The Supreme Court’s order banning tourism in Critical Tiger Habitats is perhaps necessary to shake governments out of their apathy and indolence.
Tiger Tourism, Tadoba :: More, more, we're still not satisfied.
On 24 July, the Supreme Court passed an order which, according to almost every newspaper, banned tourism in the core areas of the country’s tiger reserves. The eco-tourism versus inviolate-areas debate is already sharply polarized; the reactions to the news were, therefore, predictably vociferous. Few bothered to read the fine print.
The court’s order is not a permanent ban. It is clearly limited in time “till final directions” are issued, and the case is listed but a few weeks from now, on 22 August; and it is limited to those wildlife reserves where buffer zones have not yet been notified although the law — and previous orders of the Supreme Court — require this. Most commentators have also overlooked why the Supreme Court felt compelled to make this order. At stake was not only the protection of tigers and their habitats, but something far more serious.
On 3 April 2012, the Supreme Court noticed that despite earlier directions, as many as nine state governments had not notified the core and buffer areas of their tiger reserves under the Wildlife Protection Act. The court allowed them time to do so. The states continued to drag their feet. On 10 July 2012, the Supreme Court gave them another chance. Only two (Rajasthan and Uttar Pradesh) complied. Two more (Jharkhaand and Arunachal) said they had their notifications ready and would soon place these before the court. Others, the Supreme Court noted on 24 July, had “not even made an attempt to issue [the] notifications”. The Supreme Court fined the defaulting states and noted that continued compliance failure would result in contempt proceedings.
This is serious. Is it even open to a government to simply ignore an order of the Supreme Court like this? Which is less harmful, a temporary ban on tourism in core areas or not having core areas at all because a state government is too lethargic or too inefficient or too corrupt? The tourism industry should direct its ire at the state governments not the Supreme Court. The end-of-the-world-is-nigh moaning by resort owners and hoteliers is misplaced, as are, too, their claims that this order will affect their operations in the forthcoming October to February season and in perpetuity thereafter. Things might change as soon as 22 August when the Supreme Court hears the matter again; and till then, in the monsoon (or what seems to be passing for it), all tiger reserves are closed anyway.
The Union Government and the National Tiger Conservation Authority (NTCA) issued eco-tourism guidelines in June 2011. These are said to be have been finalised on 9 July 2012 (the Environment Ministry’s website still does not have the final guidelines). The guidelines recognize protected areas, the delineation of ecotourism zones, relocation of villages and habitation and keeping certain core areas free of tourism. The state governments are yet to respond to these, and the court has asked for their comments.
When do our state governments propose to wake up? The 1500 sq kms of Melghat, originally the flagship of Project Tiger, has been under threat for nearly two decades, ever since some politician decided to knock off a third of its area for “development” (Melghat’s forests are predominantly teak). That might have succeeded but for the intervention of the High Court and an environmental group. And there’s Tadoba, claimed to be the “real” home of the tiger. It does have tigers in teeming abundance. It also has extraordinarily misbehaved and uncontrolled tiger tourists. The fatal hit-and-run killing of a tigress with newborn cubs in Bandhavgarh in 2010 only emphasizes the problem.
The issue is not, therefore, whether tiger tourism helps tiger conservation, but one of getting a state government to follow the orders of the Supreme Court and to act as the law requires these governments to act. To those who have been screaming about what a disaster this order is: high time we got an order like this. If this is what it takes to get a state government to follow the Supreme Court’s orders and to do what is desperately needed — to notify core and buffer areas — then so be it.
The tiger tourism versus tiger conservation issue is much trickier. There are those who claim that tiger tourism has not harmed tigers; that tiger populations have increased in the most touristed areas; and that poachers, like tigers, do not wait on tourists; that orders like this have a tendency to continue. Conservationists, too, are alarmed for they are likely to be shut out from the core areas where they work; and indeed their work is both vital and valuable. They argue, too, that there are indigenous forest dwellers within these areas and their lives and livelihoods should not be allowed to be stripped. Predictably, the most vociferous proponents of tiger tourism are those who have some stake in the industry as tour operators or hoteliers.
