The Kerala High Court on Monday (August 17) disposed of a plea preferred by the makers of the Mohanlal-starrer Malayalam film 'Athimanoharam' seeking a direction to the Forest Department officials to consider their request to permit film shooting in Pamba and Sannidhanam. [2026 LiveLaw (Ker) 449]

The Division Bench of Justice Raja Vijayaraghavan V. and Justice K.V. Jayakumar yesterday took note of the submission made by the Special Government Pleader for Forests that the Deputy Director, Periyar Tiger Reserve (Periyar Wildlife Division), had rejected the request.

It was noted that the request was rejected in view of the decision in Angels Nair v. The Principal Secretary and Ors. after finding that the areas fall within the reserve:

"We find from the order that the Deputy Director has taken a stand that in terms of the directions issued by a Division Bench...in Writ Appeal No. 2179 of 2023 and as in view of the order...dated 26.08.2025 issued by the Government, no permission can be granted for shooting commercial films and television serials within Wildlife Sanctuaries, National Parks or Tiger Reserves. The areas mentioned in the representation form part and parcel of the Periyar Wildlife Sanctuary and the Periyar Tiger Reserve, and have been leased or diverted in favour of the Travancore Devaswom Board for facilitating the Sabarimala pilgrimage. The legal status of the leased/diverted forest land remains unchanged."

The plea before the Court was preferred by director Tharun Moorthi and producer Ashiq U.E. They proposed to carry out shooting of the film at Pamba and Sannidhanam, and accordingly, permission was received from the Devaswom Commissioner, TDB. However, the Devaswom Commissioner's permission was conditional - they have to obtain prior permission from the Chief Conservator of Forest, the Deputy Director of the Periyar Tiger Reserve, and the Division Forest Officer, Pathanamthitta. 

The film-makers then preferred representations before the DFO and the Deputy Director. For a direction to these officers to consider their representations, they came before the High Court.

The Court had earlier passed an interim direction to the Deputy Director to consider the representations after hearing the parties. Subsequently, the same was rejected.

With respect to the representation before the DFO, permission was granted after considering a report of the Range Forest Officer, Goodrical that the areas requested for permission are the “Tea Shop opposite to the Pamba petrol bunk” and “Pamba KSRTC bus stand and surroundings”.

"After considering the report of the Range Forest Officer, the DFO has taken a decision that film shooting can be permitted in the locations above from 18.08.2026 to 28.08.2026 subject to payment of prescribed fees and execution of the requisite agreement with the Forest and Wildlife Department," the Court recorded.

Since decisions have already been made by the officials, the Court was of the view that nothing survives in the plea. However, the filmmakers sought to reserve their right to challenge the Deputy Director's decision.

Recording the same, the Court disposed of the plea.

Case No: WP(C) No. 28032 of 2026

Case Title: Tharun Moorthi and Anr. v. State of Kerala and Ors.

Citation: 2026 LiveLaw (Ker) 449

Counsel for the petitioners: Lakshmi Narayan (Sr.), R. Rajanie, Vaishnavi Shaji, Nevil Zacharia Mathew

Counsel for the respondents: Syam Kumar C.R. - Special GP (Forest), G. Biju - TDB 

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