A bench of Justices Ashutosh Kumar and Arun Dev Choudhury heard Borboruah’s plea, which sought directions to zoo authorities in Assam, ensuring strict compliance with the guidelines for housing exotic animals under the Zoo Rules, 2009.
The bench observed that the concerns raised by Borboruah in the PIL had been adequately addressed.
Temporary ‘home’ 🌿🐒🌿
The Assam State Zoo-cum-Botanical Garden serves as a rescue and rehabilitation centre for wild animals in distress, especially the exotic animals rescued from smuggling attempts by illegal traders in international markets. The zoo serves as a temporary or, at times, even permanent shelter for the animals.
However, the PIL pointed out that the rescued animals are often kept in restricted spaces after being rescued.
Plan to upgrade Assam Zoo 🐘🦒🌳
D Gogoi, counsel for the Forest Department, submitted an affidavit indicating that the state government has already taken a policy decision to undertake a major overhaul of zoos located in Assam, with a special focus on the Assam State Zoo-cum-Botanical Garden. The project is aimed at modernising the zoo’s infrastructure for animals, staff and visitors alike.
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The court was informed that a work order for modernisation has been issued by the Chief Engineer, Public Works Department. The project is valued at approximately Rs 345.67 crore and is scheduled to be completed by November 29, 2026. The plan is expected to significantly upgrade the existing facilities and transform the zoo into a modern wildlife conservation and visitor education centre.
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India · Conservation Status · 2026 Wildlife Under Threat Population status and distribution of five of India’s most vulnerable species — from the alluvial grasslands of Assam to the rainforests of the Northeast.
5 Species Profiled
1 Critically Endangered
2 Endangered
2 Vulnerable
NE Primary Region
Species Profiles — All Five Species
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Greater One-horned Rhinoceros Vulnerable
Once on the brink of extinction, this species has made a resilient recovery across the floodplains of Assam and Nepal — a landmark conservation success story.
Global Population (2025) 4,075 3,323 in India alone
Primary Stronghold Kaziranga NP Assam & West Bengal
Recovery ProgressStrong ↑
Key Findings
Trend: Rose from 4,014 (2022) to 4,075 (2025) — steady upward trajectory.
Threat: Habitat expansion is now the primary priority over poaching.
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Golden Langur Endangered
Recognizable by its golden coat, this primate is restricted to a narrow corridor between Bhutan’s Black Mountains and the Brahmaputra River.
India Population (2024) 7,396 93% in forest reserves
Core Habitat W. Assam Manas · Ripu RF
Key Findings
Split: 5,566 northern range; 1,830 in fragmented southern pockets.
Threat: Fragmentation causes absence of all-male bands, risking genetic health.
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Hoolock Gibbon Endangered
India’s only ape species, known for haunting vocal duets. Populations have collapsed by nearly 90% in 30 years due to relentless deforestation.
Estimated Population ~12,000 Across NE India
Range NE India S. of Brahmaputra
Population Decline~90% over 30 yrs ↓
Key Findings
Key Site: Hoollongapar Gibbon Sanctuary — the only PA named for this species.
Threat: Roads, railways, and tea plantation expansion fragment forest habitat.
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Clouded Leopard Vulnerable
An elusive, arboreal predator with the largest canine teeth relative to body size of any feline — the “modern-day saber-tooth” of the Northeast rainforests.
Global Adult Population <10,000 Declining & elusive
Indian Range Himalayan Foothills Sikkim · Arunachal
Habitat Loss RateModerate ∴
Key Findings
Research: 2025 studies found core habitats in Dehing Patkai and Fakim (Nagaland).
Threat: Shifting cultivation and illegal skin trade are primary pressures.
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Pygmy Hog — World’s Smallest Wild Pig Critically Endangered
A specialist of tall, wet alluvial grasslands that builds unique thatched nests with roofs. Presumed extinct until rediscovered in 1971. Its presence signals the health of an entire grassland ecosystem.
Wild Population (2026) <350 Critically endangered
Distribution Assam Only Manas NP · Orang NP
Reintroduced Since 1995 179+ ~200 now at Orang NP
Extinction RiskCritical 🔴
Key Findings
Rediscovery: Presumed extinct until captive breeding and reintroduction programme running since 1995.
Progress: Reintroduced population at Orang NP has grown to approximately 200 individuals.
Indicator species: Its presence confirms the health of tall alluvial grasslands — a critically underprotected habitat type.
Redesigning animal enclosures
Gogoi informed the bench that the project includes a comprehensive redesign of animal enclosures. The specifications are being revised and upgraded in accordance with the guidelines issued by the Central Zoo Authority, which prescribed minimum space requirements and structural standards for housing exotic and indigenous animals.
The objective would be to ensure that the animals were kept in enclosures that provide sufficient space, environmental enrichment and conditions closer to their natural habitats.
It was further submitted that, as part of the ongoing modernisation project, these rescue facilities would also be upgraded. The authorities will make all efforts to ensure that the housing arrangements for rescued exotic species also comply with the prescribed guidelines on enclosure dimensions and animal welfare standards.
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Taking note of these assurances, the bench observed that the concerns raised by Borboruah in the PIL had been adequately addressed by the state authorities through the proposed modernisation initiative. The court expressed satisfaction that the government had taken concrete steps to align zoo infrastructure with the applicable guidelines and rules governing animal welfare.
Option to revive PIL
While closing the PIL, the court made an important observation to safeguard the interests of captive animals. The bench clarified that if the petitioner, upon examining the architectural illustrations, structural designs or any other relevant materials relating to the modernisation project, finds that the guidelines of the Central Zoo Authority are not being adhered to, he would be at liberty to seek revival of the petition “by filing a two-page affidavit,” in which situation, the PIL will be addressed again.
Doors of justice to remain open
For now, the Gauhati High Court might have closed the PIL, but it has kept its doors open for future interventions if necessary, ensuring that the interests of animals who cannot approach courts themselves remain protected under the rule of law.
For living creatures that cannot speak human language, covering the distance to justice remains a challenge, but assurance matters. An enclosure that defines their world, and ours too. Like cherished childhood memories, the zoo still plays a prominent role in connecting their world to ours.
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A promised home and humane care rest on humans who hold the keys to those locked cages. The pleaders might not knock on the courtroom with their paws, but a human again would. We all shall have access to justice till there is someone choosing to listen.
(With inputs from Sumit Kumar Singh)
The bench observed that the concerns raised by Borboruah in the PIL had been adequately addressed.