Supreme Court Directs Status Quo on Mhadei Tiger Reserve Dispute and Halts Development Activities

Shahin Akhtar

On 08th September, 2025, the Supreme Court put a hold on all development activities in Goa’s Mhadei-Kotigaon region, which the National Tiger Conservation Authority (NTCA) has earmarked as a possible tiger reserve. The bench, headed by Chief Justice of India B.R. Gavai and comprising Justices K. Vinod Chandran and Atul S. Chandurkar, said the current status should be maintained until a central empowered committee hears all stakeholders and submits its report within six weeks.

The matter reached the top court after the Goa government and others contested a Bombay High Court order that had directed the state to notify the Mhadei Wildlife Sanctuary and nearby areas as a tiger reserve within three months. The Supreme Court had earlier agreed to hear the case and had sought responses from NTCA and other parties.

The Mhadei Wildlife Sanctuary, spread over 208 square kilometers, is located in northeastern Goa and shares a border with Karnataka. The Bombay High Court’s decision was based on a petition by the NGO Goa Foundation, which had sought the implementation of NTCA’s advice to declare the area, a tiger reserve.

In its order, the High Court made a striking reference to the Mahabharata: “If there is no forest, then the tiger gets killed; if there is no tiger, then the forest gets destroyed. Hence, the tiger protects the forest and the forest guards the tiger.” As per the order, the state must prepare a detailed conservation plan for tigers under the Wildlife Protection Act and submit it to the NTCA no later than three months after notifying the reserve.

The High Court had also asked the state to set up anti-poaching camps manned by forest guards and watchers across wildlife sanctuaries and national parks. It further stressed that encroachments must be prevented in these protected areas both before and after the tiger reserve is officially notified. The NTCA, on its part, was told to provide full assistance and speed up the approval process once the state submitted its conservation plan.

With the Supreme Court’s intervention, all projects and developmental work in the Mhadei-Kotigaon area are now on hold until the empowered committee gives its recommendations.

Case Name: The State of Goa Through Chief Secretary v. The Goa Foundation

Case Number:  SLP (C)/20683/2023

Bench: Chief Justice of India B.R. Gavai, Justices K. Vinod Chandran and Atul S. Chandurkar

Click here to access the order

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