Supreme Court Expresses Concern About Unregulated Visits Of Devotees In Places Of Worship Situated In National Parks & Sanctuaries

The Supreme Court has expressed concerns at the unregulated number of devotees visiting places of worship which are situated in national parks and sanctuaries.

"In many of the forests in such Protected Areas, certain places of worship are situated where the devotees come in thousands and lakhs. On one hand, it is not possible for the administration to restrain such devotees from visiting the places of worship. On the other hand, such uncontrolled visits of the devotees results in problems with the management of such Protected Areas", a bench comprising Justices BR Gavai and Vikram Nath observed.

The bench made these observations while considering a report filed by Amicus Curiae K Parameshwar regarding the effect of devotees visiting a temple located within the Sariska tiger reserve in Rajasthan.  According to the findings, the large number of devotees visiting the forest has had an adverse effect on the management of the Tiger Reserve.The note was based on the report of the State Empowered Committee on the Management of the Sariska Tiger Reserve and the temple situated within it.

The Court observed that the the issue as raised is also an issue of concern in some other National Parks and Sanctuaries where places of worship are situated.

The bench of Justice B.R. Gavai and Justice Vikram Nath said that, “we find that the note prepared by the learned Amicus Curiae is an attempt to solve this critical issue. We therefore, find that at least on a pilot basis, the suggestions should be considered for implementation.”

According to the Amicus Curiae's findings, the number of devotees visiting the temple every day is in the thousands. On special occasions like fairs, this number crosses into the lakhs.

It was submitted that the uncontrolled number of devotees visiting the forest has an adverse effect on the management of the Tiger Reserve.

The Amicus Curiae suggested that in order to control the movement of devotees within the forest, entry to the forest for visiting the temple should be allowed only through electric buses.

He submitted that the electric buses would transport the devotees from the entry gate of the Tiger Reserve to the temple, and back to the gate in the same manner.

The note also pointed out that although the park is closed during the monsoon season, devotees still visit the temple during that period, which further complicates forest management.

In light of the above the Court found that at least on a pilot basis, the suggestions should be considered for implementation.

The Court deemed it necessary to hear from the State of Rajasthan, as well as the Ministry of Environment, Forests and Climate Change and the Ministry of Road Transport and Highways of the Union of India, before issuing any orders.

Further, the Court has issued notice on the matter to the Union of India, through the Principal Secretary, Ministry of Environment, Forests and Climate Change, and Ministry of Road Transport and Highways, and the State of Rajasthan through its Chief Secretary.

Case Title: In re: T.N. Godavarman v. UOI

Citation : 2023 LiveLaw (SC) 362

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