‘Voluntary’ consent and why women in protected forest areas are challenging it

Forest and tiger conservation programmes are leading to the relocation and evictions of tribal communities from their homelands, forcing many to migrate to alien urban spaces, for their survival

Bhanumathi Kalluri

Residents of Karadikallu Hattur Kollehaadi gathered for their first Gram Sabha meeting as per the Forest Rights Act in Nagarhole on May 20. Pic credit: Sartaj Ali Barkat 

Earlier this month, the Jenu Kuruba tribal women and children in Nagarhole reserve of Karnataka dug their heels deep into their forest soil, braving police battalions, in a unique display of determination to reclaim their ancestral land. Their intent to return to their original home in Karadikallu Hattur Kollehaadi, after experiencing years of trauma of ‘voluntary’ relocation for the tiger project, raises several serious concerns about tribal women and the resultant impacts on women’s food security, livelihood and socio-legal entitlements. 

The Nagarhole national park, which was formed in 1983 and declared a critical tiger habitat in 2007, identified more than 33 tribal habitations for eviction to implement the forest department’s plan for conservation of tigers in the Nagarhole and Bandipur reserves. Most belonged to the Jen Kuruba and Yerawa tribes.

This formula of conservation implemented across the country, believes that tribal communities are a threat to the existence of wildlife, even when historically, tribals have been co-existing with wildlife and biodiversity in their forests. 

In Nagarhole, the tribals have been campaigning against these forced evictions under the banner of Nagarahole Adivasi Jammapale Hakku Sthapana Samiti for several years now with the Jenu Kurubas, a particularly vulnerable tribal group (PVTG) taking the lead.

Communities like the Jenu Kurubas whose traditional way of life and knowledge are strongly linked to protecting and utilising forest resources and having specialized skills in harnessing forest resources like honey, contend that it is not their way of life but other exploitative and urban demands that are destroying forests and wildlife.

An illustrated representation of Jenu Kuruba families carrying their belongings and pictures of those who died while they lived and worked on coffee plantations back to their ancestral land inside the Nagarhole forest, staking claim to where they should have rightfully been buried.  Illustration by Divya

Yet, given the global and national policy dominance and support to this forest conservation model, specifically being pushed by the National Tiger Conservation Authority (NTCA), evictions on a large scale in many states have resulted in tribal communities being thrown out of their homelands, scattered and forced into migration to alien urban spaces, for their survival. 

The most severe impacts of such forced relocations have been experienced by tribal women whose food security, spiritual, cultural and social agency is put to test when they are forced into daily wage labour outside, in contrast to their highly evolved customary practices of harnessing natural resources in the forest. 

Yet the NTCA persists in its mission of evictions and has, to this effect, intensified its act through an order to state governments in June 2024, instructing that they expedite the relocation of 64,801 families from 591 villages of 19 Tiger states living inside Critical Tiger Habitats. 

Despite wide opposition to these orders and important questions being raised regarding the NTCA’s guidelines related to the ‘voluntary’ nature of its evictions, the lack of scientific assessment of the threat to tigers from forest dwelling communities and legal violations experienced by tribals victimised by relocations, the forest departments have been receiving tacit support for forcibly evicting communities.

Vexed by the lack of the promised amenities and rehabilitation in relocated sites, and the long pending issues related to legal entitlements, communities who were forcibly evicted or coerced into relocation, are now demanding their entitlements. The Jenu Kurubas and particularly the women who have taken the brave journey back to their forest and their spiritual deities, are resonating the anger and demands of tribal women across tiger reserves in the country. 

Informed consent or coercion? 

The NTCA, in its 14 February 2025 rejoinder to a petition submitted by civil society groups for withdrawal of its relocation orders, repeatedly emphasizes that its guidelines adhere to all laws and relocations have been ‘purely voluntary’ in nature, after obtaining ‘prior informed consent’ from affected families. Dismissing the petition as being baseless, it further stresses that relocation happens on mutually agreed terms and conditions, with the informed consent of the Gram Sabha. 

Yet, the urgent question that needs to be asked is why the Jenu Kurubas and several other tribes across tiger reserves in the country, are challenging these ‘voluntary’ mechanisms of removing them from their ancestral homes in the forest.