The other side of the debate, often seen as extreme, is that in our situation, the only way to protect our core areas is to declare them off-limits to all human activity: leave the tigers and forests alone. They point out that the so-called benefits to local people from tiger tourism are hypothetical; few get meaningful jobs. Also, our core areas are unlike the vast game reserves of Africa where population densities are relatively lower, and where a single family or enterprise may own and protect thousands of hectares of untouched nature. Here, the pressure of human habitation makes the protection of fragile ecosystems and habitats an impossible business.
With some luck, the Supreme Court will never need to get into it. In an interview with the New York Times, the petitioner before the Supreme Court, Mr Ajay Dubey, himself did not oppose tourism. “It should be under certain rules and regulations,” he said. He also seeks the implementation of the law as it stands: that the core areas of critical tiger habitats of National Parks and sanctuaries be kept “inviolate”, i.e., free of human activity.
The Supreme Court’s order goes no further than this.1 To claim that it has created some new prohibitory law, and one that will inure in perpetuity, is a myth. And like all myths, this one too is based on obfuscation.
II
Opinions are sharply cleaved on whether we should have tiger tourism in core areas, protected areas (PAs) and Critical Tiger Habitats (CTHs), and even a cursory look at the printed material can be overwhelming. There are scholarly articles by field researchers, newspaper opinion pieces by journalists and columnists, blogs by environmental foundations and strident cries from the tourism corner.
A good starting point is the 2010 article by Krithi K. Karanth and Ruth Defries, Nature-based tourism in Indian protected areas: new challenges for park management.2 Based on extensive field work and interviews around ten PAs, Karanth and Defries found not only an increase in the tourism growth rates, but that 80% were domestic tourists. 72% of the tourist facilities surveyed are recent constructions; 85% are within a 5 km radius of PAs. Rules for entry are inconsistent; and there exist severe pressures for livelihood from local populations. They note that tourist facilities contribute only marginally to local employment — less than 0.001% of the population that lives within 10 kms of these PAs. This is of some consequence because other reports indicate that indigenous people have become the latest crutch of the ecotourism industry. Equally important, they note that “generally revenues [from tourism] are not a large source of conservation funds”, also contrary to another popular claim from the tourism sector. All PAs, they say, urgently need “enforcement and establishment of clear guidelines to govern tourists, vehicles and the use of water, food and other resources by tourist facilities”.
Other writers are more concerned with the impact on local populations on heavy-handed park and protected area management. In the context of Gir, Amita Shah (2007) argues that where PAs are surrounded by large habitations, including in reserve limits, management of these areas demands that livelihood needs of local communities be addressed too.3Shahabuddin, Kumar and Shrivastava (2007) are even more scathing in their analysis of the “inequitable and top-down approach, lacking scientific, historical and socio-economic considerations” that are said to have governed Sariska’s game park management.4Banerjee (2010), too, urges that ecotourism must be integrated into a “broader array of sustainable livelihoods” to encourage local communities to support conservation.5
In the pages of the venerable Economic & Political Weekly, storms rage and anger on both sides of the divide is barely concealed. Taghioff and Menon’s analysis (2010) of the consequences of the declaration of the Mudumalai Sanctuary in Tamil Nadu as a tiger reserve suggested that the very creation of these PAs failed the due process of law, was undemocratic and over-simplified very complex issues; and that the tiger is not necessarily a good keystone species for a “healthy” forest. From the present perspective, they advocate a layered set of of “near-inviolate” zones in core areas and “coexistence in buffer zone areas”.6 They also call into question the adivasi-only slant to the implementation of the Forest Rights Act.7Tarsh Thekaekara of the Shola Trust responded to Taghioff and Menon a few months later.8 Thekaekara also says this:
“To date, no buffer zone has been created in Mudumalai, and it is only the core zone or critical tiger habitat (321 square kilometres) that has been declared. Both buffer and core zones are dealt with exclusively in the WLPA. The forest department and people living inside, ie, the Mudumalai panchayat, were the stakeholders in this. A consultation with the panchayat was held, and the Moundaden Chettys, having spent 10 years asking to be moved away from their pachyderm neighbours, were happy to give their written consent to both the declaration of the tiger reserve and the relocation package. The core zone was then declared.”
