Act against illegal resorts: Karnataka Minister

1. At a Glance

• Karnataka's Environment Minister Ramalinga Reddy has told forest officials to take immediate action against illegally built resorts and homestays in the Eco-Sensitive Zone (ESZ) and buffer zone of the State's tiger reserves and protected areas. [1]
• The topic brings together three things: commercial tourism, the core–buffer–ESZ zoning of tiger reserves, and federal enforcement of central environmental law. [1][3][5]
• UPSC relevance: Prelims (ESZ, buffer vs core, NTCA, the 1986 Environment Protection Act, State Board for Wildlife) and Mains GS-III (conservation, EIA, ecotourism).

2. Why in the News

• The direction was given at a meeting of the Standing Committee of the State Board for Wildlife (SBWL), Karnataka, which the Minister chaired. It was reported on 7 October 2026 (The Hindu, Chennai edition, p. 9). [1]
• The Minister asked for the number of resorts, homestays and other commercial activities in the ESZ and buffer zone that came up after ESZs were notified for the tiger reserves and protected areas. [1]
• He also said there should be "minimal disturbance" in ESZ areas. [1]

3. Background & Evolution

• Tiger reserve zoning: reserves are split into a core area, which is inviolate and used only for conservation, and a buffer area, which is a "multiple use area" with a strong conservation bias. [3][5]
• ESZ link: NTCA has advised States to declare the buffer/peripheral areas of tiger reserves as eco-sensitive under the Environment (Protection) Act, 1986. The entire buffer should form part of the ecologically sensitive area. [3]
• MoEFCC ESZ guidelines dated 9 February 2011 set the framework for what activities are allowed, regulated or prohibited in ESZs. [4]
• 3 June 2022: the Supreme Court ordered that no new permanent structure may be allowed for any purpose within an ESZ. [4]
• 26 April 2023: the Supreme Court clarified that activities are allowed, subject to strict adherence to the 2011 MoEFCC guidelines. [4]
• 17 November 2025: the Supreme Court gave a reportable judgment (2025 INSC 1325) in W.P.(C) No. 202 of 1995, the long-running forest-conservation matter. [2]
• Tourism rules: new eco-friendly resorts may be allowed in buffer zones, but are strictly banned in identified tiger corridors. Eco-friendly tourism facilities may come up on non-forest land within the buffer. [4]

4. Core Static Facts

Item	Fact
Core area	No forestry operations, collection of minor forest produce, grazing, human settlement or other biotic disturbance; used only for conservation [3][5]
Buffer area	A "multiple use area" with conservation-oriented land use; supports spill-over wildlife from the core and works as a corridor [3][5]
ESZ legal basis	Notified under the Environment (Protection) Act, 1986 [3][4]
ESZ guidelines	MoEFCC, 9 February 2011 [4]
SC bar on new permanent structures in ESZ	Order of 3 June 2022, modified on 26 April 2023 [4]
Resorts in buffer	Eco-friendly resorts allowed, but prohibited in tiger corridors; must comply with ESZ notifications [4]
Apex tiger body	National Tiger Conservation Authority (NTCA), which succeeded the Director, Project Tiger [3][5]
State body in the news	State Board for Wildlife, acting through its Standing Committee [1]

• The following are standard textbook facts. They did not come from the sources I retrieved, so check them against the bare Act:
• Core/buffer zoning is set out in Section 38V of the Wild Life (Protection) Act, 1972, inserted by the 2006 amendment.
• NTCA is constituted under Section 38L.
• The SBWL is set up under Section 6 and is chaired by the Chief Minister.

