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4. In compliance with the aforesaid directions given by this Court, the Central Empowered Committee has submitted a detailed report dated 6th March, 2026, running into 428 pages, along with suggested Standard Operating Procedures for translocation of the animals. For the sake of convenience, the important observations and recommendations contained in the said report are extracted hereinbelow: -

“17. For assessing the carrying capacity of the existing deer enclosure, the CEC examined the Guidelines for Establishment and Scientific Management of Zoos in India, 2008, issued by the Central Zoo Authority (CZA). It prescribes a minimum outdoor enclosure area of 1,500 sq. metres per pair of spotted deer (Axis axis), excluding areas utilised for barriers, shelters, pathways, and service infrastructure. Treating approximately 70% of the gross enclosure area as net usable open space, the existing enclosure at A.N. Jha Deer Park, measuring about 10.26 acres (41 ,500 sq. metres), provides an estimated usable area of about 29,000 sq. metres. On this basis, the enclosure can sustainably accommodate approximately 19 deer units (pairs), resulting in a scientifically assessed carrying capacity of around 38 deer. Applying the CZA-prescribed optimal sex ratio of 2 males to 3 females, the enclosure can optimally sustain approximately 15 male deer and 23 female deer.

5. In substance, the report of the Central Empowered Committee affirms the decision to translocate the deer to appropriate wildlife reserves. It notes that the Central Zoo Authority, in exercise of its powers under Section 38H(6) of the Wild Life (Protection) Act, 1972, has cancelled the recognition of A.N. Jha Deer Park as a “mini zoo”, on account of persistent non-compliance with zoo management norms, failure to regulate the deer population, and the expiry of its licence in August, 2021. Under such circumstances, the continued retention of the deer at the said park is impermissible in law, there being no duly recognised statutory authority to ensure their proper management. The report further records that the deer population has increased exponentially due to the absence of effective population control and sterilisation measures, thereby necessitating their translocation.

6. It may further be noted that the High Court of Delhi, vide order dated 19th July, 2024, disposed of the writ petition filed by petitioner herein upon taking on record an additional affidavit dated 18th July, 2024 filed by the Delhi Development Authority2. In the said affidavit, it was stated that, as a policy decision approved by the Vice Chairman, DDA and endorsed by the Lieutenant Governor of Delhi, approximately two dozen deer would be retained at A.N. Jha Deer Park, subject to renewal of its “mini zoo” status by the Central Zoo Authority, and that necessary steps would be taken to obtain such approval. It was further indicated that the remaining deer could be translocated to forest areas in neighbouring States, having regard to the limited carrying capacity within Delhi and concerns relating to poaching. In view of the aforesaid stand and the 2 For short, “DDA”.

9. However, having regard to the fact that the Central Zoo Authority has already cancelled the recognition granted to the A.N. Jha Deer Park as a “mini zoo”, and further taking into account that the local authorities lack the requisite financial resources as well as infrastructural capacity to effectively sustain and fulfil the objectives for which the said deer park was originally established, the continuance of the existing arrangement does not commend acceptance. This position is further reinforced by the opinion of the Central Empowered Committee, an independent expert body, which has categorically observed that the A.N. Jha Deer Park does not possess the requisite carrying capacity to sustain such a large population of deer. We cannot be unmindful of the fact that deer, being a wildlife species, ought not to be confined to cages or restrictive enclosures save in exceptional and compelling circumstances duly justified in law and on ecological considerations.