In a letter to the Union environment, forests and climate change minister, senior officials of the ministry under him and their Gujarat counterparts, including chief minister Vijay Rupani, top Vadodara-based environmentalist Rohit Prajapati has demanded that the government must immediately stop translocation of the crocodiles from the lakes near Sardar Sarovar Dam, as the translocation of crocodile is “not a viable/appropriate solution”, and it is short-sighted with long term adverse impacts.
The letter by Prajapati, who heads Paryavaran Suraksha Samiti, signed by his colleagues Krishnakant and Swati Desai, also says the translocation is a violation of several environment and forest laws, including the Wildlife (Protection Act, 1972.
Text of the letter:
The Gujarat State Forest Department has started relocating crocodiles from two ponds / impoundments near the Sardar Sarovar Dam Project next to the world’s tallest statue. The purported reason given is “Tourist Safety” but most likely this is being done for the proposed ‘Seaplane Project’.
We strongly believe that translocation of crocodile will cause further problems for this nationally vulnerable Schedule I species and result in multiple issues within the area for different stakeholders, including the concerned authorities.
What necessitates this translocation of the crocodiles from these ponds/impoundments? Who has decided this action, based on what advice or needs? On what scientific and technical bases and supervision this action is undertaken? The drastic and mindless action of the Forest Department will result in destruction and degradation of the habitats of many species and undermine the multiple values and ecological services of nature. Let us not overlook the needs and habits of the crocodiles and other food-web species for some selfish, human-centric ends. The planet Earth belongs to all species. It is imperative to respect the rights and needs of this mute but keystone species and the multiple values of its environs.
The translocation of crocodiles, under the pretext of “Tourist Safety”, is neither an apt reason nor a good solution, because such translocation means shifting the problem from one place to another. This may necessitate many more translocations in the near future or the species might migrate back to these impoundments in future. Hence, the so-called problem would persist. The following aspects also need to be considered and/or heeded:
- In absence of unknown number of crocodiles in the present Dyke 3 & 4, it is not possible to claim a crocodile free water body. Moreover, there is also the possibility of crocodiles entering the dykes from adjoining water bodies that are at the distance of 18 – 20 km from the Narmada Dam and main river course.
- Crocodile species have strong homing instinct and it tends to come back in original site. This has been scientifically proved in crocodiles (Read et al. 2007; Campbell et al. 2013), including mugger (Vyas & Bhatt 2004; Vyas 2010).
- Earlier, in 2006, Forest Department, Gujarat had appointed a crocodilian expert for such similar reasons. The expert opinion was that “zero mugger” is not possible for the water body, it is the best site for wildlife tourisms and better to develop for that, only. (See: Basu 2006).
- The government’s decision to incarcerate and relocate crocodiles from their natural habitat is against the principles of ‘The Wildlife (Protection) Act 1972’. Especially such an act by the Forest Department which very well knows that this period is the breeding season of the crocodiles raises questions on their role in the management of wildlife and its habitat.
- More significantly, the importance of this species is illustrated by the multiple legal and policy efforts which have been developed by the Government of India to protect the crocodile’s population. This species is categorized as nationally ‘Vulnerable’ subsequent to an assessment following IUCN criteria for threatened species (Molur & Walker 1998) and has the highest legal protection in India as it is listed in Schedule I of the Indian Wildlife (Protection) Act 1972. Any activity which is against the survival of the highly protected species without having been approved by the State Wildlife Board and National Wildlife Board and the Government of India is patently illegal. There are established Rules, Regulations, and Policies to be followed before attempting to relocate scheduled species.
The following related observations and points are also critical:
In order to trap the crocodiles, cages have been set up illegally along the banks of the two ponds/impoundments, known as Dyke 3 and 4, which are close to the Tent City. These dykes are artificial water bodies created to stabilise the water released from the Sardar Sarovar Dam before it reaches the entry point of the main Narmada Canal. It is important to note that Narmada River is habitat of the crocodiles and the act of evacuating them will affect many other species (birds, reptiles, amphibians and fish) existing in this ecosystem. Further, even when the “Tent City” was planned no such threat was perceived or considered and the sudden action of relocating the crocodiles under the pretext of “Tourist Safety” is contentious. These actions will also destroy their homing, hunting, and breeding grounds and nests in and around the two ponds / impoundments, i.e. Dyke 3 and 4.
The capture and relocation of the crocodiles is being carried out hastily and mindlessly, without having any scientific or technical bases and strategic relocation plan. These acts also ignore the statutory procedures required for the relocation of scheduled species.
This act is in blatant violation of several laws of the land, including the following:
(1) The Wildlife (Protection) Act, 1972.
(2) Environmental Impact Assessment Notification, 2006 under the Environment (Protection) Act 1986.
(3) The Environment (Protection) Act 1986.
