Supreme Court Seeks CEC Report On Proposed Mhadei Tiger Reserve, Orders Goa To Maintain Status Quo In Area

The Supreme Court on Monday directed the Central Empowered Committee (CEC) to examine the issue of notifying Goa's Mhadei Wildlife Sanctuary and adjoining areas as a tiger reserve and submit a report within six weeks.

A bench of Chief Justice BR Gavai, Justice K. Vinod Chandran, and Justice Atul S. Chandurkar also ordered the State of Goa to maintain status quo in respect of the areas which the Bombay High Court had directed to be notified as a tiger reserve until the matter is heard again.

“We find that it will be appropriate if the Central Empowered Committee (CEC) examines the issue and submits a report before this Court….In the meantime, the petitioner-State is directed to maintain status quo as on today in respect of the areas which are directed to be notified as tiger reserve by the High Court”, the Court ordered.

The order was passed in the State's appeal against the Bombay High Court's judgment of July 24, 2023, which had directed the Goa government to notify the Mhadei Wildlife Sanctuary and adjoining as a tiger reserve within three months. Environmental action group Goa Foundation objected to clearances granted by the State for commercial projects in the area, that remains unnotified despite the July 2023 judgment.

The State of Goa contended that due to the High Court order, buffer zones will also be required to be created around the sanctuaries, which would engulf 20% of the State's land and affect those living near the tiger reserve.

The petition before the High Court was filed by Goa Foundation seeking notification of the Mhadei sanctuary and adjoining areas as a tiger reserve. The National Tiger Conservation Authority had repeatedly recommended the creation of a tiger reserve in the State, pointing out that Goa had a resident tiger population.

The Supreme Court ordered the CEC to a hear to all stakeholders, including the State Government and the Goa Foundation, before submitting its report. Parties have been given two weeks thereafter to file their responses. The matter will be taken up on November 12, 2025.

The High Court had held that there was no legal impediment in issuing the notification even though the final notification under the Wildlife (Protection) Act, 1972 declaring some areas within Mhadei as a sanctuary had not been issued.

Rejecting the State's stand that the absence of final notification and the pending settlement of rights of forest dwellers were grounds to delay the process, the High Court said the State could not take advantage of its own lapses.

It also noted that the State had failed to settle the rights of forest dwellers in Bhagwan Mahaveer Wildlife Sanctuary for 56 years, and in Mhadei and Netravali Wildlife Sanctuaries for 24 years.

The High Court clarified that issuing a final notification under Section 26-A of the Act was not a prerequisite for declaring a protected area as a tiger reserve. It further directed the government to expedite the settlement of forest dwellers' rights within 12 months.

The High Court also directed the government to establish anti-poaching camps within six months, prevent encroachments in forest areas, and prepare a comprehensive plan for tiger conservation.

It emphasised that protecting tigers, as apex predators, was essential for maintaining ecological balance, safeguarding natural resources, and preserving ecosystem services such as water and soil protection.

Case no. – SLP(C) No. 20683/2023

Case Title – State of Goa Through Chief Secretary & Ors. v. The Goa Foundation & Ors.