The Supreme Court of India has once again reminded state governments that environmental commitments are not optional promises but binding legal obligations. On September 27, 2025, the Court pulled up the Jharkhand Government for failing to notify the Saranda and Sasangdaburu forests as a wildlife sanctuary and conservation reserve, despite repeated undertakings before the judiciary and the National Green Tribunal (NGT).
The bench of Chief Justice of India BR Gavai and Justice K Vinod Chandran was hearing a batch of environmental matters under the landmark T.N. Godavarman case, which has served as the foundation of Indian environmental jurisprudence for over two decades. The Court expressed serious displeasure at the State’s change of stance and warned of contempt proceedings against Jharkhand’s Chief Secretary if compliance is not completed before the next hearing.
Background: Saranda and Sasangdaburu Forests
The Saranda forest in West Singhbhum district is Asia’s largest Sal forest, covering more than 820 sq. km. Rich in biodiversity, elephant corridors, medicinal plants, and rare fauna, it is also home to several tribal communities. The Sasangdaburu forest, located nearby, is similarly known for its pristine ecological value.
However, these forests also sit on vast deposits of iron ore and other minerals, making them a hotspot for mining activities. Over the years, conservationists have warned that large-scale mining has fragmented habitats and threatened wildlife populations, particularly elephants and endangered species.
Declaring these regions as a wildlife sanctuary and conservation reserve under the Wildlife Protection Act, 1972, would provide stronger legal safeguards against unsustainable mining and deforestation.
NGT and Supreme Court Directions
The issue of protecting Saranda and Sasangdaburu has been raised multiple times. On July 12, 2022, the National Green Tribunal (NGT) directed the Jharkhand Government to consider notifying the region as a sanctuary.
When no action was taken, petitioners approached the *Supreme Court, which on November 20, 2024, directed the State to file an affidavit explaining its inaction.
In its affidavits dated February 20, April 16, and April 29, 2025, the Jharkhand Government assured the Court that:
- A proposal had been moved to declare 57,519.41 hectares as Saranda Wildlife Sanctuary.
- Another 13,603.806 hectares would be declared as Sasangdaburu Conservation Reserve.
- The proposal had been sent to the Wildlife Institute of India (WII), Dehradun for expert comments.
- After receiving WII’s feedback, the proposal would go to the State Wildlife Board and then for Cabinet approval before final notification.
On this basis, the Court gave the State two months’ time to complete the process.
Contradictions and Delays
Despite this clear roadmap, Jharkhand failed to keep its word. WII submitted a positive report on May 30, 2025, supporting the notification of the sanctuaries. But instead of acting, the State Government on May 13, 2025, formed a new committee to “review the boundary/area of the proposed sanctuary,” citing the Geological Survey of India’s identification of mining potential in the region.
This reversal contradicted the affidavits already on record. The Court observed that the State Government had changed its stand to favor mining interests at the cost of environmental commitments.
Supreme Court’s Observations
The Court’s order left little room for ambiguity:
“We are of the considered view that the State Government of Jharkhand is in clear Contempt of the order passed by this Court on 29.04.2025.”
The bench reminded Jharkhand that its Chief Secretary had been present when assurances were given. The State cannot now backtrack on commitments made on affidavit.
Accordingly, the Court directed the Chief Secretary of Jharkhand to appear personally on October 8, 2025, at 10:30 a.m. to show cause why contempt proceedings should not be initiated.
However, the Court clarified that if the Government complies with the April 29 order before the hearing, the personal appearance of the Chief Secretary would not be required.
Legal Significance: Contempt and Mandamus
This case highlights two important legal aspects:
- Contempt of Court – When a government gives an undertaking to the Court and later fails to act, it amounts to wilful disobedience. The Supreme Court’s power to punish for contempt under Article 129 of the Constitution ensures accountability.
- Mandamus Against the State – The Court warned that continued non-compliance could force it to issue a writ of mandamus, compelling the Jharkhand Government to notify the sanctuaries as promised. This underscores the judiciary’s role in enforcing environmental protection when executive inaction persists.
Mining vs. Conservation: The Larger Conflict
The tension in this case reflects a larger policy dilemma in India: balancing economic development through mining with ecological conservation. Jharkhand, Odisha, and Chhattisgarh contain some of India’s richest mineral belts, but these areas also overlap with *dense forests, wildlife habitats, and tribal lands.
- Conservationists argue that unregulated mining threatens India’s biodiversity hotspots.
- State governments often prioritize mining for revenue, jobs, and industrial growth.
- The judiciary has repeatedly stepped in to ensure that sustainable development and inter-generational equity are respected.
The Saranda forests have already seen extensive iron ore mining. Experts warn that further fragmentation without sanctuary status would lead to irreversible ecological loss.
Implications for Jharkhand and Beyond
This case is not just about Jharkhand. Its outcome will set a precedent for other states where mining interests clash with wildlife protection. Key implications include:
- Stronger Judicial Oversight: States cannot make promises in court and then backtrack for economic reasons.
- Accountability of Bureaucracy: By summoning the Chief Secretary personally, the Court has placed responsibility at the highest administrative level.
- Boost to Conservation Law: If Saranda and Sasangdaburu are notified, it will strengthen India’s protected area network.
- Mining Policy Impact: Governments may have to re-think granting mining leases in eco-sensitive zones.
Conclusion
The Supreme Court’s tough stand against the Jharkhand Government signals that environmental protection is a constitutional obligation, not a negotiable option. The Saranda and Sasangdaburu forests are not just patches of green on the map but critical ecosystems that sustain wildlife, regulate climate, and support tribal communities.
By threatening contempt and mandamus, the Court has drawn a clear line: promises made in the highest court must translate into action on the ground. The coming weeks will reveal whether Jharkhand honors its word or continues to drag its feet. Either way, the case will remain a benchmark in the evolving narrative of environmental governance in India.
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