'Every Day, a Foolhardy Proposal to Shrink Forests': Ex-Civil Servants on Development in Eco-Sensitive Areas

New Delhi: A group of 77 former civil servants who have worked with the central and state governments in the past have raised concerns regarding the large-scale, state-driven deforestation for various developmental projects, particularly highlighting the cutting down of nearly a million trees in the Great Nicobar island, along with deforestation of crucial green hubs in Assam and Delhi.

‘We are deeply dismayed at the recent reports of large scale, state driven deforestation due to diversion of forestlands for developmental projects,” the ex-civil servants, under the banner of Constitutional Conduct Group (CCG), said in an open letter.

The rise in deforestation, they noted, is most evident in the ecologically sensitive Himalayan and North Eastern states, such as Sikkim, Arunachal Pradesh, Himachal Pradesh, among others. “...the most appalling of them being the cutting down of nearly a million trees, over 13000 hectares of rainforest in Great Nicobar island.” 

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They said that the compensatory afforestation expected to be undertaken for such a diversion of forest areas is “either not undertaken or if undertaken is almost never successful”. “The proposals are also, often, ludicrous, e.g. taking up compensatory afforestation for the rainforests of Great Nicobar in dry Haryana, 4500 km away,” CCG stated.

The group pointed out that several such lands within national parks and wildlife sanctuaries, which are classified as ‘Protected Areas (PAs)’, along with their ESZs, are being diverted at an alarming pace. Such projects require the approval of the Standing Committee of the National Board of Wildlife (SC-NBWL) – a statutory body tasked with promotion, conservation and development of wildlife and their habitats. 

They highlighted the Assam government’s proposal to reduce the Eco-Sensitve Zone (ESZ) of the Kaziranga National Park from 10 ms kilometres to one kilometre, to make space for hotels, which is bound to adversely impact the endangered rhinoceros population. 

Further, in the national capital of Delhi, the proposal to use 12.6 hectares of the Delhi Ridge for the President's Bodyguard parade ground, if implemented, will fragment the already degraded ridge which serves as a “green lung” for the metropolis, they noted.

‘100 plus diversion proposals cleared every meeting’

The CCG said that despite concerns raised time and again over these deforestation efforts, “97% of the diversion proposals placed before the SC-NBWL since 2014 have been cleared,” adding that in just four meetings held in 2024 and 2025, nearly 5824 hectares of land inside PAs and ESZs have been cleared for non-forest use with “as many as 100 plus proposals getting cleared in almost every meeting”. 

The diversions were being permitted for projects like industrial parks, quarrying, mobile towers, tunnels, oil refineries, railway lines, synthetic organic chemical manufacturing unit, petrochemical park, temples, helipads, mining, hotels, apartment complexes, oil drilling, etc. – all of which in no way benefit wildlife and their habitats. 

They also expressed concern over the rise in developmental clearances in Protected Areas every passing year: from 91 projects cleared in 2019, to 378 in 2024, and 312 in 2025.

“The implementation of infrastructure development, mining, etc. through diversion of forests and Protected Areas, has been possible due to the weakening of environment and conservation laws by the government as well as through judicial rulings,” they said, pointing at the Van (Sanrakshan Evam Samvardhan) Adhiniyam or the Forest Conservation (Amendment) Act, 2023, under which the Ministry of Environment, Forest and Climate Change has allowed huge tracts of forested land to be left out from legal protection and allows easy diversion of such lands.

Also read: Conservationists Decry National Board for Wildlife, Court Gives Govt 4 Weeks to Reply

In two years since the amendment, 2024-25 and 2025-26, approximately 22,562 hectares of forestland per year has been approved for diversion, for non-forestry purposes, as compared to an average of 19,223 hectares per year from 2019-2024, and 14,941 hectares per year from 2014-2019.

The wildlife standing committee, they said, “seems to have no hesitation in approving almost all the diversion proposals placed before it”, given that in the past decade more than 30 wildlife sanctuaries and National Parks have been de-notified or drastically reduced in area to enable easy diversions of their land for “developmental” projects, including the Megapode Wildlife Sanctuary as well as the Galathea Bay Wildlife Sanctuary in Great Nicobar, despite the latter being India’s most important and the northern Indian Ocean’s largest nesting site for endangered giant leatherback turtles.

A Supreme Court ruling

The CCG also condemned the Supreme Court’s role, mentioning how a July ruling further allowed the Union government to regularise violations under Section 3 of the Environment (Protection) Act, 1986, by effectively replacing the ’precautionary principle’ (preventing harm) while dealing with India’s environment with a "pollute and pay" model.  

“Entrepreneurs can construct big-ticket projects without taking any of the mandatory prior clearances, present the government with a fait accompli and simply pay compensation to stay operational,” they noted.

Expressing disappointment, they said, “Every day brings a new, foolhardy proposal to reduce forested and wildlife protected areas.”

