Explained: Saranda’s forests and the case for a ‘sanctuary’ before Supreme Court

The case before the Supreme Court

The Supreme Court directed the Jharkhand government to notify an area of 314 sq km as a wildlife sanctuary while hearing a plea, which sought compliance with a July 2022 judgment of the National Green Tribunal’s eastern zone Bench. The plea before the NGT sought a declaration of an eco-sensitive zone in Saranda/Sasangada Sanctuary in West Singhbhum district.

The petitioner had argued that the large forested area was already declared as a “game sanctuary” in 1968, in undivided Bihar. It was underlined before the NGT that under the Wildlife Protection Act, 1972, any sanctuary and national park declared by a state government under any Act, before the 1972 Act, shall be “deemed” as a sanctuary or national park.

Even as the NGT did not find anything on record to show that the Saranda Forest Division was ever notified as a game sanctuary, it ordered the Jharkhand government to consider whether the area needed to be declared as a sanctuary. It recognised that Saranda was a “repository” of some of the finest Sal forests in the country. The state government, though, did not notify any sanctuary or conservation reserve, leading to a plea before the apex court.

A Supreme Court Bench on November 20, 2024, took on record the NGT’s directions and directed the Jharkhand government to come out with a positive response on the declaration of a sanctuary. Between November and September 2025, the CJI-led bench has pulled up the state’s opportunities to complete the process of sanctuary declaration.

In fact, twice, once on April 16 and then on September 17, the CJI pulled up the Jharkhand government for keeping the matter pending, and for its “dilly dallying” tactics. It even went to the extent of directing state government officials to explain why action should not be taken for committing contempt for forming a committee to review “boundaries of the proposed sanctuary”, especially keeping in mind potential mining areas.

On October 8, senior advocate Kapil Sibal, appearing for the Jharkhand government, assured the court that the state had no intention to run away from the sanctuary proposal. The court thus ordered the state to submit an undertaking that an area of 31,468.25 hectares or 314.68 sq km will be notified as a wildlife sanctuary. On October 17, the Jharkhand government submitted a draft proposing to notify over 25,000 hectares instead of 31,468.25 to protect the rights of communities, but the CJI-led bench decided to hear the matter next week.

The court also clarified, on a plea by Steel Authority of India Ltd, that the wildlife sanctuary shall not affect any valid and subsisting mining leases in case such leases have already been granted and are operational. Solicitor General Tushar Mehta had argued that SAIL’s iron ore mining will be hit and sought protection for the mines.

Saranda’s ecological importance and mining reserves

Saranda, meaning seven hundred hills, forest division in West Singhbhum district covers about 856 sq km, and 816 sq km is a reserved forest, and the rest is a protected forest. In its assessment of the biological and ecological significance of the Saranda landscape, the Wildlife Institute of India has underlined that the area is historically recognised for its rich biodiversity.

It presently harbours elephants, four-horned antelope, and sloth bear, and is experiencing habitat degradation and fragmentation and is home to three elephant corridors, providing connectivity with other neighbouring forests.

Tigers have been sighted in the past, but they have not colonised this forest in recent times.

The proposed sanctuary, it said, will help protect the biodiversity hotspot in the junction of Jharkhand and Odisha. Moreover, mining operations, including illegal iron ore and manganese extraction, as revealed by the Justice M B Shah Commission of Inquiry, have led to a decline in wildlife density and biodiversity.

This was also documented in the Indian Council of Forest Research and Education (ICFRE) Carrying Capacity Study Report on Saranda and Chaibasa Region, prepared as part of the action taken on the Shah Commission report. Moreover, the WII noted in its recent assessment that anthropogenic pressures have fragmented the Saranda Forest habitats, and its 2016 assessment highlighted a reduction in butterflies, mammals, and birds, emphasising a negative correlation between mining proximity and species richness, thus showing the urgent need to protect the area.

Moreover, elephants, once widespread in Saranda, have gradually moved away to Chhattisgarh and Odisha, and presently, the corridors to the south and east of Saranda are also under stress. Jharkhand hosts two distinct population clusters – Palamau and Singhbhum, according to the latest elephant estimation report released on October 14 and has an estimated 217 elephants now.

Jharkhand government’s contentions and mining interests

The Hemant Soren government has argued in the Supreme Court that while it supports the declaration of the sanctuary, the rights of tribals and other forest dwellers must be protected, and has also pointed out high revenue from mineral extraction. The Saranda region accounts for 26% of the country’s iron ore reserves.
In an affidavit submitted on October 7, the state government said that the Saranda region falls under the fifth schedule and is inhabited by Ho, Munda and allied Adivasi communities, including some particularly vulnerable tribal groups.

It argued that sanctuary notification risks criminalising subsistence activities, thereby violating provisions of the Forest Rights Act, Panchayats (Extension to the Scheduled Areas), 1996. Amicus K. Parameshwar has maintained that the declaration of a sanctuary will not extinguish any rights of tribals or forest dwellers.
As per Steel Authority of India’s interlocutory application in the Supreme Court matter, active mines in and around Saranda currently produce 10 to 15 million tonnes a year, which is roughly 5 per cent of India’s annual iron-ore output.

Despite SAIL and the Jharkhand government’s concerns regarding a sanctuary’s impact on mining interests in and around Saranda, the court has recorded in its order that no mining activity is currently going on in the proposed sanctuary area. In fact, the Divisional Forest Officer, Saranda Forest Division, submitted this detail in an affidavit.

Controversies around mining and the threat it poses to the rich biodiversity of Saranda are also not new. Under the United Progressive Alliance (UPA) government, a commission of inquiry led by Justice M B Shah had probed illegal mining in Jharkhand. The probe discovered unlawful iron ore extraction in violation of mining and environmental laws.

The Shah Commission had exposed that iron ore of an approximate value of 14,403 crores and manganese of Rs 138 crore were extracted illegally. As part of the action taken on Justice Shah Commission’s recommendation, the Union Environment Ministry prepared a sustainable mining plan for iron mining in Saranda. This put in place ‘go and no-go’ areas for mining with an annual cap of 64 million tonnes per annum, with room to increase it in case sustainable mining is done.