The Supreme Court of India, in an order dated 19 November 2025, prohibited the conduct of tiger safari activities within the core and critical tiger habitat areas of the Jim Corbett Tiger Reserve. A Bench of Chief Justice BR Gavai, Justice AG Masih, and Justice AS Chandurkar held that the conservation imperative for endangered tiger populations prevails over considerations of tourism revenue, and directed the cessation of safari operations in designated core zones.
Background
The order was passed in the long-running T.N. Godavarman Thirumulpad proceedings, which have served as the primary judicial vehicle for forest and wildlife conservation directives in India since the mid-1990s. The specific issue arose from reports that tiger safari operations within the Jim Corbett Tiger Reserve in Uttarakhand were being conducted in core and critical tiger habitat zones, potentially disturbing breeding populations and disrupting natural behavioural patterns.
The Wildlife (Protection) Act, 1972 establishes the framework for tiger reserve management, with a distinction between core (or critical tiger habitat) areas — where human activity is strictly regulated — and buffer zones, where limited ecotourism may be permissible. The National Tiger Conservation Authority (NTCA) has issued guidelines governing tourism activities in tiger reserves, but the enforcement and interpretation of the boundary between permissible ecotourism and prohibited encroachment into core habitats has been a recurring source of contention.
Key Holdings
The Supreme Court directed the following:
Safari operations prohibited in core habitat: All tiger safari operations within the core and critical tiger habitat of the Jim Corbett Tiger Reserve must cease. The Bench held that the introduction of vehicular safari tourism in core zones is inconsistent with the statutory purpose of protecting critical tiger habitat.
Conservation over revenue: The Court rejected the argument that safari tourism generates revenue essential for conservation funding. Chief Justice Gavai observed that the economic value of tourism cannot justify activities that compromise the very wildlife populations the tourism claims to support.
Buffer zone operations permissible: The prohibition was confined to core and critical habitat areas. Safari and ecotourism operations in designated buffer zones may continue, subject to compliance with NTCA guidelines and carrying capacity assessments.
Broader applicability: While the order specifically addressed Jim Corbett, the reasoning articulated by the Bench has implications for tiger safari operations across all tiger reserves in India where core habitat boundaries are at issue.
Implications for Practitioners
Environmental law practitioners and state forest departments must assess existing safari operations across all tiger reserves in light of this order. Any safari routes that traverse core or critical tiger habitat areas will need to be re-evaluated and potentially re-routed to buffer zones.
For wildlife tourism operators, the commercial impact is significant but geographically bounded. Operations in buffer zones remain legally permissible, and the judgment effectively compels a reorientation of tourism infrastructure away from core areas. Practitioners advising tourism operators should review concession agreements and licensing terms for core zone exposure.
The order also revitalises the regulatory authority of the NTCA. State governments that had permitted safari operations in core zones on the basis of perceived local authority may need to align their policies with both the NTCA framework and this judicial direction. Practitioners handling forest and environment disputes should monitor whether similar orders are sought for other tiger reserves.