5. Multi-Dimensional Analysis

Environmental

• Buffers absorb spill-over wildlife and serve as corridors. Commercial building there breaks up habitat and raises human–wildlife conflict. [3][5]
• Construction in a tiger corridor is a stated red line, even for eco-friendly resorts. [4]

Legal / Constitutional

• ESZs draw their force from the EP Act, 1986. Structures built after notification without permission are therefore illegal, not just irregular. [3][4][1]
• The Supreme Court's 2022 and 2023 orders, and the continuing Godavarman matter (W.P.(C) 202/1995), make the courts an active regulator of land use in forest areas. [2][4]

Economic / Social

• Homestays and resorts provide local income. A blanket crackdown could hurt local communities unless they are steered towards regulated, eco-friendly tourism on non-forest land. [4]
• Regulated activities in buffer areas are meant to balance conservation with livelihoods. [3]

Administrative / Governance

• The Minister's request for an inventory of commercial activity points to a baseline-data gap: enforcement is happening after notification, not alongside it. [1]
• Implementation is split three ways: the Centre (MoEFCC/NTCA) notifies and advises, the courts set binding limits, and the State forest department enforces. [1][3][4]

Ethical

• There is a trade-off between short-term tourism revenue and fair treatment of future generations and wildlife. Weak enforcement can reward people who build illegally first. [1][4]

6. Recent Developments (last 12–18 months)

• 17 November 2025: Supreme Court judgment, 2025 INSC 1325, in W.P.(C) 202/1995. [2]
• December 2025: NTCA released the booklet "Securing Tigers for Posterity". [5]
• October 2026: the Karnataka SBWL Standing Committee directed action against illegal resorts and homestays in ESZ and buffer zones. [1]

7. Prelims Hooks

• ESZs are notified under the Environment (Protection) Act, 1986, not the Wild Life (Protection) Act. [3][4]
• MoEFCC's ESZ guidelines are dated 9 February 2011. [4]
• 3 June 2022: the Supreme Court barred any new permanent structure within an ESZ. [4]
• 26 April 2023: the Supreme Court allowed ESZ activities subject to the 2011 guidelines. [4]
• The entire buffer of a tiger reserve should be part of the ecologically sensitive area. [3]
• The buffer zone is a "multiple use area" with a conservation bias. [3][5]
• The core zone allows no grazing, minor forest produce collection or human settlement. [3][5]
• New eco-friendly resorts may be allowed in the buffer, but are prohibited in tiger corridors. [4]
• Eco-tourism facilities are permitted on non-forest land within buffer zones. [4]
• The Godavarman forest matter is W.P.(C) No. 202 of 1995. [2]
• Karnataka's action came through the Standing Committee of the State Board for Wildlife. [1]

8. Why Calling a Resort 'Illegal' Is Harder Than It Sounds

• The Minister's order covers only buildings that came up after notification
• He asked for resorts and homestays built after the ESZs (Eco-Sensitive Zones) were notified [1].
• Anything built before that date is outside this order, even if it sits right on a wildlife path.

• So the later a State notifies an ESZ, the more buildings escape the rule.

• States often take years to notify ESZs, and that leaves a gap open for building

• In Rajasthan, CAG (Comptroller and Auditor General, India's official auditor of government spending) found that the forest department sent incomplete ESZ proposals. This delayed notification around two tiger reserves [9].
• CAG first raised this in its Audit Report No. 5 of 2019. The PAC (Public Accounts Committee, the legislature's committee that acts on CAG reports) asked for speed in March 2022. CAG found the position unchanged afterwards [9].
• At the national level, the government told Parliament in July 2022 that a final notification on eco-sensitive areas had been pending for eight years [13].

• Every year of delay is a year in which a resort can be built legally and then never be counted as 'illegal'.

• The legal line has moved more than once

• In 2022 the Supreme Court said no new permanent structure in an ESZ. In 2023 it changed this to 'allowed, if the 2011 guidelines are followed' [4].
• A building put up between these two orders may be judged by a different test than one built later. Owners will use this in court.

9. The Rulebook Exists, but the Plans and Committees Often Don't

• An ESZ notification is meant to work through three tools
• A Zonal Master Plan (a land-use map saying what can go where in the ESZ).
• A Tourism Master Plan (how much tourism the area can handle, and where).

• A Monitoring Committee (the body that actually says yes or no to a project) [10].