Terming the idea of India’s growth through the push for development of roads, infrastructure, mines “misguided”, the CCG said that there was “no realisation” that an unpolluted environment together with extensive forest cover and thriving wildlife is “even more important for human well-being”. 

Acknowledging that infrastructure development projects are necessary for the country, they demanded that it should not come at the cost of ecological security. 

Such a prioritisation is against all aspects of the “precautionary principle” and “intergeneration equity” enunciated by the Supreme Court, as well as being in contravention of Articles 48 A and 51 A of the Constitution and most importantly of Article 21, the Right to Life, they said and urged the government and the judiciary to prioritise the ecological security and the health and life of its citizens over the false narrative roads, buildings, mines, industries, with more destruction of the natural world, that is currently seen as progress. 

Signatories to the CCG letter:

1. Anand Arni | RAS (Retd.) | Former Special Secretary, Cabinet Secretariat, GoI
2. Aruna Bagchee | IAS (Retd.) | Former Joint Secretary, Ministry of Mines, GoI
3. Sandeep Bagchee | IAS (Retd.) | Former Principal Secretary, Govt. of Maharashtra
4. J.L. Bajaj | IAS (Retd.) | Former Chairman, Administrative Reforms and Decentralisation Commission, Govt. of Uttar Pradesh
5. G. Balachandhran | IAS (Retd.) | Former Additional Chief Secretary, Govt. of West Bengal
6. Vappala Balachandran | IPS (Retd.) | Former Special Secretary, Cabinet Secretariat, GoI
7. Chandrashekar Balakrishnan | IAS (Retd.) | Former Secretary, Coal, GoI
8. Rana Banerji | RAS (Retd.) | Former Special Secretary, Cabinet Secretariat, GoI
9. Sharad Behar | IAS (Retd.) | Former Chief Secretary, Govt. of Madhya Pradesh
10. Madhu Bhaduri | IFS (Retd.) | Former Ambassador to Portugal
11. Pradip Bhattacharya | IAS (Retd.) | Former Additional Chief Secretary, Development & Planning and Administrative Training Institute, Govt. of West Bengal
12. Nutan Guha Biswas | IAS (Retd.) | Former Member, Police Complaints Authority, Govt. of NCT of Delhi
13. Meeran C Borwankar | IPS (Retd.) | Former DGP, Bureau of Police Research and Development, GoI
14. Ravi Budhiraja | IAS (Retd.) | Former Chairman, Jawaharlal Nehru Port Trust, GoI
15. R. Chandramohan | IAS (Retd.) | Former Principal Secretary, Transport and Urban Development, Govt. of NCT of Delhi
16. Rachel Chatterjee | IAS (Retd.) | Former Special Chief Secretary, Agriculture, Govt. of Andhra Pradesh
17. F.T.R. Colaso | IPS (Retd.) | Former Director General of Police, Govt. of Karnataka & former Director General of Police, Govt. of Jammu & Kashmir
18. Anna Dani | IAS (Retd.) | Former Additional Chief Secretary, Govt. of Maharashtra
19. Vibha Puri Das | IAS (Retd.) | Former Secretary, Ministry of Tribal Affairs, GoI
20. Nitin Desai | | Former Chief Economic Adviser, Ministry of Finance, GoI
21. M.G. Devasahayam | IAS (Retd.) | Former Secretary, Govt. of Haryana
22. Sushil Dubey | IFS (Retd.) | Former Ambassador to Sweden
23. Suresh K. Goel | IFS (Retd.) | Former Director General, Indian Council of Cultural Relations, GoI
24. Meena Gupta | IAS (Retd.) | Former Secretary, Ministry of Environment & Forests, GoI
25. Wajahat Habibullah | IAS (Retd.) | Former Secretary, GoI and former Chief Information Commissioner
26. Siraj Hussain | IAS (Retd.) | Former Secretary, Department of Agriculture, GoI
27. Syed Masood Husain | IES (Retd.) | Former Chairman, Central Water Commission & ex officio Secretary, Ministry of Jal Shakti, GoI
28. Sanjay Kaul | IAS (Retd.) | Former Principal Secretary, Govt. of Karnataka
29. Naini Jeyaseelan | IAS (Retd.) | Former Secretary, Inter-State Council, GoI
30. Najeeb Jung | IAS (Retd.) | Former Lieutenant Governor, Delhi
31. Sudhir Kumar | IAS (Retd.) | Former Member, Central Administrative Tribunal
32. Aloke B. Lal | IPS (Retd.) | Former Director General (Prosecution), Govt. of Uttarakhand
