Supreme Court of India on Deer Translocation from A.N. Jha Deer Park, Hauz Khas.

Headnote:

The Supreme Court addressed concerns regarding the translocation of deer from A.N. Jha Deer Park in Hauz Khas, New Delhi, to tiger reserves in Rajasthan. The petitioner-NGO challenged the translocation, alleging non-compliance with Central Zoo Authority (CZA) and IUCN guidelines, unsafe transport, improper selection of animals, and inadequate post-release monitoring. The Court found that prior translocations were poorly documented, lacked ecological feasibility assessment, and endangered the welfare of the animals. The Court directed a comprehensive, independent scientific assessment before any further translocation, ensuring compliance with statutory and international wildlife management norms.

Background:

1. A.N. Jha Deer Park, established in 1968, had expanded from 10.26 to 10.97 acres by 2021 and housed chital/spotted deer (Axis axis).
2. The Delhi Development Authority (DDA) managed the park under CZA license, which was canceled in 2014 for non-compliance and reinstated with corrective assurances.
3. Persistent mismanagement continued, with overpopulation reaching 350–600 deer, inadequate veterinary care, insufficient fodder, and poor enclosure conditions.
4. In 2022, DDA sought to translocate ~550–600 deer to Rajasthan and Delhi reserves citing overcrowding; CZA approved translocation following IUCN guidelines.
5. Petitioner-NGO filed a PIL challenging the cancellation of CZA recognition and the translocation process. The Delhi High Court allowed translocation to proceed for deer not exceeding DDA’s capacity, retaining ~two dozen at the park.

Court’s Observations:

1. The Deer Park suffered chronic managerial deficiencies and overpopulation that threatened deer welfare.
2. DDA lacked logistical and veterinary capacity to manage the large population.
3. Translocations already undertaken were flawed: overcrowding in trucks, transport of juveniles and pregnant deer, inadequate post-release monitoring, and insufficient habitat suitability assessment in recipient reserves.
4. Field surveys revealed discrepancies in the number of deer translocated and surviving, lack of identification tags, and possible animal welfare violations.
5. Scientific guidelines under CZA and IUCN were inadequately followed, undermining both animal welfare and ecological objectives.

Directions:

1. Central Empowered Committee (CEC) to conduct an on-ground survey of the Deer Park and file a report within eight weeks, detailing:
2. Current deer population
3. Ecological carrying capacity
4. Maximum sustainable population
5. Surplus population eligible for translocation
6. CEC to inspect release sites (Ramgarh Vishdhari and Mukundra Hills Tiger Reserves) and report on:
7. Actual surviving deer
8. Habitat suitability, forage and water availability, predation risk
9. Veterinary monitoring and post-release protocols
10. Compliance with CZA and IUCN guidelines
11. CEC to prepare a roadmap for any future translocation: tagging, transport, veterinary protocols, ecological feasibility, post-release monitoring.
12. All authorities must fully cooperate with CEC.
13. DDA to report on land previously used for deer enclosures and past/present status.
14. DDA prohibited from holding commercial events in the park; instead, public outreach and educational programs are encouraged.
15. No additional deer translocations until further orders.

Legal Provisions Discussed:

1. Article 21, Constitution of India – Right to a clean and ecologically balanced environment
2. Articles 48A & 51A(g), Constitution of India – Directive principles on environmental protection
3. Wild Life (Protection) Act, 1972 – Statutory framework for zoo and wildlife management
4. IUCN Guidelines – Standards for translocation and reintroduction of captive wildlife

Conclusion

The Court emphasized the need for scientifically grounded, ethical, and legally compliant management of urban wildlife. Decisions affecting deer translocation must safeguard animal welfare, ecological balance, and constitutional environmental values. The case is listed for 17 March 2026 for receiving CEC and DDA reports.

Citation: 2025 INSC 1358

Case: New Delhi Nature Society v. Director Horticulture, DDA & Ors.

Court: Supreme Court of India, New Delhi

Coram: Justice Vikram Nath & Justice Sandeep Mehta

Date of Decision: 26 November 2025

SLP (C) No.: 13374-13375 of 2025