Leaving aside the minutiae and technicalities of this debate (Taghioff and Menon responded a short while later),9 Thekaekara’s observation appears to highlight the effectiveness of local community involvement even in the creation of CTHs.10
Buried in this is another debate, one that seems to me to be tangential at least in the current context: whether large carnivores are appropriate keystone or umbrella species for biodiversity conservation.11 The “keystone species” formulation goes back to Robert Paine in 1969,12 and has been much debated since. K Ulas Karanth, one of our foremost conservationists, argues that the tiger is just such a species: one that “exerts an influence on the associated assemblage, often including numerous indirect effects, out of proportion to the keystone’s abundance or biomass”. Karanth describes tigers as a “warning lamp that indicates how healthy natural landscapes continue to remain in the face of our onslaught”, and uses an old metaphor that compares species extinction with the removal of rivets in an airplane: you do not know which rivet being removed will cause the plane to crash.13 Karanth argument that tigers need forests — meaning, presumably, that they need pristine forests to breed (though there’s evidence they may survive elsewhere) — seems unexceptionable; but the reverse, as Taghioff and Menon point out, may not be true.14
Surely this is irrelevant, and surely Karanth is right in his approach even if some of his arguments are not immediately appealing? We should test the criticism of Karanth by examining the reverse; the “or else what?” ideation. Can it be seriously suggested that in the interests of a nebulous and unformed concept of biodiversity conservation, one should ignore the very real threat to tiger survival? Why should we bother protecting tigers at all when there are so many other urgent human problems? In fact, this is the starting point of Karanth’s thesis, and Taghioff and Menon are merciless in their critique of it. But even they acknowledge that tigers are “intrinsically important” and need “inviolate zones”, provided that the creation of these zones is based on watertight arguments. It is hard to disagree with this formulation.
“According to Matthews (2009, p50), the presence of visitors offers four important benefits to tiger conservation. First they offer an “informal monitoring and anti-poaching programme”. Second, tourism helps to raise the status of a park thus increasing its ability to attract both international and government funding. Third, it “enhances the motivation and quality of a park’s rangers and management”. It also makes forest department personnel highly accountable and finally the economic benefit that tourism creates allows the forest reserve, and its wildlife to be valued as “a living ecosystem”.
There seems, here, to be a singular detachment from reality. Who is this universal tiger tourist who goes around informally monitoring tigers and spotting poachers? There is absolutely no evidence of any tourist finding a poacher — and poachers, like tigers, do not wait for tourists to trundle past. The two species also keep very different business hours and the prospect of a herd of tourists chasing down a poaching is extremely dim.
Tiger Tourism, Tadoba :: Tiger-spotting and tourist-dodging. How is this even fair?
But there is ample anecdotal evidence of tourist misbehaviour: private cars being allowed entry and crashing over firelines, getting dangerously close to the big cats; people in clothes so bright they would make Lord Surya reach for his Raybans; even pot-bellied heroes in too-tight tee-shirts jumping out of vehicles to call to a tigress (Bandhavgarh, 2010). What’s a tiger, after all, but a pussy cat on steroids? And the tigress who was hit by a speeding car after-hours in Bandavgarh in 2010 was not the victim of poaching but of illicit tourism of the VVIP variety. In Tadoba in February this year, a local BJP bigwig arrived with her entourage and demanded to be let in after hours. A tiger cannot change its stripes; neither, it seems, can our VIPs. Again, in Tadoba, a hapless forest guard on foot, with nothing but a short stick, complains to a naturalist that he is helpless in the face of all these people whizzing around in their jeeps and MUVs with their foot-long bandook camera lenses.
Not one voice from tourism tells us how to manage, control or penalize this cretinous conduct. Not one game reserve has provision for, or enforcement of, penalties against misbehaving tourists. Drivers and guides expect tips; tips depend on tiger-spotting; and the result has been, till recently and only in a few reserves, traffic jams and vehicle chaos that make rush-hour Mumbai look pleasant. In Bandhavgarh, a tour operator violates the vehicle-entry restriction and sends in over-quota jeeps. They are stopped, but only at the exit, and when action is proposed, the expected happens: threats against park officials and the invocation of powerful influences.
The pro-tourism lobby has equally sharp-witted advocates, and some are suitably cautious. Chris Weston, who has travelled widely in India’s reserve as the principal photographer for Animals on the Edge, says that banning tourism will not save our tigers. He agrees, however, that tourism is adversely affecting wildlife in reserves. But, he says, banning it as “an isolated action” is not an effective answer, simply because poaching is the greater threat. Banning tourism is no assurance against extinction; but the tourist industry and international conservation groups “have failed to provide any solutions of their own. In the past ten years, despite donations to tiger conservation projects totalling over $41 million and the hundreds of millions of dollars earned in tourist revenue, India’s tiger population has more than halved and their numbers continue to decline at an alarming rate”.
