When the Guardian Floats the Tender: Bhimbandh and the Conflict at the Heart of Eco-tourism

The Law Is Clear; the Gap Is Who Asks Permission

The commitment is written plainly into law. Section 33(a) of the Wild Life (Protection) Act, 1972 lets a sanctuary's managers build what the sanctuary needs. Its proviso then draws a hard line: no commercial tourist lodges, hotels, zoos or safari parks inside a sanctuary without the prior approval of the National Board for Wildlife (NBWL).

In February 2023, the Supreme Court went further and restrained new construction in tiger reserves, national parks and wildlife sanctuaries until further orders. The reported reality in Bhimbandh is a tender for exactly the kind of project the proviso covers.

What the tender proposes As reported, the Bihar Eco Tourism Development Society (BETDS)

• a body under the State Forest Department - floated a tender dated 16 October 2026 for facilities on 12.9 acres inside Bhimbandh Wildlife Sanctuary. The plan includes:
• a helipad, 104 cottages and 12 tree houses; - a restaurant, spa, banquet facilities and an auditorium for weddings and conferences; - buildings up to two or three storeys, at an investment of about ₹62.87 crore, under a 60-year concession. These are commercial lodges and banquet facilities in any ordinary reading of the term. That places them squarely within the proviso.

The two arguments that do not hold Land ownership. The project director, a Chief Conservator of Forests, reportedly said the land belongs to the tourism department and other government departments.

But Section 33(a) applies to construction inside a sanctuary, not on Forest Department land alone. A plot within the notified boundary does not escape the law because another department holds the title. Existing rights may continue; they do not become a licence for new commercial construction. Phasing. He also reportedly said work could start where clearances are not needed while waiting for the rest.

Splitting a single project into stages does not change what the whole project is, nor the approval it requires. The tender itself is reported to be inconsistent on this: one clause puts the responsibility for environmental permits on BETDS, another on the private developer.

Where the

chain actually breaks The weak link is not the law and not the courts. It is institutional design. The Forest Department is meant to apply Section 33(a) and here it is also the promoter. Weeks earlier, the same department signed and then cancelled an MoU to help a highway project obtain forest clearance, after it was flagged for conflict of interest.

When the regulator is also the developer, the person most responsible for seeking NBWL approval has a reason not to.

What works The system is not toothless.

The proviso exists, the 2023 restraint is in force and in March 2024 the Supreme Court halted the Pakhro tiger safari in Corbett over illegal felling and construction. Public scrutiny forced the highway MoU's cancellation within weeks.

For the exam, the insight to carry is this: protected-area law in India rarely fails in the text; it fails when the body meant to enforce it is also the body that benefits from bending it.