NGT Directs Madhya Pradesh Government to Frame SOP and Visitor Limits for Darshan Yatra in Bandhavgarh Tiger Reserve Core Area
Pranav B Prem
The National Green Tribunal (NGT), Central Zone Bench, Bhopal, comprising Justice Sheo Kumar Singh (Judicial Member) and Dr. Vijay Kulkarni (Expert Member), has expressed serious concern over the Madhya Pradesh authorities permitting the annual Darshan Yatra in the core area of Bandhavgarh Tiger Reserve. The Tribunal warned that large-scale gatherings in such ecologically fragile zones risk causing irreparable damage to biodiversity and directed the State Government to finalise a Standard Operating Procedure (SOP) for regulating the event within three months.
Background of the case
The application was filed by environmental activist Ajay Shankar Dubey, questioning the legality of permissions granted for the Kabir Darshan Yatra inside the reserve’s core zone. The applicant contended that such events, drawing thousands of devotees, violated provisions of the Wildlife (Protection) Act, 1972, the Forest (Conservation) Act, 1980, and the Environment (Protection) Act, 1986. The Tribunal noted that Bandhavgarh is a critical tiger habitat under Project Tiger. It stressed that the core zone is meant to remain inviolate for the protection of endangered species, particularly tigers, and any mass human activity such as religious yatras disturbs this fragile equilibrium.
The Bench recorded that previous yatras had witnessed participation of more than 14,000 people, a figure confirmed by the State’s own tourism authorities. Pilgrims reportedly bathed in the Charanganga River, camped overnight without sanitation facilities, cut bamboo for walking sticks, and created noise that disturbed tigers and other species.
Findings of the Tribunal
The NGT found that the permission granted by the Field Officer of Bandhavgarh Tiger Reserve was defective as it failed to incorporate safeguards like participant caps, fixed entry-exit timings, waste management, sanitation, and crowd control measures. Such lapses, the Tribunal held, posed significant environmental risks. It observed: “The core zone of the park is an inviolate area designed to provide a sanctuary for endangered species. Any human activity, including religious yatras, in this core zone disrupts this fragile equilibrium, leading to habitat destruction, disturbance to wildlife, and irreparable environmental degradation.”
The Bench also examined a carrying capacity study undertaken in January 2025 by the Wildlife Institute of India (WII), Dehradun, led by Dr. Parag Nigam. The study estimated that while the terrain could physically accommodate 7,000–8,000 pilgrims, due to steep climbs, fragile pathways, and the movement of tigers, elephants, leopards, and bears, the safe carrying capacity was only 4,000–5,000 visitors. The WII recommended mandatory online registration a month in advance, entry only by vehicles, and better management by the park authorities and district administration.
The State government informed the Tribunal that the committee’s recommendations, including vehicle-only entry and registration protocols, had been forwarded to the Principal Chief Conservator of Forests for final approval and formulation of a binding SOP.
Tribunal’s Directions
Taking note of these developments, the NGT directed the Madhya Pradesh government to finalise the SOP and related guidelines within three months. It also stressed that until such a framework is put in place, the authorities must ensure strict compliance with the “Guidelines for Tourism in and around Tiger Reserves” issued in 2012 under the Wildlife (Protection) Act. The Bench underscored that while faith must be respected, it cannot override ecological imperatives in a legally protected tiger habitat. The Tribunal disposed of the application with liberty to aggrieved parties to approach the appropriate forum once the State’s SOP is finalised and published.
With these directions, the NGT disposed of the original application, cautioning the Madhya Pradesh authorities that unregulated mass pilgrimages in the Bandhavgarh Tiger Reserve core zone are inconsistent with environmental law and pose grave risks to biodiversity.
Appearance
For Applicant (s): Mr. Harshwardhan Tiwari, Adv.
For Respondent(s): Mr. Prashant M. Harne, Adv.
Cause Title: Ajay Shankar Dubey V. Shri Shubhranjan Jain & Ors.
Case No: Original Application No. 268/2024(CZ)
Coram: Justice Sheo Kumar Singh [Judicial Member], Dr. Vijay Kulkarni [Expert Member]
