All kinds of commercial extraction from forests ought to be brought under strict moratorium


Memorandum by Sagar Rabari, General Secretary, Khedut Samaj-Gujarat to Noyal Thomas, Dy Inspector General of Forests (Forest Policy), Government of India, Ministry of Environment & Forests and Climate Change, New Delhi on the Draft National Forest Policy dated 14th March 2018:

We, the Khedut Samaj-Gujarat (KS-G) are a 1,00,000-strong membership-based organisation of farmers and agriculturists of Gujarat. We are writing to you in connection with the Draft National Forest Policy dated 14th March 2018 put up for discussion and debate. Here are our comments on the same. We hope that you would positively consider the same.

We would like to submit that a time period of one month is not sufficient to debate this important piece of proposed legislation. We would request you to extend this period for another month so that more groups on the ground may be made aware of the same for a more meaningful discussion to emerge.

  1. In the section on Goals and Objectives there is a mention of the extent of forest cover that is to be maintained at all times (one third nationally and two thirds in mountainous and hilly regions) which is a belated but welcome admission of the need to maintain a minimum of forest cover. This will perforce also entail that other uses of land such as agriculture, industry, urban etc. be also thus fixed. In short, a land use policy at the national level is called for as a corollary to this proposed policy.
  2. The noble goal of ‘maintaining’ the existing forest cover while bringing more area under plantation to increase the same calls for a moratorium on any sale, lease or diversion, for any purpose, of forest land. As of now the policy does not mention this at all. Without a moratorium on such diversion of forest land it would be impossible to increase the forest cover.
  3. The ‘strategy’ appears to prioritise commercial forestry and views forest as a ‘resource’ and is thus in direct contradiction to the preamble and goals and objectives of the Draft Policy. Forests ought not to be treated as a ‘resource’ but as a heritage and cared for this. Only then will the national goal of rejuvenation of forests be met. Hence any and all kind of commercial extraction from forests ought to be brought under a strict moratorium. Any public private partnerships (PPPs) ought not to be entertained in this regard. Forests must remain within the public domain only. “Production Forestry” (4.2.1) thus ought not to be considered.
  4. The policy does not mention Adivasis/STs in the management and planning of the forests except as beneficiaries. This is blatantly unjust and unfair. They should be considered as the prime stakeholders in any policy regarding forests and their maintenance and rejuvenation as per the provisions of PESA, 1996 and FRA, 2006. Till FRA applications are not decided upon this policy cannot be implemented. In this connection it would be useful to re-examine the Preamble to the Forest Rights Act 2006 which remains relevant and ought to guide the present policy also.

An Act to recognize and vest the forest rights and occupation in forest land in forest dwelling Scheduled Tribes and other traditional forest dwellers who have been residing in such forests for generations but whose rights could not be recorded; to provide for a framework for recording the forest rights so vested and the nature of evidence required for such recognition and vesting in respect of forest land.

WHEREAS the recognised rights of the forest dwelling Scheduled Tribes and other traditional forest dwellers include the responsibilities and authority for sustainable use, conservation of biodiversity and maintenance of ecological balance and thereby strengthening the conservation regime of the forests while ensuring livelihood and food security of the forest dwellings Scheduled Tribes and other traditional forest dwellers;

AND WHEREAS the forest rights on ancestral lands and their habitat were not adequately recognised in the consolidation of State forests during the colonial period as well as in independent India resulting in historical injustice to the forest dwelling Scheduled Tribes and other traditional forest dwellers who are integral to the very survival and sustainability of the forest ecosystem;

AND WHEREAS it has become necessary to address the long standing insecurity of tenurial and access rights of forest dwelling Scheduled Tribes and other traditional forest dwellers including those who were forced to relocate their dwelling due to State development interventions.


