Supreme Court on Mining in Saranda Wildlife Sanctuary: Protection of Forest Ecosystem Upheld.

Headnote:

The Supreme Court reaffirmed that the Saranda Forest in Jharkhand, being an ecologically fragile and wildlife-rich area, must be protected from unregulated mining. The Court directed a complete halt on fresh mining leases and renewals within the notified sanctuary and its eco-sensitive zone until a comprehensive ecological carrying-capacity study is completed. It emphasized balancing economic development with environmental sustainability, reiterating that no project can override the constitutional mandate of environmental protection under Article 48-A and Article 51-A(g).

Background:

• The matter originated from continuing monitoring proceedings under T.N. Godavarman Thirumulpad v. Union of India (W.P. (C) 202/1995), concerning illegal forest diversion and mining in protected areas.

• The Saranda Wildlife Sanctuary, located in West Singhbhum District, Jharkhand, covers ~820 sq. km and forms a vital elephant corridor and biodiversity hotspot.

• Reports by the Ministry of Environment, Forest and Climate Change (MoEF&CC) and the Wildlife Institute of India (WII) highlighted heavy degradation due to iron-ore mining, loss of canopy, and contamination of streams.

• Petitioners and conservation groups sought immediate intervention, alleging that several leases were granted or extended without wildlife clearance under the Wildlife (Protection) Act, 1972 and Forest (Conservation) Act, 1980.

Court’s Observations:

• The Court noted that forest land cannot be used for mining without prior approval under Section 2 of the Forest (Conservation) Act, 1980, and that such approvals must also satisfy the tests under Section 29 and Section 35 of the Wildlife (Protection) Act, 1972 when the area is part of a sanctuary or its ESZ.

• It reiterated that sustainable development is not an unrestricted license for exploitation, stressing the public trust doctrine and the State’s duty to act as trustee of natural resources.

• The Bench observed that continued mining in Saranda would cause irreversible damage to the elephant corridors, sal forests, and local tribal livelihoods.

• The Court rejected the State’s plea to allow partial mining on “already broken up” areas until the ecological assessment report is finalized.

Directions Issued:

1. Immediate Suspension – All fresh mining leases, renewals, or expansion projects within the Saranda Wildlife Sanctuary and its eco-sensitive zone are to remain suspended until further orders.
2. Ecological Audit – MoEF&CC and WII to conduct a comprehensive carrying-capacity study within six months and submit findings to the Central Empowered Committee (CEC).
3. Restoration Plan – Jharkhand Forest Department and mining companies directed to jointly prepare and implement a forest restoration and wildlife-corridor revival plan within one year.
4. Accountability – The Court directed the CBI and ED to examine allegations of illegal diversion and financial irregularities in mining leases granted between 2010–2020.
5. Livelihood Measures – The State Government was instructed to create alternative livelihood programmes for affected tribal communities under CAMPA and CSR frameworks.

Legal Provisions Discussed:

• Article 48-A & Article 51-A(g), Constitution of India – Duty to protect the environment.

• Forest (Conservation) Act, 1980 – Section 2 (restriction on forest-land diversion).

• Wildlife (Protection) Act, 1972 – Sections 29 & 35 (protection of wildlife sanctuaries).

• Environment (Protection) Act, 1986 – Regulation of industrial projects in ESZs.

• Doctrine of Public Trust – State as custodian of natural resources for the public good.

Conclusion:

The judgment underscores the Supreme Court’s continuing environmental oversight in the Godavarman series. It places the Saranda ecosystem under strict judicial protection, restricting industrial activity until the scientific assessment validates its sustainability. The decision serves as a precedent reinforcing that ecological preservation outweighs commercial extraction in ecologically sensitive landscapes.

Citation: 2025:INSC:1311

Case: In Re: Saranda Wildlife Sanctuary

Court: Supreme Court of India

Bench: Chief Justice D.Y. Chandrachud, Justice J.B. Pardiwala & Justice Manoj Misra

Date of Decision: 13 November 2025

Original Application: W.P. (C) No. 2997 of 1995