West Singhbhum: On November 13, 2025, the Supreme Court of India delivered one of its clearest conservation orders in recent memory. It directed the Jharkhand government to formally notify 31,468.25 hectares of the Saranda forest as a wildlife sanctuary within three months. The order cited contempt. It set a hard deadline: February 12, 2026.
The deadline passed without a notification. Instead, the state filed a review petition on February 14 error-strewn enough that the registry sent it back. A corrected version was refiled on April 30, 2026.
This is not a story about one delayed order. It is a story about what judicial conservation actually means when a state government has decided, for reasons it will not fully state in open court, that it will not comply.
The Forest in Question
Saranda, situated in the West Singhbhum district of Jharkhand, is widely recognised as Asia’s largest contiguous Sal forest ecosystem, spanning approximately 82,000 hectares across terrain the local Ho tribal language calls the “Land of Seven Hundred Hills.” The forest supports 23 documented mammal species among them the Asiatic elephant, leopard and sloth bear and 138 avian species. Its perennial streams feed the Brahmani river basin and recharge groundwater tables for downstream agricultural communities across two states.
Saranda also sits atop one of the world’s largest single deposits of high-grade iron ore, estimated to exceed 2,000 million tonnes and accounting for roughly 26 percent of India’s total iron ore reserves. SAIL, Tata Steel, Rungta Mines and Usha Martin collectively hold extensive mining leases in the region. The Chiria mine complex alone covers approximately 2,376 hectares nearly three percent of the entire forest division.
The forest’s legal status has been in limbo since 2000, when Jharkhand was carved out of Bihar. The original 1968 Bihar notification declaring Saranda a game sanctuary across 126 compartments and 31,468.25 hectares was never transitioned into formal sanctuary status under the Wildlife Protection Act, 1972. For over two decades, the state expanded mining leases inside this regulatory vacuum.
Repeated Orders By Court
The judicial intervention began in 2020, when wildlife scientist Dr. R.K. Singh filed an application before the National Green Tribunal’s Eastern Zone Bench. The NGT directed Jharkhand to consider notifying Saranda as a sanctuary in July 2022 state took no action.
By 2024 the matter had moved to the Supreme Court through an interlocutory application in the landmark T.N. Godavarman Thirumulpad case, which has served since 1995 as the judiciary’s primary vehicle for forest governance oversight. What followed was a documented escalation. In November 2024, the court asked the state to explain its delay. In April 2025, the Forest Secretary appeared personally and gave a solemn undertaking that notification would follow within two months of receiving the Wildlife Institute of India’s expert report.
The WII submitted its positive recommendation on May 30, 2025. The state responded not with a notification but with a review committee, constituted on May 13, to re-examine the boundary citing mineral prospecting potential flagged by the Geological Survey of India. In September 2025, Chief Justice B.R. Gavai and Justice K. Vinod Chandran accused the state of “gross contempt,” stating that the administration was “indulging not only in dilly-dallying but playing tricks with the court.” The Chief Secretary was summoned personally.
The state arrived in October with a draft notification that reduced the proposed sanctuary to 24,941.64 hectares a boundary crafted, the record suggests to protect mining interests. The Supreme Court rejected it and directed notification of the full 31,468.25 hectares. The deadline was February 12 and the state did not comply.
The Reasons that Government Will Not State Plainly
Officially, the Jharkhand government frames its resistance around tribal welfare. It argues that declaring a sanctuary in a Fifth Schedule area governed by PESA, 1996 and the Forest Rights Act, 2006 will restrict tribal access to forests and displace communities. The concern is not illegitimate in principle. In practice, however the Supreme Court addressed it directly. Its November 2025 order stated that the state’s fears of tribal displacement were “only a figment of imagination,” noting that under Section 24(2)(c) of the Wildlife Protection Act, the District Collector retains the authority to permit existing tribal habitations and rights to continue within sanctuary limits.
The more honest explanation lies in the numbers. The West Singhbhum District Mineral Foundation trust alone holds over Rs 370 crore in accrued funds and expects annual royalty receipts exceeding Rs 165 crore. A strict ban on all mining inside the 314 square kilometre sanctuary and its one-kilometre buffer zone as mandated by the November order would render several high-yield iron ore blocks permanently inaccessible to state-backed and private operators alike.
What Contempt Can and Cannot Do
The constitutional question this dispute raises is precise. Under the Seventh Schedule, forests and wildlife protection fall under the Concurrent List but executive power to issue sanctuary notifications rests primarily with state governments. The Supreme Court derives its jurisdiction from Article 21 the right to life extended to include a clean and healthy environment and Article 32’s writ jurisdiction, amplified through three decades of the Godavarman continuing mandamus.
When a state executive refuses to comply with a Supreme Court direction, the court’s primary enforcement tool is contempt jurisdiction under Article 129. The threat to jail a Chief Secretary is not unprecedented in 2023, the Calcutta High Court ordered the suspension of the Chief Secretary of Andaman and Nicobar Islands for violating judicial directions. However, no state Chief Secretary has yet been jailed in an environmental case. The threat thus far has remained a threat.
The comparative record is instructive. In the Vedanta Niyamgiri case, the Supreme Court’s intervention succeeded because it anchored itself to local democratic assertion referring the decision to Gram Sabhas, which voted unanimously against mining. In the Aravalli encroachment cases, compliance was enforced through physical demolition orders, which created immediate visible consequences. Saranda requires something different: a long-term, positive administrative action from a government that has demonstrated across six years and multiple hearings that it will delay for as long as the legal system permits.
The Ecology Cannot Wait
The cost of this delay is not abstract. Between 2000 and 2020, Jharkhand lost nearly 8,000 hectares of forest cover, with West Singhbhum among the worst-affected districts. The Singhbhum Elephant Reserve, established in 2001 with Saranda as its core, has seen traditional migration corridors to Odisha and Chhattisgarh severed by open-cast mining and mineral transport infrastructure. Between 2000 and 2023, elephants killed more than 1,300 people in Jharkhand a figure that reflects not aggression but displacement. Perennial streams are increasingly choked with iron oxide siltation, threatening water security for communities that depend on the forest’s hydrological function.
The precautionary principle in environmental law holds that lack of full scientific certainty is not justification for postponing preventive measures. In Saranda there is no scientific uncertainty the forest is degrading and the corridors are fragmenting. The window for statutory protection is closing.
The Structural Gap That Enables This
The Wildlife Protection Act, as amended in 2022 rationalised schedules and established a National Wildlife Conservation Authority. What it failed to do was introduce mandatory timelines for sanctuary notifications. Currently no statutory limit exists on the time that can elapse between a government declaring its “intention” to notify a sanctuary and the actual notification. This gap is what has allowed Saranda to remain in regulatory limbo since 2000. It is also what will allow the next Saranda to exist, unless Parliament acts.
A co-management model modelled on the Biligiri Rangaswamy Temple Wildlife Sanctuary in Karnataka, where the Soliga tribe’s community forest rights were formally recognised across 60 percent of the reserve including core areas offers a path that does not require choosing between conservation and tribal rights. The Jharkhand government’s claim that these are mutually exclusive is contradicted by documented precedent from within India.
There is a review petition pending. There will likely be more hearings, more orders, more deadlines. The court has done what courts can do. It has stated the law clearly, rejected the state’s boundary manipulations, warned of contempt and summoned the state’s senior-most bureaucrat. What it cannot do is issue the notification itself. That requires the Jharkhand government to stop treating a Supreme Court order as the opening move in a negotiation. Asia’s largest Sal forest cannot afford to wait for that realisation to arrive.
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