Case Note & Summary
The case involved a petition concerning the conservation of the endangered Asiatic Wild Buffalo in the Udanti Wildlife Sanctuary, Chhattisgarh. The petitioner sought directions for the preparation of a rescue plan, funding for conservation efforts, and measures to prevent interbreeding with domestic buffalo. The State of Chhattisgarh submitted an affidavit detailing its conservation efforts, but acknowledged financial constraints affecting the implementation of its management plan. The Central Empowered Committee (CEC) was directed to conduct an inquiry, leading to the formation of a task force to develop an action plan. The court noted that the steps taken by the State were inadequate and highlighted the need for a comprehensive scheme to address the conservation of wildlife, including the wild buffalo. The court emphasized the importance of the Wildlife (Protection) Act, 1972, and the constitutional duty to protect the environment. It directed the State to take immediate actions to ensure the genetic purity of the wild buffalo, conduct research, and submit an Annual Plan of Operations to the Central Government. The judgment underscored the necessity of balancing human development with wildlife conservation, advocating for ecocentric approaches to environmental protection.
Headnote
A) Environmental Law - Wildlife Conservation - State Obligations - Wildlife (Protection) Act, 1972 - The court directed the State of Chhattisgarh to fully implement the Centrally Sponsored Scheme for the Integrated Development of Wildlife Habitats to save the endangered wild buffalo from extinction, ensuring genetic purity and conducting research on the species. Held that immediate steps must be taken to protect the wild buffalo and its habitat (Paras 23-24).
Issue of Consideration
Whether the State of Chhattisgarh is fulfilling its obligations under the Wildlife (Protection) Act, 1972 to conserve the endangered wild buffalo.
Final Decision
The court directed the State of Chhattisgarh to fully implement the Centrally Sponsored Scheme for the Integrated Development of Wildlife Habitats, take immediate steps to ensure genetic purity of the wild buffalo, conduct research, and submit an Annual Plan of Operations to the Central Government within three months.
Law Points
- Wildlife conservation
- Endangered species protection
- State responsibilities
- Environmental law
- Anthropocentrism vs. ecocentrism



