Prioritise ecological security of country over “false narrative” of “highway development”: CCG to Govt & Courts

Former bureaucrats protest the “steady lowering of statutory safeguards for protecting India’s Environment and Forests” in an open letter to the government; both government and the judiciary need to prioritise the ecological security of our country and the health and life of its citizens over the false narrative of more roads, more buildings, more townships, more mines, more industries, more destruction of the natural world that is currently seen as progress.
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The diversion of 215,943 hectares (ha) of forestland for non-forest use during the period from 2014–15 to 2025–26 by express government approval, as declared before Parliament in July 2026 has been contested and protested by a group of civil servants, the Constitutional Conduct Group (CCG) in an open letter to government dated September 17. The group former civil servants of the All India and Central Services who have worked with the Central and State Governments in the course of their careers has stated that nearly 62 per cent of this land (diverted 215,943 hectares) was cleared for mining, hydropower, irrigation and road projects. The pace of forest diversion has accelerated sharply in recent years.

Stating that they are deeply dismayed at the recent reports of large scale, state driven deforestation due to diversion of forestlands for developmental projects, the open letter cites a July 2026, reply of the Minister of State for Environment, Forest and Climate Change in response to a Parliament question. Further, the communication states that, in the five years from 2014–15 to 2018–19, a total of 74,705.68 ha of forestland was approved for diversion. In the next five-year period from 2019–20 to 2023–24, this increased, by nearly 29 per cent, to 96,112.90 hectares. If the current pace continues, forest land diversion during the next five years is likely to exceed 110,000 hectares. Besides, the increase in deforestation is most evident in the ecologically sensitive Himalayan and North Eastern states, in Sikkim, Arunachal Pradesh, Himachal Pradesh, etc. And many other proposals are in the offing, the most appalling of them being the cutting down of nearly a million trees, over 13000 hectares of rainforest in Great Nicobar Island.

The communication also emphasises that, the compensatory afforestation that is expected to be undertaken for the diversion of these 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.

Within this alarming trend, of particular concern is the fact that lands within National Parks and Wildlife Sanctuaries. I.e. Protected Areas (PAs) along with their Eco-Sensitive Zones (ESZs) are also being diverted at an alarming pace. Proposals to divert lands inside PAs 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. However, it is seen that 97% of the diversion proposals placed before the SC-NBWL since 2014 have been cleared.  In just four meetings held in 2024 and 2025, as much as 5824 ha 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 permitted were for 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. – entities which in no way benefit wildlife and their habitats. More worryingly, an increasing trend of diversions is noted in Protected Area clearances with every passing year: from 91 projects within Protected Areas granted clearance in 2019, the number steadily increased to 378 in 2024 and 312 in 2025.  PAs make up only 5.4% of the geographic area of the country and the headwaters of many rivers originate in these PAs, providing water and ecological security to the country.  Fragmentation of forests and wildlife habitat drastically reduces the ability of these areas to perform their vital role as a green lung for the country.

How did this happen

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.  For instance, the Forest Conservation Amendment Act 2023, has   redefined forests in a way that leaves out huge tracts of forested land from legal protection and allows easy diversion of such lands.

Projects which have gone ahead without obtaining the mandatory forest clearances as required under law are being regularised on payment of nominal fines, or by the ridiculous requirement that the violator undertake three to five times penal compensatory afforestation. This is totally antithetical to environmental jurisprudence which directs that EIAs should be done prior to commencement of the project and the diversion of forest and other lands, and not as a fait accompli after the project has started.   After the Forest Conservation Act of 1980 was amended and the Van (Sanrakshan Evam Samvardhan) Adhiniyam or the Forest Conservation Amendment Act came into being in 2023, the Ministry of Environment, Forest and Climate Change  has, in just two years (2024–25 and 2025–26), already approved the diversion, for non-forestry purposes, approximately 22562 ha of forestland per year , as compared to an average of 19223 hectares per year during the five year period 2019 – 24, and 14941 hectares  per year for the preceding  five year period.

The letter also contends that, the SC-NBWL, which is constituted of mainly top government officials, unfortunately, “seems to have no hesitation in approving almost all the diversion proposals placed before it.  It is particularly condemnable 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.  This includes 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.”

The recent Supreme Court ruling in July 2026 stating that post-facto environmental clearances (ECs) are legally acceptable if they are authorised by a post-facto valid statutory notification under the Environment (Protection) Act, 1986, does nothing to improve matters, permitting the central government to regularise violations under Section 3 of the Environment (Protection) Act, 1986.  The Court effectively replaces 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.