  1. As above, the role of PESA and the panchayats (in non-scheduled areas) is not even mentioned. Panchayats (both in scheduled and non-scheduled areas) and ULBs (in urban and peri-urban areas) should be brought into the management regime of forests. In fact, we would submit that they should have a decisive role with adequate control over finances and functionaries, and most importantly, the forest department in this matter.
  2. The role of Forest Department, which is hugely problematic and is a constant bone of contention for the tribals, is not delineated. It needs to be spelt out clearly. It is also an opportune moment to reassess its relevance seventy years after independence from colonial rule. We need to recognize that the Forest Department was a colonial creation for meeting the needs of colonial extraction of revenue and it runs much the same way even in drastically changed circumstances. The powers of the Forest Department thus need to be curtailed and they need to be brought under the jurisdiction of ULBs and gram panchayats and gram sabhas.
  3. In point 4.1.1 (a) “Reducing Threats to Forests” there are various threats mentioned (encroachments, illegal tree fellings, forests fires, invasive weeds, grazing). However, the policy is quiet on the most important threats to forests viz. industry and mining. This ought to be rectified.
  4. In point 4.2.2 “Economic Valuation of the Forests” stops short of saying that “Scientific methods will be evolved for appropriate valuation of forests and their services through institutions of repute.” However it is silent on responsibility and culpability of the entity or individual that destroys forests.
  5. Looking at future plans of developing Private Ports along coastline, will all that mangrove forest like Sundavan be given on PPP model for deforestation and afforestation Furthermore, mangroves perform several valuable, indeed even priceless, ecological services such as : prevention of coastal erosion, natural protection against cyclones and tsunami etc. Destruction of natural mangroves would destroy the coast and render the population there vulnerable to such disasters. How does this policy fix responsibility for such calamities? Should not such calamities be treated as human made? The entire Sagarmala project would ruin the coastline of India and the populations residing there. In light of this mangroves should be treated as sacrosanct and not be distributed at all.
  6. Point 4.2.5 “Integrate climate change concerns & REDD+ strategies in forest management” sub-point (e) mentions that “Steps would be taken for promotion of wood technology innovations and enterprises. Intensive marketing and branding campaigns such as “Wood Is Good”, “Grow more wood- use more wood” will be taken up for promotion of growing trees and usage of wood products.” This appears to be entirely concerned with the promotion of commercial forestry and revenue generation and has nothing to do with preservation and rejuvenation of forests. This ought to be removed.
  7. Point 4.2.6 mentions “Develop a national forest ecosystems management information system”. But the policy statement is silent on making the same available to the public, putting it in the public domain and opening it to public and academic scrutiny.
  8. Point 4.8 “Legal and institutional frameworks” proposes establishing a “National Board of Forestry headed by the central minister in-charge of forests and State Boards of Forestry headed by state minister in-charge of forests” to ensure “inter-sectoral convergence, simplification of procedures, conflict resolution and periodic review.” However, as mentioned earlier the management of forests is heavily bureaucratised and the need is for simplifying the existing institutional arrangements and paring down its authoritarian control, not complicating it and adding to its heft.
  9. Some of our most important concerns also pertain to the source of funds mentioned in the Draft Policy document. It says that (among others)

“4.10.3 The Compensatory Afforestation fund which is being transferred to the states would be a major source of funds for taking up Afforestation & rehabilitation works in degraded forest areas as well as for bringing new areas under forest & tree cover.

“4.10.4 Efforts for tapping funds from other national sectors like Rural Development, Tribal Affairs, National Highways, Railways, Coal, Mines, Power, etc., will be taken for appropriate implementation of linking greening with infrastructure and other development activities.”

This appears to be a blatant and shame-faced attempt at surreptitiously diverting the CAMPA funds towards corporate efforts to undertake afforestation. In other words, the money that came from the corporates will be given back to them. Why should industry be given public money to undertake afforestation (as is being implied in the Draft Policy) when they have destroyed them in the first place? We would go so far as to suggest that these funds should be put under the direct control of Gram Sabhas to carry out afforestation programmes.

Moreover, the mention of “tapping funds” from other sectors reeks of diverting funds from the SC Special Component Plan and Tribal Sub-Plan. This must not be done under any circumstances. Else it needs to be clarified which funds from those ministries will be used for this purpose. At the very least it needs to be stated that the SC Special Component Plan and Tribal Sub-Plan funds will not be touched for this purpose.

  1. The policy also talks of “Harmonization (of the Forest Policy) with other policies and laws” (point 4.11). This appears to be another name for “single window clearance” for corporates, as is done routinely to “attract big capital”. However, there appears to be no logical connection to such harmonizing and preservation of forests; the two are mutually exclusive and not dependent on each other. Furthermore, it states that “As far as community forest resources management under Forest rights Act is concerned, the new policy will address the same under participatory forest management and the same will be addressed through the proposed community forest management mission.” This is a blatant attempt at replacing the important pieces of progressive legislation of PESA viz. community forest rights with the bureaucratic PFM. Such dilution of PESA is absolutely uncalled for and ought to be dropped.

We request to drop this policy; held public hearings in all states with people dependant on forest before reaching any conclusion. Only economic valuation does not apply to forest, there are emotions, ecology and environment too are associated with forest.


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