Supreme Court Directs Uttarakhand To Restore Ecological Damage In Corbett Tiger Reserve, Demolish Illegal Constructions

The Supreme Court has issued a detailed set of directions to restore the Corbett Tiger Reserve following large-scale illegal constructions, roadworks and tree felling that took place during the establishment of the Pakhrau Tiger Safari. Accepting the recommendations of the Expert Committee constituted in March 2024, the Court ordered the State of Uttarakhand to begin demolition of all unauthorised structures within three months and to file a compliance affidavit within one year.

The judgment forms the latest chapter in the continuing proceedings stemming from the Court's March 2024 decision in the T N Godavarman case, where the Bench had flagged serious ecological damage inside Corbett and called for expert evaluation, CBI investigation and disciplinary action against the officials involved.

Restoration Plan To Be Submitted Within Two Months

The judgment, delivered by a bench comprising Chief Justice of India BR Gavai, Justice AG Masih and Justice AS Chandurkar issued wide-ranging directions on forest restoration, demolition of illegal structures, regulation of tourism, tiger safaris and measures to prevent human–wildlife conflict.

The Court directed the Uttarakhand Chief Wildlife Warden, in consultation with the Central Empowered Committee, to submit a comprehensive restoration plan within two months. The Court emphasised that the restoration must follow the Expert Committee's methodology, including removal of above-ground constructions, excavation of hard pan material, restoration of hydrological flows and plantation using only native species.

The Expert Committee, which included representatives of NTCA, CEC, Wildlife Institute of India and co-opted specialists, assessed the ecological damage across approximately 118 hectares. It recommended an in-situ restoration cost of about Rs. 4.3 crore and placed the total ecological damage, including loss of ecosystem services and timber value, at approximately Rs. 29.8 crore.

The State opposed this quantification, arguing that the Committee relied on a higher figure of felled trees than what was recorded by the Divisional Forest Officer. While hearing the matter again on 14 November 2025, the Court noted the State's objections but declined to reopen the valuation exercise, holding that the issue of tree felling and responsibility is already before the trial court.

"We are, however, not inclined to go into the issue with regard to valuation of quantification of costs for restoration as well as the potential ecological loss caused from the Safari project. We are also not inclined to go into the issue with regard to number of trees felled since trial and the prosecution at the instance of CBI is pending. Rather, we find that it will be in the interest of justice that the State of Uttarakhand is directed to restore the ecological damage caused to the Corbett Tiger Reserve under the supervision, guidance and control of the CEC. Needless to say that the Field Director shall periodically report to the CEC with regard to the restoration and the restoration work would be carried to the satisfaction of the CEC."

Guidelines for Tiger Safari

On the proposed tiger safari projects, the Supreme Court held that they must strictly comply with the Guidelines to Establish Tiger Safari in Buffer and Fringe Areas of Tiger Reserves 2019 and subsequent directions issued in its 2024 judgment. Animals must be sourced strictly as per the 2024 judgment.  The Court directed that rescue centres be established to facilitate the treatment and care of animals, and that these facilities must be located near the tiger safari sites.

The safaris will remain under the direct control of the Field Director of the concerned tiger conservatory. The Court also stressed regulating vehicular movement, stating that the number of vehicles entering safari zones must be capped and that hybrid or electric vehicles should be promoted to limit environmental disturbance.

Eco-Tourism Only; Regulation of Activities and Resorts

The CJI emphasised that only eco-tourism activities will be permitted in sensitive zones, and a set of prohibited and regulated activities will apply. Regarding forest resorts operating in and around the safari area, the Court said it has laid down detailed directions, including permissible noise levels and compliance norms.

The Court has directed the preparation of a Tiger Conservation Plan within six months to ensure scientific management of habitats, movement corridors and mitigation of disturbances.

Highlighting the welfare of frontline forest staff working in core tiger habitats, the Supreme Court directed the State to provide special protection measures and prohibited outsourcing in core forest operations. Directions have also been issued for capacity building of the forest personnel.

The judgment further mandates guidelines to minimise human–animal conflict. Directions were also issued in relation to religious tourism in the issue.

CBI Charge Sheet Filed Against Forest Officials

The Court recorded that the Central Bureau of Investigation has completed its enquiry into the illegal constructions and filed a charge sheet naming several public servants, including former Corbett Director Rahul and multiple officers of the Kalagarh Tiger Reserve Division. Charges have been invoked under the Indian Penal Code, Prevention of Corruption Act, Indian Forest Act, Forest Conservation Act and Wildlife Protection Act.

Since the investigation has reached its logical conclusion, earlier applications relating to CBI directions stand disposed of.

Disciplinary Proceedings Still Pending

The Court noted that despite earlier directions, Uttarakhand has not completed the departmental proceedings against delinquent Indian Forest Service officers. The State has been given three further months to conclude the process.

Case : In Re : Corbett

Citation : 2025 LiveLaw (SC) 1112

Click here to read the judgment