Every day brings a new, foolhardy proposal to reduce forested and wildlife protected areas. One such is the recent proposal of the Assam Government to reduce the Eco-sensitive zone (ESZ) of the iconic Kaziranga National Park from 10 Kms to 1 km and allow brick kilns, stone crushers, hotels, commercial warehouses, etc., to operate much closer to the park boundary. It does not apparently matter that the rhinoceros population will be severely and adversely affected. Another such proposal is the use of 12.6 hectares of the Delhi Ridge for the President’s Bodyguard parade ground, which, if implemented, will further fragment the already degraded ridge in Delhi which serves as a green lung for the metropolis.

Do highways mean growth?

The recent push for “development” arises from a misguided understanding that roads, infrastructure, mines, etc. will ensure the growth of the country. There is no realisation that an unpolluted environment together with extensive forest cover and thriving wildlife is even more important for human well-being. Recently issued environmental, forest and wildlife laws, rules and office orders along with “development friendly” judicial rulings have weakened the earlier strong environmental and conservation approach of the country.

The over 700 signatories state that while they acknowledge that infrastructure development projects are necessary for the country, but they should not come at the cost of ecological security. This can only imperil the country as evident from the massive landslides, mudslides, alarming AQI’s, heat waves, deluges, floods, and other environmental calamities occurring across the country. 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.

Finally, the communication urges both the government and the judiciary to prioritise the ecological security of our country and the health and life of its citizens over the false narrative of more roads, more buildings, more townships, more mines, more industries, and more destruction of the natural world that is currently seen as progress.

Constitutional Conduct Group (77 signatories as below)

1.Anand ArniRAS (Retd.)Former Special Secretary, Cabinet Secretariat, GoI
2.Aruna BagcheeIAS (Retd.)Former Joint Secretary, Ministry of Mines, GoI
3.Sandeep BagcheeIAS (Retd.)Former Principal Secretary, Govt. of Maharashtra
4.J.L. BajajIAS (Retd.)Former Chairman, Administrative Reforms and Decentralisation Commission, Govt. of Uttar Pradesh
5.G. BalachandhranIAS (Retd.)Former Additional Chief Secretary, Govt. of West Bengal
6.Vappala BalachandranIPS (Retd.)Former Special Secretary, Cabinet Secretariat, GoI
7.Chandrashekar BalakrishnanIAS (Retd.)Former Secretary, Coal, GoI
8.Rana BanerjiRAS (Retd.)Former Special Secretary, Cabinet Secretariat, GoI
9.Sharad BeharIAS (Retd.)Former Chief Secretary, Govt. of Madhya Pradesh
10.Madhu BhaduriIFS (Retd.)Former Ambassador to Portugal
11.Pradip BhattacharyaIAS (Retd.)Former Additional Chief Secretary, Development & Planning and Administrative Training Institute, Govt. of West Bengal
12.Nutan Guha BiswasIAS (Retd.)Former Member, Police Complaints Authority, Govt. of NCT of Delhi
13.Meeran C BorwankarIPS (Retd.)Former DGP, Bureau of Police Research and Development, GoI
14.Ravi BudhirajaIAS (Retd.)Former Chairman, Jawaharlal Nehru Port Trust, GoI
15.R. ChandramohanIAS (Retd.)Former Principal Secretary, Transport and Urban Development, Govt. of NCT of Delhi
16.Rachel ChatterjeeIAS (Retd.)Former Special Chief Secretary, Agriculture, Govt. of Andhra Pradesh
17.F.T.R. ColasoIPS (Retd.)Former Director General of Police, Govt. of Karnataka & former Director General of Police, Govt. of Jammu & Kashmir
18.Anna DaniIAS (Retd.)Former Additional Chief Secretary, Govt. of Maharashtra
19.Vibha Puri DasIAS (Retd.)Former Secretary, Ministry of Tribal Affairs, GoI
20.Nitin Desai Former Chief Economic Adviser, Ministry of Finance, GoI
21.M.G. DevasahayamIAS (Retd.)Former Secretary, Govt. of Haryana
22.Sushil DubeyIFS (Retd.)Former Ambassador to Sweden
23.Suresh K. GoelIFS (Retd.)Former Director General, Indian Council of Cultural Relations, GoI
24.Meena GuptaIAS (Retd.)Former Secretary, Ministry of Environment & Forests, GoI
25.Wajahat HabibullahIAS (Retd.)Former Secretary, GoI and former Chief Information Commissioner
26.Siraj HussainIAS (Retd.)Former Secretary, Department of Agriculture, GoI
27.Syed Masood HusainIES (Retd.)Former Chairman, Central Water Commission & ex officio Secretary, Ministry of Jal Shakti, GoI
28.Sanjay KaulIAS (Retd.)Former Principal Secretary, Govt. of Karnataka
29.Naini JeyaseelanIAS (Retd.)Former Secretary, Inter-State Council, GoI
30.Najeeb JungIAS (Retd.)Former Lieutenant Governor, Delhi
31.Sudhir KumarIAS (Retd.)Former Member, Central Administrative Tribunal
32.Aloke B. LalIPS (Retd.)Former Director General (Prosecution), Govt. of Uttarakhand
33.Subodh LalIPoS (Resigned)Former Deputy Director General, Ministry of Communications, GoI
34.Harsh ManderIAS (Retd.)Govt. of Madhya Pradesh
35.Amitabh MathurIPS (Retd.)Former Special Secretary, Cabinet Secretariat, GoI
36.Aditi MehtaIAS (Retd.)Former Additional Chief Secretary, Govt. of Rajasthan
37.Malay MishraIFS (Retd.)Former Ambassador to Hungary
38.Satya Narayan MohantyIAS (Retd.)Former Secretary General, National Human Rights Commission
39.Jayashree MukherjeeIAS (Retd.)Former Additional Chief Secretary, Govt. of Maharashtra
40.Ruchira MukerjeeIP&TAFS (Retd.)Former Advisor (Finance), Telecom Commission, GoI
41.Anup MukerjiIAS (Retd.)Former Chief Secretary, Govt. of Bihar
42.Deb MukharjiIFS (Retd.)Former High Commissioner to Bangladesh and former Ambassador to Nepal
43.Shiv Shankar MukherjeeIFS (Retd.)Former High Commissioner to the United Kingdom
44.Gautam MukhopadhayaIFS (Retd.)Former Ambassador to Myanmar
45.Jugal MohapatraIAS (Retd.)Former Secretary, Department of Rural Development, GoI
46.Surendra NathIAS (Retd.)Former Member, Finance Commission, Govt. of Madhya Pradesh
47.P. Joy OommenIAS (Retd.)Former Chief Secretary, Govt. of Chhattisgarh
48.Amitabha PandeIAS (Retd.)Former Secretary, Inter-State Council, GoI
49.Mira PandeIAS (Retd.)Former State Election Commissioner, West Bengal
50.Alok PertiIAS (Retd.)Former Secretary, Ministry of Coal, GoI
51.G.K. PillaiIAS (Retd.)Former Home Secretary, GoI
52.Smita PurushottamIFS (Retd.)Former Ambassador to Switzerland
53.V.P. RajaIAS (Retd.)Former Chairman, Maharashtra Electricity Regulatory Commission
54.V. Ramani

