In Re : T.N. Godavarman Thirumulpad vs Union Of India

insc-2025-1311 Supreme Court of India 13 November 2025 • WRIT PETITION (C) NO. 202 OF 1995 • 63 min read

9 cases cited (0 SG, 9 foreign) Cited by 1 case

Practice Areas

Constitution of India Corridors or Ecologically Sensitive Areas in accordance with the provisions of the Wild Life (Protection) Act, 1972 Forest (Conservation) Act, 1980 Forest Department Saranda Wild Life Sanctuary may be declared as per the provision of Wild Life (Protection) Act, 1972 Forest Land for Mining purpose as approved by Forest Conservation Act, 1980 Indian Forest Act, 1927 It was further contended that the protection of wildlife is mandatory under the Wildlife (Protection) Act, 1972 Notwithstanding anything contained in the Forest (Conservation) Act, 1980 Rehabilitation and Resettlement Act, 2013 Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 Wild Life (Protection) Act, 1972

Judges (2)

B.R. Gavai Delivered K. Vinod Chandran Coram

Counsel (4)

K. Parameshwar Counsel Amicus Kapil Sibal Counsel Respondent Shibani Ghosh Counsel Applicant Tushar Mehta Counsel Respondent

Parties (2)

Union of India Respondent T. N. Godavarman Thirumulpad Petitioner

Case Significance

In Re : T.N. Godavarman Thirumulpad vs Union Of India is a Supreme Court of India decision dated November 13, 2025 (citation: insc-2025-1311). Saranda Wildlife Sanctuary case involving applications regarding forest rights and mining operations by SAIL in Jharkhand. The Supreme Court held that ancillary mining activities by SAIL are permissible under the Forest Rights Act even after declaration as a Wildlife Sanctuary, and disposed of the applications accordingly. The bench comprised Justices B.R. Gavai and K. Vinod Chandran. The judgment was delivered by Justice B.R. Gavai. Counsel appearing: K. Parameshwar (amicus curiae), Kapil Sibal (counsel for respondent), Shibani Ghosh (counsel for applicant), Tushar Mehta (counsel for respondent).

This case has been cited by 1 subsequent judgment. The judgment references 9 case citations.

Summary

Saranda Wildlife Sanctuary case involving applications regarding forest rights and mining operations by SAIL in Jharkhand. The Supreme Court held that ancillary mining activities by SAIL are permissible under the Forest Rights Act even after declaration as a Wildlife Sanctuary, and disposed of the applications accordingly.

What was the outcome of In Re : T.N. Godavarman Thirumulpad vs Union Of India?

Statutes Cited

Constitution of India

Art 48A Art 51A(g)

Corridors or Ecologically Sensitive Areas in accordance with the provisions of the Wild Life (Protection) Act, 1972

Forest (Conservation) Act, 1980

Forest Department Saranda Wild Life Sanctuary may be declared as per the provision of Wild Life (Protection) Act, 1972

Forest Land for Mining purpose as approved by Forest Conservation Act, 1980

Indian Forest Act, 1927

It was further contended that the protection of wildlife is mandatory under the Wildlife (Protection) Act, 1972

Notwithstanding anything contained in the Forest (Conservation) Act, 1980

Rehabilitation and Resettlement Act, 2013

Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006

Wild Life (Protection) Act, 1972

s 18 s 19 s 24 s 26A

Cases Cited (9)

IN (9)

(1996) 5 SCC 647 (2006) 1 SCC 1 (2006) 3 SCC 549 (2013) 6 SCC 476 (2013) 8 SCC 234 (2024) 13 SCC 1 (2025) 2 SCC 641 2023 SCC OnLine SC 504 2025 INSC 1311

Cited By (1)

insc-2025-1311

In Re : T.N. Godavarman Thirumulpad vs Union Of India

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (insc-2025-1311)