But this poachers-vs-tourists is a straw man argument. Nobody is suggesting that we should ban tourists and encourage poachers. Poaching is a crime, and can be dealt with accordingly, even with extreme measures; tourism cannot. Their effects and impacts are also different. The sheer volumes of tourists (give number) are an enormous load on forests and tiger habitats. Masses of vehicles line up as a tiger is about to cross a road. Some block the road. The tiger is forced to retreat or find a way around. This is precisely what should not be happening.
“Business in Khatia village on the border of Kanha National Park in Madhya Pradesh starts as early as 2.30 am. Tour operators crowd the yet-to-open ticket counter at the entry gate. Gypsies carrying drowsy tourists start queuing up, jostling to be ahead of each other. Restaurants and shops open to serve the tourists. As soon as dawn breaks, Khatia resembles a crowded marketplace. All this is to ensure that tourists do not return disappointed. They must see a tiger.”
In four years, the number of tourists in Kanha went up by 60%. The number of hotels more than doubled. Most are in close proximity to the reserve’s perimeter and they restrict wildlife access to the river and have encroached into the wildlife corridor between Kanha and Pench, a virtually contiguous stretch of dense forest. Nobody bothers with carrying-capacity studies. Kanha allows 280 vehicles a day. The NTCA pegs the sustainable limit at no more than 55. Hotels have inappropriate facilities — infinity pools in water-starved areas and air-conditioning. They also put intolerable demands on the area and natural resources, chiefly water. In 2009, Down to Earth reports, 48 resorts in Kanha drew 540,000 litres of groundwater per day. They also consumed 302 tonnes of firewood, including for wood-fired boilers, and over 40% of this wood came from the forests of the buffer zone. State governments do not want restrictions on tiger tourism: it is a huge money-spinner. Corbett, close to Delhi, is perhaps even worse off: in 2012, it saw 2.1 million tourists (and earned Rs.70 million in revenue).
Finally, there’s the outcry from conservationists who also ask for regulation, not bans, and question how GenNext conservationists will rise. They should read the order more closely. It bans tourism, not conservation; but the fear, of course, is that every government, in typically ham-fisted fashion, will label everyone not in khaki a ‘tourist’. That lack of intelligence will be the government’s; it has nothing to do with the Supreme Court’s order. And, in any case, it is always possible to allow a conservationist into a core area — provided he has some credentials other than those three lovely letters, VIP. It’s not unlike trying to get into America or England: off-limits unless you have a visa.
Of course tour operators and hoteliers are dejected. They should be; this is as much a problem of their own making as the state governments’. Let’s not delude ourselves: hotels are in business to make profits, not to dispense charity to local populations; and the evidence of tourism’s “aid” to local populations ranges from thin to non-existent. The secondary argument, that tiger populations have increased where there is tourism, is the classic post hoc ergo propter hoc fallacy: no one has yet scientifically established any causality between more tourists and more tigers.
The governments’ and tourism industry’s cries for regulation and for more nuanced approach is too little too late. Governments have done very little in this direction. Also, if the Supreme Court was to ask state governments and tourism stakeholders to suggest more moderate measures, how long would that take? There seems very little doubt that any such suggestion would be met first with opposition, then with repeated attempts at watering down regulations and finally with a blithe ignoring of court orders: plus ca change. The more it changes, the more it remains the same; and we have seen this far too often already. When more “sympathetic” attempts have failed, a more extreme approach like this is perhaps just what is need to shake governments out of indifference, apathy and outright defiance.
We can arrest poachers, try them, jail them. But what is to be done with a miscreant tourist? Even one is a menace, and if he jeopardizes the interests of his other, better-behaved, confreres, so be it. Till such time as we have clearly defined guidelines for tourists — including mandatory thou-shalt-not presentations before entering the park, plus powers to park officials to summarily evict and ban individual tourists for misconduct — and our governments see that they have no choice in the matter, our critical tiger habitats are perhaps best kept off-limits.
Losing tigers to poachers and being unable to stop it is a national shame. An even greater shame is that merciless and punitive action seems to be the only language our governments understand.