 

IAS (Retd.)Former Director General, YASHADA, Govt. of Maharashtra
55.M. RameshkumarIAS (Retd.)Former Member, Maharashtra Administrative Tribunal
56.Archana RanjanIRS (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 RaoIAS (Retd.)Former Health Secretary, GoI

 

59.Satwant ReddyIAS (Retd.)Former Secretary, Chemicals and Petrochemicals, GoI
60.Julio RibeiroIPS (Retd.)Former Director General of Police, Govt. of Punjab
61.Manabendra N. RoyIAS (Retd.)Former Additional Chief Secretary, Govt. of West Bengal
62.A.K. SamantaIPS (Retd.)Former Director General of Police (Intelligence), Govt. of West Bengal
63.Deepak SananIAS (Retd.)Former Principal Adviser (AR) to Chief Minister, Govt. of Himachal Pradesh
64.Biswaranjan SasmalIRS (Retd.)Former Additional Secretary, Department of Social Justice Empowerment, GoI
65.G.V. Venugopala SarmaIAS (Retd.)Former Member, Board of Revenue, Govt. of Odisha
66.N.C. SaxenaIAS (Retd.)Former Secretary, Planning Commission, GoI
67.Aftab SethIFS (Retd.)Former Ambassador to Japan
68.Ashok Kumar SharmaIFoS (Retd.)Former MD, State Forest Development Corporation, Govt. of Gujarat
69.Ashok Kumar SharmaIFS (Retd.)Former Ambassador to Finland and Estonia
70.Raju SharmaIAS (Retd.)Former Member, Board of Revenue, Govt. of Uttar Pradesh
71.ShivenduIAS (Retd.)Former Secretary, Health & Member (Finance), Jharkhand State Electricity Board, Govt. of Jharkhand
72.Avay ShuklaIAS (Retd.)Former Additional Chief Secretary (Forests & Technical Education), Govt. of Himachal Pradesh
73.Tara Ajai SinghIAS (Retd.)Former Additional Chief Secretary, Govt. of Karnataka
74.Mridula SinhaIAS (Retd.)Former Director General, Administrative Training Institute, Govt. of Jharkhand
75.Prakriti SrivastavaIFoS (Retd.)Former Principal Chief Conservator of Forests & Special Officer, Rebuild Kerala Development Programme, Govt. of Kerala
76.Anup ThakurIAS (Retd.)Former Member, National Consumer Disputes Redressal Commission
77.Geetha ThoopalIRAS (Retd.)Former General Manager, Metro Railway, Kolkata

 

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