(4) The Wetlands (Conservation and Management) Rules, 2010.
Crocodylus palustris (Mugger or Marsh Crocodile) is categorized as nationally ‘Vulnerable’ subsequent to an assessment following IUCN criteria for threatened species (Da Silva & Lenin 2010) and has the highest legal protection in India as it is listed in Schedule I of the Indian Wildlife (Protection) Act 1972. The importance of this species is illustrated by the multiple legal and policy efforts that have been developed by the Government of India to protect the crocodile population. ‘Indian Crocodile Conservation Project’ was launched as early as the late 1960’s. Subsequently, the crocodile has been included in Appendix – I of Convention of International Trade in Endangered Species (CITES) and brought under Schedule – I of ‘The Wild Life (Protection) Act 1972’, meaning that any activity which is against the survival of the highly protected species without having been approved by the State Wildlife Board / National Wildlife Board and the Government of India is patently illegal.
The National Board for Wildlife has specific provisions in the the Wildlife (Protection) Act, 1972 under the following sections:
“S 33 (a): No construction of commercial lodges, hotels… shall be undertaken except with the prior approval of the National Board.
S 35 (6): No destruction, removal of wildlife or forest produce from a National Park or diversion of habitat unless State Government in consultation with the National Board authorizes the issue of such permit.” It is important to note here that the species is protected under ‘The Wildlife (Protection) Act, 1972’. Thus, there is a clear violation of ‘The Wildlife (Protection) Act, 1972’ as the said activity would amount to “hunting” as defined in Sec. 2 (16) of the said Act as follows:
(1) “(16) “Hunting” with its grammatical variations and cognate expressions, includes:
(2) (a) Killing or poisoning of any wild animal or captive animal and every attempt to do so;
(3) (b) Capturing, coursing, snaring, trapping, driving or baiting any wild or captive animal and every attempt to do so;
(4) (c) Injuring or destroying or taking any part of the body or any such animal or in the case of wild birds or reptiles, damaging the eggs or such birds or reptiles, or disturbing the eggs or nests of such birds or reptiles.”
The species was threatened in the past by unregulated hunting for its skins, but now the threats come from habitat degradation and destruction. Further, this is an unscientific and non pragmatic step/action taken by the Gujarat State Forest Department/Authority without opinions of any crocodile expert/herpetologists.
A well worked out operation plan based on scientific studies and techniques along with a monitoring and evaluation plan are required prior to translocation. Also, release site should be identified and each animal should be tagged prior to release to monitor their movements and avoid related negative consequences. Advice and involvement of team of expert of crocodiles is a must. Translocation and rehabilitation of crocodiles must be carried out only after expert opinion from Crocodile Specialist Group and Wildlife Institute of India is sought. In fact, the relocation activity can never be done without it being approved by the State Wildlife Board / National Wildlife Board.
The concerned authorities should reconsider its translocation activities and comply with scientific guidelines and advice as well as legal issues for addressing this eco-sensitive issue.
We expect your prompt and positive response in the interest of life, livelihoods, and environment of all the concerned areas and species.
If you do not act now, your inaction shall be considered as non-compliance of ‘The Wildlife (Protection) Act, 1972’ and may / will invite legal action.***References:
- Basu, D. 2006. Report on mugger Crocodylus palustris conflict vis-à-vis initiation of water sports in dyke-lakes of Sardar Sarover Project, District Rajpipal, Gujarat. Crocodile Project, Uttar Pradesh Forest Department, Lucknow,10 pp (Unpublished Report).
- Campbell HA, Dwyer RG, Irwin TR, Franklin CE (2013) Home Range Utilisation and Long-Range Movement of Estuarine Crocodiles during the Breeding and Nesting Season. PLoS ONE 8(5): e62127. doi:10.1371/journal.pone.0062127
- Da Silva, A. and Lenin, J. (2010). Mugger Crocodile Crocodylus palustris. Pp. 94-98 in Crocodiles. Status Survey and Conservation Action Plan. Third Edition, ed. by S.C. Manolis and C. Stevenson. Crocodile Specialist Group: Darwin.
- Read MA, Grigg GC, Irwin SR, Shanahan D, Franklin CE (2007) Satellite Tracking Reveals Long Distance Coastal Travel and Homing by Translocated Estuarine Crocodiles, Crocodylus porosus. PLoS ONE 2(9): e949. doi:10.1371/journal.pone.0000949
- Vyas, R. and S. Bhatt. (2004). The mugger (Crocodylus palustris) population, problems, panic and rescue operation in and around Vadodara City. CSG Newsletter23(3):6-9
- Vyas, R. (2010). The Muggers (Crocodylus palustris) of Vishwamitri River: Past and Present. Herpetology & Environmental Research Project (HERP), Vadodara, Gujarat State, March 2010: 32pp+ Fig.5+Table 11+ i-xxi.