The Supreme Court on Monday held that Deer Park in south Delhi will require approval from the Central Zoo Authority (CZA) to continue as a “mini zoo” with a restricted deer strength of just 38, paving way for the translocation of the remaining deer population to two tiger reserves in Rajasthan.

A bench of justices Vikram Nath and Sandeep Mehta said: “It is directed that retention of up to 38 deer at AN Jha Deer Park as recommended by the Central Empowered Committee (CEC) shall be permissible only subject to the grant of requisite approvals and clearances by CZA.”
The court further directed the Delhi Development Authority (DDA) to ensure that it develops and upgrades the necessary logistical capacity, infrastructure, and adequately trained human resources for the upkeep and management of the reduced deer population. “DDA shall ensure that the retained population has an optimal sex ratio of 15 males to 23 females,” the court said.
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{{/usCountry}}The court directed that the park, spread across 10 acres, be maintained as a “protected forest” and stressed, “Under no circumstances shall the nature or status of the said area be altered, and the same shall continue to be maintained as a protected forest at all times in the future.”
The directions came on a petition filed by NGO New Delhi Nature Society objecting to the translocation of caged deer to tiger reserves in Rajasthan – Ramgarh Vishdhari Tiger Reserve and Mukundara Hills Tiger Reserve. Already, 260 deer have been relocated to the two reserves.
As the issue raised in the petition required expert opinion, the court had directed the CEC in November 2025 to conduct a site visit of the Deer Park and the two translocation sites to suggest a way forward. The CEC supported the decision to translocate the deer to wildlife reserves, stating that Deer Park does not have the carrying capacity to support such a large population of deer.
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“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,” the bench said.
Further, the CEC pointed out that CZA had cancelled the recognition of AN 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.
In November 2025, the Supreme Courthalted further translocation of deer from the Deer Park and tasked the CEC with examining key issues, including the actual population, ecological capacity, and the fate of animals already shifted to Rajasthan.
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The judgment accepted all recommendations made by the CEC, which said that if Deer Park is to continue in its present form, it must conform to CZA norms, as the space available can “sustainably and humanely” accommodate only 38 spotted deer with an optimal sex ratio of 15 males to 23 females. CZA norms framed under the Wildlife (Protection) Act, 1972 incorporate the IUCN guidelines.
The court directed the translocation to be carried out in a time-bound manner in strict compliance with prescribed rules and regulations under the supervision of the CEC, and in strict adherence to the draft guidelines on Animal Translocation framed by the CEC. In case DDA is unable to attain these mandatory compliances, the court permitted an appropriate application to be moved for clarification or directions.
The CEC, in a report last month, emphasised a slew of measures to be carried out in the urban ecological zone, including providing night shelters for deer, water troughs, green fodder, planting native trees and shrubs, and designated public viewing areas.
The total deer population in the park was originally estimated to be between 400 and 550. The Guidelines for Establishment and Scientific Management of Zoos in India, 2008, issued by CZA, prescribe a minimum outdoor enclosure area of 1,500 square metres per pair of spotted deer, excluding areas utilised for barriers, shelters, pathways, and service infrastructure.
As the Deer Park provides an estimated usable area of about 29,000 square metres, the CEC said the enclosure can sustainably accommodate approximately 19 deer units (pairs).
The court directed that while translocating, the authorities must follow guidelines applicable for transporting deer, veterinary requirements, and all prescribed protocols relating to capture, handling, transportation, acclimatisation through soft release, and post-release monitoring of the deer at the two sites.
The CEC report found that the deer, having been confined to a controlled habitat for a considerable period, had no exposure to open forest ecosystems, thereby rendering abrupt relocation unsuitable and potentially detrimental to their survival and well-being.
Noticing the statutory gap for dealing with future wildlife translocations in a carefully structured and scientifically informed manner ensuring animal welfare and ecological sustainability, the court directed the Union ministry of environment, forest and climate change to examine the draft comprehensive guidelines prepared by the CEC within six months and submit a compliance report to the court.
“These guidelines deserve to be, and shall be, imparted statutory status,” the court said, posting the matter for monitoring compliance on January 19 next year.
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