• Without them, nobody can lawfully say yes or no

• At Palamau Tiger Reserve (Jharkhand), a petition before the NGT (National Green Tribunal, the special court for environment cases) said 59 hotels and resorts were coming up inside the ESZ [10].
• The same petition said no Zonal Master Plan, Tourism Master Plan or Monitoring Committee existed to decide on eco-tourism permission [10].

• On 25 May 2026 the NGT asked Jharkhand to respond [10].

• This is a national pattern, not one State's failure

• Down To Earth's review found ESZs largely 'on paper': Zonal Management Plans missing, committees weak, and ESZ rules not built into town Master Plans [11].

• So roads, quarries and buildings keep coming up even after an ESZ is notified [11].

• Why this matters for Karnataka's order

• The Minister's inventory will show how many buildings exist [1].
• But if there is no plan and no working committee, the State cannot tell an honest eco-friendly homestay from a disguised resort. Both look equally 'unpermitted'.

10. Why Orders Like This Often Fade After the Headlines

• Counting is easy. Removing is hard.
• CAG found that commercial shops were running inside Sariska Tiger Reserve without approval from the National Board for Wildlife. No concrete action had been taken to remove them [9].

• The chain went like this: the auditor flagged the problem, the legislature's committee asked for action, and the department still did not act [9].

• The damage keeps growing while files move slowly

• Forest area in Bandipur National Park has fallen by 15.19% in 50 years, mainly due to development and forest fires [12].
• Nagarhole has lost about 11% of its forest cover, linked to human activity and more horticulture (fruit, coffee and other plantation farming) [12].

• These are two of Karnataka's main tiger reserves. A crackdown that only produces a list will not slow this loss.

• The same enforcer is also the permit-giver

• The State forest department both enforces the ESZ and processes permissions [1][3].
• Buildings that came up 'after notification' came up while that same department was in charge. An inventory made by the department is partly a report on its own past failure, which gives it little reason to make the list complete.

11. The Livelihood Objection and How Far It Holds

• The strongest objection: this will hit small local families, not big resort owners
• Homestays are often a local family renting out rooms. Big resorts can afford lawyers and long court cases.

• So a crackdown may close the small, weak operator first. The rich operator stays open on a court stay.

• What is right about it

• The rules themselves favour local, low-impact tourism. Eco-friendly facilities are allowed on non-forest land inside the buffer [4].

• An order that treats every homestay as illegal goes against the purpose of the buffer, which is a 'multiple use area' meant to support local people too [3].

• Where it fails

• The ban in tiger corridors (the strips of forest tigers use to move between reserves) is absolute, even for eco-friendly resorts [4]. Being small does not make a building safe if it blocks a corridor.

• Palamau shows the real problem: when there is no Tourism Master Plan, the honest local operator also has no legal route to get permission [10]. The fix is to build that route, not to stop enforcing.

• Fair answer: sort buildings by where they stand (corridor or not) and how big they are, not just by when they were built.

12. What Karnataka Should Do Next, and Who Should Do It

• Forest Department: finish the plans before the demolitions
• Prepare the Zonal Master Plan and Tourism Master Plan, and set up the Monitoring Committee for each ESZ. These are the tools an ESZ notification needs to work [10][11].

• Without them, every demolition order can be challenged as arbitrary (decided without a clear rule).

• State Board for Wildlife: make the inventory public and time-bound

• The Standing Committee asked for numbers [1]. It should set a deadline and publish the list.

• Rajasthan shows what happens otherwise: the issue sat from CAG's 2019 report to the PAC's 2022 recommendation and beyond, with no change [9].

• Act on corridors first

• Resorts in tiger corridors are banned outright, so the legal case is strongest there [4].

• NTCA has asked that the entire buffer be part of the ESZ [3]. Karnataka should check that its ESZ maps actually cover all buffer and corridor land.

• Give genuine homestays a legal path

• Move permitted eco-tourism to non-forest land in the buffer, as the rules allow [4].
• This separates the local family earning a living from the commercial resort trying to get round the rules.