33. Subodh Lal | IPoS (Resigned) | Former Deputy Director General, Ministry of Communications, GoI
34. Harsh Mander | IAS (Retd.) | Govt. of Madhya Pradesh
35. Amitabh Mathur | IPS (Retd.) | Former Special Secretary, Cabinet Secretariat, GoI
36. Aditi Mehta | IAS (Retd.) | Former Additional Chief Secretary, Govt. of Rajasthan
37. Malay Mishra | IFS (Retd.) | Former Ambassador to Hungary
38. Satya Narayan Mohanty | IAS (Retd.) | Former Secretary General, National Human Rights Commission
39. Jayashree Mukherjee | IAS (Retd.) | Former Additional Chief Secretary, Govt. of Maharashtra
40. Ruchira Mukerjee | IP&TAFS (Retd.) | Former Advisor (Finance), Telecom Commission, GoI
41. Anup Mukerji | IAS (Retd.) | Former Chief Secretary, Govt. of Bihar
42. Deb Mukharji | IFS (Retd.) | Former High Commissioner to Bangladesh and former Ambassador to Nepal
43. Shiv Shankar Mukherjee | IFS (Retd.) | Former High Commissioner to the United Kingdom
44. Gautam Mukhopadhaya | IFS (Retd.) | Former Ambassador to Myanmar
45. Jugal Mohapatra | IAS (Retd.) | Former Secretary, Department of Rural Development, GoI
46. Surendra Nath | IAS (Retd.) | Former Member, Finance Commission, Govt. of Madhya Pradesh
47. P. Joy Oommen | IAS (Retd.) | Former Chief Secretary, Govt. of Chhattisgarh
48. Amitabha Pande | IAS (Retd.) | Former Secretary, Inter-State Council, GoI
49. Mira Pande | IAS (Retd.) | Former State Election Commissioner, West Bengal
50. Alok Perti | IAS (Retd.) | Former Secretary, Ministry of Coal, GoI
51. G.K. Pillai | IAS (Retd.) | Former Home Secretary, GoI
52. Smita Purushottam | IFS (Retd.) | Former Ambassador to Switzerland
53. V.P. Raja | IAS (Retd.) | Former Chairman, Maharashtra Electricity Regulatory Commission
54. V. Ramani | IAS (Retd.) | Former Director General, YASHADA, Govt. of Maharashtra
55. M. Rameshkumar | IAS (Retd.) | Former Member, Maharashtra Administrative Tribunal
56. Archana Ranjan | IRS (Retd.) | Former Director General, Central Economic Intelligence Bureau, GoI
57. Madhukumar Reddy A. | IRTS (Retd.) | Former Principal Executive Director, Railway Board, GoI
58. K. Sujatha Rao | IAS (Retd.) | Former Health Secretary, GoI
59. Satwant Reddy | IAS (Retd.) | Former Secretary, Chemicals and Petrochemicals, GoI
60. Julio Ribeiro | IPS (Retd.) | Former Director General of Police, Govt. of Punjab
61. Manabendra N. Roy | IAS (Retd.) | Former Additional Chief Secretary, Govt. of West Bengal
62. A.K. Samanta | IPS (Retd.) | Former Director General of Police (Intelligence), Govt. of West Bengal
63. Deepak Sanan | IAS (Retd.) | Former Principal Adviser (AR) to Chief Minister, Govt. of Himachal Pradesh
64. Biswaranjan Sasmal | IRS (Retd.) | Former Additional Secretary, Department of Social Justice Empowerment, GoI
65. G.V. Venugopala Sarma | IAS (Retd.) | Former Member, Board of Revenue, Govt. of Odisha
66. N.C. Saxena | IAS (Retd.) | Former Secretary, Planning Commission, GoI
67. Aftab Seth | IFS (Retd.) | Former Ambassador to Japan
68. Ashok Kumar Sharma | IFoS (Retd.) | Former MD, State Forest Development Corporation, Govt. of Gujarat
69. Ashok Kumar Sharma | IFS (Retd.) | Former Ambassador to Finland and Estonia
70. Raju Sharma | IAS (Retd.) | Former Member, Board of Revenue, Govt. of Uttar Pradesh
71. Shivendu | IAS (Retd.) | Former Secretary, Health & Member (Finance), Jharkhand State Electricity Board, Govt. of Jharkhand
72. Avay Shukla | IAS (Retd.) | Former Additional Chief Secretary (Forests & Technical Education), Govt. of Himachal Pradesh
73. Tara Ajai Singh | IAS (Retd.) | Former Additional Chief Secretary, Govt. of Karnataka
74. Mridula Sinha | IAS (Retd.) | Former Director General, Administrative Training Institute, Govt. of Jharkhand
75. Prakriti Srivastava | IFoS (Retd.) | Former Principal Chief Conservator of Forests & Special Officer, Rebuild Kerala Development Programme, Govt. of Kerala
76. Anup Thakur | IAS (Retd.) | Former Member, National Consumer Disputes Redressal Commission
77. Geetha Thoopal | IRAS (Retd.) | Former General Manager, Metro Railway, Kolkata

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