On 18 December 2024, the Supreme Court held that Rajasthan’s sacred groves, called orans, are forests that deserve legal protection. The headline “sacred groves recognised as deemed forests” sounds national, but the operative directions concern Rajasthan. The principle, however, matters well beyond one state.
Source: Scroll.in (8 January 2025), which triggered this note; checked against the Supreme Court judgment in In Re: T.N. Godavarman Thirumulpad v. Union of India (18 December 2024) as reported by SCC Online and Mongabay. Evidence level: law reporters and press. The judgment text was not reviewed; this note relies on court and environment news reports.
A broader meaning of “forest”
The roots of the decision lie in the 1996 Godavarman judgment, which gave “forest” its dictionary meaning irrespective of ownership, legal status or vegetation type. Consequently, that broad reading paved the way for sacred groves: patches of land that local communities have protected for their spiritual significance. The December 2024 order applies it to orans. It goes beyond forest density and government classification and acknowledges three things. Even sparse ecosystems, often missing from official forest records, play vital ecological roles. Sacred groves are small but rich in cultural and ecological significance. And protection must cover landscapes that sustain biodiversity and community traditions, not only dense woodland.
What the judgment actually directed
A bench of Justices B.R. Gavai, S.V.N. Bhatti and Sandeep Mehta decided the case. Its operative directions concern Rajasthan. Specifically, the state forest department must map its orans on the ground and by satellite, and then notify them as deemed forests. The Court said the classification should not depend on a grove’s size. In addition, Mongabay reports that since 2018 Rajasthan had notified only about 5,000 of some 25,000 orans.
The Court also asked the Centre to consider identifying sacred groves across the country and framing a protection policy. It recommended protection under the Wildlife (Protection) Act, 1972, through section 36-C. So the national significance lies in the principle and the recommendation, and not in an automatic change in every state.
Note that “deemed forest” is a court-led idea and not a defined category in the Act. How it sits with the 2023 amendment to the forest law, and with community rights under the Forest Rights Act, is still being worked out. Use the case as an example of law catching up with a cultural practice, and add that qualification.
Why this ruling matters
The judgment reflects a shift in conservation thinking, from a density-based approach to an ecosystem-centred one in which cultural practice, biodiversity value and ecological services count as much as appearance. Moreover, sacred groves are living examples of community-led conservation. They protect species and ecological balance in ways that modern forest laws often overlook.
The anthropological point
Sacred groves exist across India under local names, such as kavu in Kerala, devrai in Maharashtra and the Law Lyngdoh groves of the Khasi Hills. What links them is a rule of taboo. Cutting trees, hunting or removing produce is forbidden because the place belongs to a deity or to ancestors. Thus conservation here rests on belief and community authority and not on a forest guard.
Using it in UPSC Mains
Paper 2, clause 3.3 covers the Sacred Complex and the Nature-Man-Spirit Complex, and clause 6.3 covers the development of forest policy and tribals. Sacred groves are the clearest place where the two meet. The judgment adds a legal step to the ethnography and lets an answer move from belief to forest policy in a single argument.
The closest PYQs are the Nature-Man-Spirit Complex (2026, Paper 2) and tribals as custodians of natural resources and climate change (2024, Paper 2). Browse tribal India for more. Related reading: the Forest Rights Act and tribal rights, the Dongria Kondh and Niyamgiri and the full optional guide.
Sources
SCC Online on the 18 December 2024 judgment; Mongabay India; India Environment Portal judgment record; Scroll.in (8 January 2025), cited from the earlier version of this article.