13. Anchors for Answers

• Data: Bandipur National Park lost 15.19% of its forest area in 50 years, and Nagarhole about 11% of its forest cover [12]
• Data: 59 hotels and resorts were alleged to be coming up inside Palamau Tiger Reserve's ESZ, with no Zonal Master Plan or Monitoring Committee [10]
• Report/Committee: CAG Audit Report No. 5 of 2019 and a later CAG audit (Rajasthan): ESZ notification delayed by incomplete proposals. The PAC asked for faster action in March 2022 [9]
• Law/Case: Supreme Court order of 3 June 2022 (no new permanent structure in an ESZ), changed on 26 April 2023 (allowed if the 2011 MoEFCC guidelines are followed) [4]. The NGT acted on Palamau ESZ hotels on 25 May 2026 [10]
• Comparison: Sariska (Rajasthan): commercial shops ran without National Board for Wildlife approval and were not removed even after CAG flagged them. This shows the risk of counting without acting [9]
• Scheme: Project Tiger / NTCA: the core–buffer zoning and NTCA's advice that the entire buffer be part of the ESZ [3]

14. Mains Relevance

• GS-III: Conservation; environmental pollution and degradation; Environmental Impact Assessment.
• GS-II: Government policies and interventions; Centre–State relations in enforcement.
• GS-IV: Ethics in public administration, including enforcement integrity.
• Possible questions: 1. Eco-Sensitive Zones are meant to act as shock absorbers for Protected Areas, yet unregulated tourism threatens them. Examine, with reference to recent judicial directions. (15 marks) 2. Discuss the core–buffer zoning of tiger reserves. How far can eco-tourism in buffer zones be reconciled with conservation? (10 marks) 3. Judicial activism has shaped forest governance in India. Critically assess, citing the T.N. Godavarman case. (15 marks)

15. Related Topics to Study Next

• Project Tiger and NTCA: the institutional parent of core/buffer zoning.
• The 2006 amendment to the Wild Life (Protection) Act and the 2022 amendment: the statutory base for tiger reserves and wildlife boards.
• Environment (Protection) Act, 1986: the source of ESZ notifications.
• T.N. Godavarman Thirumulpad case: the continuing mandamus on forests.
• Western Ghats ESA (Gadgil and Kasturirangan reports): a parallel debate over eco-sensitivity in Karnataka.
• Wildlife corridors and the human–wildlife conflict: the reason construction in corridors is banned.
• Forest Rights Act, 2006: community rights in buffer areas.
• Coastal Regulation Zone: a comparable zoning-based environmental regime.

16. NCERT Concepts to Revise

• Eco-sensitive zone (Geography): The illegal resorts sit in ESZs and buffer zones; knowing what ESZs allow or ban is central.
• Environment Protection Act 1986 (Geography): ESZs are notified under this Act, so it gives the legal basis for calling the resorts illegal.
• National Tiger Conservation Authority (Geography): This statutory body advises states on core and buffer zoning and declaring buffers eco-sensitive.
• Project Tiger (Geography): Tiger reserves and their core-buffer zoning come from this scheme, which is the base for the topic.
• Wildlife (Protection) Act 1972 (Geography): It provides the law for tiger reserves and wildlife boards, and is often confused with the EP Act.
• Continuing mandamus (Polity): The Supreme Court's ongoing Godavarman forest case shows how courts keep supervising land use in forest areas.

17. Common Errors / Trap Areas

• ESZ ≠ buffer zone. The buffer is part of the tiger reserve's own zoning. An ESZ is a separate notification under the EP Act around protected areas. NTCA wants the buffer to fall inside the ESZ, but the two are legally distinct. [3]
• Wrong Act. ESZs come under the EP Act, 1986, not the WPA, 1972. [3][4]
• "No construction at all" is not quite right. The 2022 Supreme Court bar was eased in 2023 by tying it to the 2011 guidelines. [4]
• Resorts in buffer vs corridor. Eco-friendly resorts can be allowed in the buffer, but never in corridors. [4]
• The SBWL is a State body. Don't confuse it with the National Board for Wildlife, which is chaired by the Prime Minister (standard static fact, not from the retrieved sources).