Dhananjay Mahapatra, Times of India, 22 August 2012
NEW DELHI: A month after the Supreme Court relied on the government’s guidelines to ban tourism in core areas of tiger reserves, making popular destinations like Corbett National Park out of bounds for wildlife enthusiasts, the ministry of environment and forests (MoEF) on Tuesday did an about turn, telling the court that it needed to re-think the guidelines.
The SC’s July 24 order banning tourism in core areas had led to loud protests from states and thriving commercial ventures in and around tiger reserves. The ministry, which had gone to great lengths to finalize the detailed guidelines, appears to have wilted under political and commercial pressure and sought time from the court to review its “finalized” guidelines.
On July 9, MoEF filed the ‘Guidelines for Ecotourism in and around Protected Areas’ in the apex court and said, “Any core area in tiger reserve from which relocation has been carried out will not be used for tourism activities.” …read more
NEW DELHI: Data from a published research shows that less than 0.001% people living in vicinity of tiger reserves are employed in resort and tourism business, and even those who are engaged have low-paying jobs like gardening and housekeeping.
The study has been quoted by one of the petitioners in the ongoing case — on imposing a ban on tourism in the core of tiger reserves — in the Supreme Court.
The findings are the results of a study published by Krithi K Karanth of the Centre for Wildlife Studies, India, and Ruth DeFries of Columbia University, USA.
The study of nature-based tourism in India was carried out on resorts and homestays within 25km of 10 selected national parks and sanctuaries. It has found that tourist facilities provided little direct incomes to people living around the parks and is ‘rarely directed towards improving conservation efforts or supporting local people.’ …read more
by Dhananjay Mahapatra, Times of India, 23 August 2012
NEW DELHI: Upset with the Union government’s U-turn on banning tourism in core areas of tiger reserves, the Supreme Court on Wednesday said the Centre appeared more concerned about commercial activity than protecting tigers.
It mocked the Centre’s crude attempt to wriggle out of its month-old stand and said the July 24 interim order banning tourism in core areas would stay till the government came out with a clear stand on protecting tigers and notifying the core and buffer areas.
A bench of Justices A K Patnaik and Swatanter Kumar came down heavily on the Centre after counsel Wasim A Qadri sought time for the government to review what it had on July 9 termed as finalized ‘Guidelines for Ecotourism in and around Protected Areas’.
…
Times View
An all-or-nothing approach to tourism in the core areas of tiger reserves is likely to be counter-productive. There is certainly merit in the argument that unrestricted commercialisation threatens the habitat of the tiger as of other wildlife. It does not, however, follow logically from that there should be commercial activity at all. If all tourists and locals are kept out of the core areas, it could aid rather than hinder poachers and those forest officers who are willing to collude with them. The answer, therefore, lies in allowing limited commercial activity under strictly supervised conditions. This creates a larger pool of stakeholders for the project to save the tiger and that can only be good news. …read more
The most visible mammals in India’s Sariska Tiger Reserve on Friday were not tigers but monkeys, stray dogs, and people — hundreds of pilgrims walking through the monsoon rain towards a Hindu shrine inside the park.
Sariska, in Rajasthan, is crossed by several roads and was once a byword for the failure of India’s efforts to conserve its remaining tigers. By 2005, after years of mismanagement, human population growth and poaching by villagers in and around the reserve, not a single tiger survived here. …read more
by ULLAS KARANTH | OUTLOOK INDIA | 25 August–3 September 2012
Tourism can increase its natural capital by converting farms to wildlife viewing land, with shared profits.
The media splash—exemplified by a hyper-ventilating Guardian report following the Supreme Court’s July 2012 interim order suspending tourism in some tiger reserves—has convinced the public that all wildlife tourism activity in India stands permanently abolished. Following the August 22 ruling on a review petition by the SC, in which it extended its ban on tourism in the ‘core areas’ of tiger reserves, people might think such a shutdown portends a disastrous collapse of public support to tiger conservation. These are exaggerations arising out of a flawed reading.
