Odisha Human Rights Commission Orders Probe Into Defective Village Relocation Near Satkosia Tiger Reserve
The Odisha Human Rights Commission (OHRC) has directed the state government to constitute a high-level inquiry committee within four weeks to investigate irregularities in the relocation of villages near the Satkosia Tiger Reserve in Angul district, Odisha.
The OHRC acted on complaints filed by residents of Bhurukundi, Asanbahal, Kataranga, Tuluka, Tikarapada, Gopalpur, and adjoining villages, alleging violations of their basic human rights during the relocation process.
The Commission termed the relocation processes "defective" and recommended that the inquiry committee identify officers responsible for violations and recommend both departmental and criminal action where warranted.
The recommended committee composition includes the Secretary (Forest and Environment Department) along with Secretaries of ST & SC Development, Revenue & Disaster Management, and Law departments, plus one independent expert with knowledge of wildlife law, the Forest Rights Act 2006, and rehabilitation policy.
The Chief Secretary has been directed to submit a compliance report regarding the committee's formation within six weeks.
Forest Rights Act, 2006: Section 4(2) on Relocation from Critical Wildlife Habitats
The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 (FRA) is a landmark legislation that recognises the historical injustice done to forest-dwelling communities. Section 4(2) specifically governs the conditions under which forest rights holders can be relocated from Critical Wildlife Habitats (CWHs) within National Parks and Wildlife Sanctuaries.
The OHRC's order to probe "defective processes" directly implicates potential violations of Section 4(2) — specifically whether Gram Sabha consent was properly obtained, whether forest rights recognition was completed before relocation, and whether resettlement facilities were in place before displacement.
National Tiger Conservation Authority (NTCA): Relocation Guidelines
The NTCA, constituted under Section 38L of the Wildlife (Protection) Act, 1972 (inserted by the 2006 amendment), is the apex body for tiger conservation in India. It has issued specific guidelines for the voluntary relocation of villages from core/critical tiger habitats, which must be followed in conjunction with the FRA provisions.
The probe ordered by OHRC will likely examine whether NTCA's voluntary relocation guidelines were followed at Satkosia — specifically whether consent was genuinely voluntary, whether the rehabilitation package was implemented before displacement, and whether post-relocation commitments were honoured.
Satkosia Tiger Reserve: Odisha's Key Conservation Area
Satkosia Tiger Reserve is situated in the Angul and Nayagarh districts of Odisha, centred around the Satkosia Gorge, a 22-km-long gorge carved by the Mahanadi River. The area was first declared a wildlife sanctuary in 1976 and was notified as a tiger reserve in 2007.
Key Details
- Total area: approximately 963.87 sq km (core area: 523.61 sq km)
- Located along the Mahanadi River gorge, extending from Sunakhania village (Boudh district) to Badmul village downstream
- Key species: tiger, leopard, elephant, gaur, chousingha (four-horned antelope), sloth bear, wild dog (dhole)
- Notable for reptilian species: gharial (Critically Endangered, IUCN), mugger crocodile, Chitra indica (narrow-headed softshell turtle), and Indian softshell turtle
- Tiger reintroduction efforts have faced setbacks — a tigress named Sundari, translocated from Madhya Pradesh in 2018, was subsequently relocated back due to conflict with local communities
- Odisha has two tiger reserves: Satkosia and Similipal (the latter being the primary tiger habitat in the state)
The Satkosia Tiger Reserve's history of human-wildlife conflict and difficulties with tiger reintroduction makes the relocation process especially sensitive. The OHRC probe reflects the broader national tension between tiger conservation imperatives and tribal rights.
Gram Sabha: Constitutional and Statutory Authority in Tribal Areas
The Gram Sabha, defined under the Panchayats (Extension to Scheduled Areas) Act, 1996 (PESA), is the assembly of all adult members of a village. In the context of forest rights and relocation, the Gram Sabha is both the initial authority for recognising forest rights (under FRA Section 6) and the body whose Free, Prior, and Informed Consent (FPIC) is mandatory before any relocation.
The complaints from affected villagers suggest that the Gram Sabha consent requirement under FRA Section 4(2) may not have been properly followed during the relocation from Satkosia. The OHRC's inclusion of an independent expert on FRA in the inquiry committee signals the centrality of Gram Sabha consent to this investigation.
- Satkosia Tiger Reserve: established 2007 (sanctuary since 1976); area approximately 963.87 sq km; core area 523.61 sq km; Angul and Nayagarh districts, Odisha
- Satkosia Gorge: 22-km gorge carved by the Mahanadi River
- FRA 2006, Section 4(2): mandates Gram Sabha FPIC, completed rights recognition, and ready resettlement facilities before any relocation from CWH
- NTCA: constituted under Section 38L of WLPA, 1972 (2006 amendment)
- PESA Act: 1996; extends Part IX of Constitution to Fifth Schedule areas
- Affected villages: Bhurukundi, Asanbahal, Kataranga, Tuluka, Tikarapada, Gopalpur
- OHRC directive: form inquiry committee within 4 weeks; compliance report within 6 weeks
- Odisha's tiger reserves: Satkosia (Angul-Nayagarh) and Similipal (Mayurbhanj)