In a sharp rebuke that raised eyebrows over the handling of sensitive environmental litigation, the Supreme Court of India on Thursday ordered a fact-finding inquiry after discovering that a crucial judicial order was missing from the official case records in the ongoing Tiger Reserve matter in Goa.
A bench led by Chief Justice of India Surya Kant, along with Justices Joymalya Bagchi and Vipul Pancholi, said its September 8, 2025 order could not be found in the paperbook placed before it. The judges noted that the disappearance of proceedings from case files had become a recurring problem and described the lapse as “a deliberate attempt for some obvious reasons.”
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The court directed the Secretary General of the Supreme Court to immediately conduct a fact-finding inquiry and submit a report to the Chief Justice on the administrative side, signalling that the matter would not be treated as a routine clerical oversight.
The missing order assumes significance because, on September 8, 2025, the bench had directed the Central Empowered Committee (CEC) to undertake a detailed examination of the proposal for a Tiger Reserve in Goa and to hear all stakeholders, including the State government and the original petitioner, before submitting its report.
On Thursday, the court recorded that the CEC had since filed its report in November 2025. It granted two weeks’ time to the respondents, including NGO Goa Foundation, to place their responses on record. The matter has been listed for further hearing on March 16.
In its report, the CEC recommended a two-phase roadmap for establishing a Tiger Reserve in the State. In Phase I, it proposed notifying the Netravali and Cotigao Wildlife Sanctuaries as core areas and merging them with the core of the Kali Tiger Reserve in neighbouring Karnataka. In Phase II, it suggested declaring the Bhagwan Mahaveer Wildlife Sanctuary and Mollem National Park as buffer areas, aligning them with the contiguous buffer zone of the Kali Tiger Reserve.
The Goa government, however, has mounted a strong challenge to the CEC’s approach. In an affidavit filed last month, the State argued that the Committee fundamentally misconstrued the scope of the reference made to it by the Supreme Court. According to the government, the CEC proceeded on the assumption that declaration of a Tiger Reserve in Goa was a foregone conclusion. The State contended that the Committee’s mandate was limited to assessing whether prevailing facts and circumstances warranted such a declaration — not to recommending modalities for implementing a decision that had not yet been taken.
The Supreme Court is hearing a special leave petition filed by the Government of Goa challenging a July 24, 2023 order of the Bombay High Court (Goa Bench), which had directed the State to notify the Mhadei Wildlife Sanctuary and adjoining areas as a Tiger Reserve. The High Court had acted on a public interest litigation filed by Goa Foundation.
With the apex court now flagging a “deliberate” disappearance of records, the controversy over Goa’s proposed Tiger Reserve has acquired a new and unsettling dimension — one that goes beyond conservation policy and into the integrity of judicial process itself.