Wildlife tourism has been temporarily halted only in tiger reserves, that too only in states that have not notified ‘buffer zones’ mandated by law. Tourism is going on unhindered at all other wildlife reserves, including tiger reserves where buffer zones have been notified. The intent of the court’s order appears to be to compel remaining states to create buffers around already notified core areas or ‘critical tiger habitats’, with the suspension of tourism as a threat. The issue, as it has been framed by the court, will hopefully renew focus on the flawed boundaries of some of these critical tiger habitats, for both scientific and practical reasons. …read more
The Supreme Court will hear on August 29 an application from the head of an NGO, Ajay Dubey, for a direction to restrain the Chief Minister, Cabinet Ministers and senior officers of Madhya Pradesh from giving public statements criticising the order banning tourist activities in core areas of tiger reserves.
A Bench of Justices A.K. Patnaik and Swatanter Kumar has also agreed to hear the Centre’s plea to review the ban order. Several States, NGOs and interested parties filed applications seeking review of the order.
Acting on Mr. Dubey’s petition, the Supreme Court, by an interim order on July 24, had said: “Till the final directions issued by this court with reference to the guidelines submitted by the National Tiger Conservation Authority, the core zone or core areas in the Tiger Reserve Areas will not be used for tourism.” This order was extended till August 29.
In the present application, Mr. Dubey said that after the interim directions were passed, the core areas in tiger reserves of Madhya Pradesh were closed for tourists. However, from the very next day, various Cabinet Ministers, in particular Chief Minister Shivraj Singh Chouhan, were openly criticising the interim directions through public statements and on public platforms. …read more
New Delhi : Extending the ban on tourism in core tiger reserve areas till September 27, the Supreme Court on Wednesday indicated it was not averse to permit regulated tourist activities, subject to the Centre evolving suitable revised guidelines to protect the depleting wild cat.
A Bench of justices A K Patnaik and Swatanter Kumar granted four weeks to the Centre to evolve the fresh guidelines after consultations with states, all stakeholders, hotel associations affected by the ban, guides and tour operators.
On July 24 the apex court had banned all tourism activities in the core tiger reserve areas.
“There is always a watch when tourism is allowed. If there is no tourism there will be no human to watch the tigers. Poachers will immediately be caught by tourists and the guides. Poachers actually work undercover. If no tourists are allowed, it will be a field day for poachers,” the Bench told Attorney General G E Vahanvati, who agreed with the observations.
The Bench asked the AG to ensure regulated tourism as hundreds of vehicles are trooping in and out of the core areas.
Tourists can hope to see tigers in their natural habitat once again as the Supreme Court Wednesday softened stand, saying it wasn’t averse to “regulated tourism” in the core areas of reserves.
“It’s the raised construction inside core areas and not tourists who harm tigers. Is it necessary that 100 vehicles go inside at a time? It (tourism) needs a proper regulation,” a bench of justice AK Patnaik and justice Swatanter Kumar said Wednesday.
However, the court’s ban — ordered on July 24 and extended on August 29 — on tourist activities will remain in place till September 27, when the case comes up next. The court is hearing a petition on tiger conservation. …read more
Taghioff, Daniel & Ajit Menon: “On Mudumalai Tiger Reserve”, Economic & Political Weekly, Vol.45 No.52, December 25, 2010, p. 83. Online link requires subscription. ↩
Incidentally, this is the subject of an different but connected debate, on the FRA, and whether local communities should have “rights” over forests. A 2011 editorial by Praveen Bhargav and Shekar Dattatri in the EPW arguing against the continuance of local communities in PAs and CTHs met with outrage: a long letter to the editor (one of the signatories was Taghioff) and an even longer full-fledged article in response. ↩
Both Thaekara and Taghioff-Menon address this in their respective articles; id. ↩
Refined in 1995. See: Paine, Robert (1995): “A Conversation on Refining the Concept of Keystone Species”, Conservation Biology, 9(4):962-64 ↩
Karanth, K Ullas (2003): The Way of the Tiger: Natural History and Conservation of the Endangered Big Cat, Voyageur Press, New Delhi ↩
Little of this material regarding large carnivores seems to be in the context of India. Thekaekara’s EPW article has extensive references. ↩
On 24 July, the Supreme Court passed an order which, according to almost every newspaper, [banned tourism in the core areas of the country's tiger reserves][1]. The eco-tourism versus inviolate-areas debate is already sharply polarized; the reactions to the news were, therefore, predictably vociferous. Few bothered to read the fine print.
[1]: http://courtnic.nic.in/supremecourt/temp/sc%202133911p.txt "Ajay Dubey v National Tiger Conservation Authority and Others, SLP (C) No 21339 of 2011, order dated 24 July 2012"
