The Supreme Court has come down heavily on the State of Jharkhand for repeatedly failing to comply with its earlier assurances regarding the declaration of Saranda and Sasangdaburu forests as a wildlife sanctuary and conservation reserve. The Court made it clear that if compliance with its prior orders is not ensured before the next hearing, the State’s Chief Secretary will have to explain why contempt proceedings should not be initiated against him.

The bench comprising CJI BR Gavai and Justice K. Vinod Chandran was hearing an application in the long-pending environmental matter under T.N. Godavarman v. Union of India.

The Court noted that though the National Green Tribunal (NGT), by its order dated July 12, 2022, had directed Jharkhand to consider declaring the region as a sanctuary, no action was taken until an interlocutory application was filed. Taking note of the area’s rich biodiversity and dense Sal forests, the Court had earlier directed the State on November 20, 2024, to explain its delay through an affidavit.

In response, the State filed affidavits indicating that proposals had been initiated to declare 57,519.41 hectares as Saranda Wildlife Sanctuary and 13,603.806 hectares as Sasangdaburu Conservation Reserve. These proposals were also sent to the Wildlife Institute of India (WII), Dehradun, for comments. On April 29, 2025, the State assured the Court that a final notification would be issued following Cabinet approval, subject to WII’s report.

However, despite WII’s positive recommendation submitted on May 30, 2025, the State instead constituted a Committee on May 13, 2025, to “review the boundary/area of the proposed sanctuary,” citing possible mining prospects identified by the Geological Survey of India.

The Court expressed strong disapproval, highlighting that this reversal contradicted the State’s own affidavits dated February 20, April 16, and April 29, 2025.

The bench remarked:
“When the Secretary was present before us, in the affidavit dated 29.04.2025, a clear assurance was given that once WII approved, all formalities including the State Wildlife Board and Cabinet approval would be completed. Two months’ time was granted accordingly. The State’s conduct is in clear contempt of this Court’s order dated 29.04.2025.”

Accordingly, the Court directed the Chief Secretary of Jharkhand to personally appear on October 8, 2025, at 10:30 a.m. and show cause why contempt should not be initiated. It further warned that if non-compliance continues, the Court may issue a mandamus compelling the State to act as per its earlier commitments.

At the same time, the Court clarified that if the State fulfills its undertaking before the next date, the Chief Secretary’s personal appearance would not be required.

Case Details: In Re: T.N. Godavarman Thirumulpad v. Union of India & Ors. (Writ Petition (Civil) No. 202/1995)