intended for wild buffalo and deer. The circle report highlights an instance in January 2026 where a live wire trap was discovered in Usoor range and defused just in time. Additionally, inter-state coordination with Maharashtra (for Bastar-G… conducted in coordination with the Electricity Department to identify low-hanging, loose, ог exposed 11 kV/33 kV electric lines, and such locations have been promptly communicated for rectification as per prescribed safety norms. Regular checking of electric poles and wires by forest staff and watchers is being carried out to prevent illegal electrification and fencing. Further, close coordination has been maintained with the Electricity Department, Police Department, and District Administration through meetings and joint action to address loose points, illegal connections, and potential poaching threats, while sensitive areas have been identified and kept under continuous surveillance to ensure protection of wildlife and prevention of forest offences F. Conclusion and On-going Preventive Measures 15. That, the Hon'ble High Court, in a series of judicial pronouncements passed in WPPIL No. 5 of 2018, WPPIL No. 145 of 2021, and instant PIL, has expressed concern over the incidents of wildlife deaths caused by electrocution and illegal use of live electric wires, fencing, and snares. 16. That, in compliance with the aforesaid judicial directions, the Forest Department is taking all necessary and relevant actions in a coordinated and time-bound manner to curb illegal activities. These measures include intensified patrolling and surveillance in vulnerable forest and fringe areas, identification and removal of illegal electric fencing and live wires, prompt registration of offences, and prosecution 7 of offenders. Simultaneously, the Department is actively strengthening inter-departmental coordination with Electricity Distribution Companies, Police Authorities, and District Administration, and is also exploring inter-state coordination mechanisms to address cross-border wildlife crimes and shared corridors. The approach adopted is preventive, multi-disciplinary, enforcement-oriented, with a clear focus on long- term mitigation of electrocution-based poaching and ensuring strict compliance with the directions of the Hon'ble Court in letter and spirit. and 17. That, in summary, the deponent humbly submits that the State authorities are trying their best to take concrete, coordinated and sustained actions to prevent poaching by electrocution and snaring, in line with the Hon'ble Court's directives. 18. That, the initiatives span capacity-building (training workshops), extensive ground patrolling drives, multi-agency enforcement, and community outreach, thereby addressing both the technical and social aspects of the issue. Key vulnerable areas have been identified and are under heightened surveillance by joint teams of Forest and Police, and regular inspections with Electricity Department are ensuring that illegal live wires or fences are promptly removed. 19. That, importantly, responsibility is being fixed on field officers for any lapses, and departmental action is initiated wherever negligence is found. The inter-departmental mechanism now in place facilitates real- time information sharing and rapid response, which are crucial for effective prevention of wildlife crimes that often occur in remote areas at odd hours. The State is also leveraging technology camera traps, drone to augment surveillance, and sniffer dog squads these measures (for instance, sniffer dogs have helped solve over 60 wildlife cases in the past and are now deployed in 7 strategic locations). 20. That, the deponent assures that these efforts are ongoing and will be rigorously sustained. All field formations have been instructed through a detailed circular (issued in January 2026) to continue anti- snare walks on a regular periodicity and to treat every instance of electric wiring or trapping as a top-priority incident. 21. That, public awareness campaigns are being intensified by involving panchayats, tribal leaders, and educational institutions so that the local populace becomes an active stakeholder in wildlife protection. 22. That, the deponent remains duty-bound to adhere to every observation and direction of the Hon'ble Court, and it is his sincere endeavour to deploy all possible means to safeguard the precious wildlife in the State. 23. That, it is prayed that the steps outlined herein, supported by the documents and photographs, may be found sufficient in demonstrating the State's commitment to effective, sustained, and preventive action against the menace of electrocution and snare poaching, in compliance with the Court's orders, and this affidavit may kindly be taken on record.” 6 In view of the aforesaid affidavit dated 21.01.2026 filed by the Principal Chief Conservator of Forest-cum-Wild Life Warden, Govt. of Chhattisgarh, the present Public Interest Litigation is disposed of with 8 the hope and trust that the Forest Department shall ensure strict compliance of aforesaid plan and adequate steps are to be taken by the respondent authorities to conserve Tiger, Elephant and other Wildlife in the State at the earliest. Sd/- Sd/- (Ravindra Kumar Agrawal) (Ramesh Sinha) Judge Chief Justice inder </div>