At a workshop in April 2025, conducted by non-profits Dhaatri, Keystone Foundation, Centre for People’s Forestry and others, women from more than 20 Protected Areas (PAs), shared their agonizing experiences of ‘voluntary’ relocation. Their testimonies are examples of not only how constitutional laws have been disrespected, but also how women’s right to life, dignity and wellbeing have been compromised. 

Some of the examples that were presented are evidence of a blatant breach of women’s right to decision-making within their constitutional entitlements and their inaccessibility to mechanisms of grievance redressal when promises verbally given to them fell flat.

Even after years of relocation and eviction, rehabilitation remains poorly implemented, while their rights under various laws like the Panchayats Extension to Scheduled Areas Act of 1996 (PESA), the Forest Rights Act of 2006, the Wildlife Protection Amendment Act of 2006 and the right to fair compensation and transparency under the Land Acquisition, Rehabilitation and Resettlement Act of 2013  (LARR Act), and even the NTCA guidelines itself, remain violated. This is particularly true with respect to women, and more so, for women from PVTGs like the Jenu Kurubas, Chenchus, Kolams, Baigas and many others. 

Women from relocated villages near the Panna tiger reserve at a meeting for discussing forest rights and entitlements. Picture courtesy Dhaatri Resource Centre 

At the workshop, women from Panna tiger reserve narrated how elephants were let loose, electricity was disconnected, they were booked under false criminal cases for poisoning water bodies to pressurize them to ‘voluntarily’ relocate. The women were made to give their thumb impressions on documents that were either blank or they could not read the contents, bank accounts were opened and money was deposited into their accounts without their consultation, public hearings were conducted with large police battalions in an atmosphere of intimidation, and even while the women never raised their hands in consent, their silence and fear were read as consent. 

The intimidation continues even now, several years after they were moved. A recent raid was conducted by the forest personnel in Umravan village, which is in the buffer area, as reported by the women. While some of the widows’ houses were broken into in their absence, and all their cash and jewelry stolen, the women say that their representations for an investigation into the theft have been ignored, despite the Ministry of Tribal Affairs and the National Commission for the Scheduled Tribes (NCST) asking for an action taken report from the state government, in response to their petition.

This season they could not collect any mahua or chironjee as they spent all their time running around government offices seeking justice on the atrocity committed during the peak harvest season. They feel that these intimidation tactics are to force them to leave their village. While the NTCA states in its letter that its relocation order is only for the core zone villages, people living in buffer areas also face threats of eviction, as evident in this case.

In Uttarakhand’s Rajaji National Park, the women from the Van Gujjars stated that they were forced to leave their pastoral lands, with many not receiving permits for grazing their cattle. As a result, the women said they had lost all their sources of livelihood from dairy products, and their traditions of ‘Mai- the caretaker of animals, and Dai- the feeder of the animals’ had been severely impacted. 

No alternate livelihood opportunities were provided, despite the NTCA’s claim that “co-existence and secure livelihood options have been well practiced” and that “livelihood options have been available to the local people through various activities like SHGs, Eco-tourism.”

There is barely any evidence of displaced women receiving employment in these ‘eco-tourism’ safaris or any other sustainable livelihood opportunities. And even children forced to leave their homes and migrate, have ended up as child labour in hazardous informal sectors like mining and construction. 

Women from Tadoba, Bhimashankar and Melghat tiger reserves in Maharashtra testified how they were not informed about the project details in the notices served to them, not given an opportunity to get their forest rights claims settled, denied electricity, road and other basic facilities to put pressure on them for giving consent. In addition, the land given to them as compensation was uncultivable and they were given no prior opportunity to visit the land allocated before giving consent, which goes against norms mentioned in related laws.

In Telangana, Chenchu women reported that there was no notice given to them, no process of consent seeking or procedure of ‘rehabilitation’ followed. They were simply bundled into jeeps dead in the night, without any prior intimation. They were not even allowed to feed their children and were dumped at a roadside village with their belongings. Their houses and hand pumps were destroyed to ensure that they did not return to their native village.

In Odisha’s Similipal, as in all the other tiger reserves, women complained that they were denied basic facilities like drinking water, roads, electricity, school and government schemes like NREGA in order to break their resistance and ‘voluntarily’ leave. Their right to collect firewood is also criminalized, even as they are unable to use the LPG schemes. “Don’t we have a right to cook food for our families?” they asked.

When such primary rights are denied to them and they face constant harassment, the local communities are forced to give consent and ‘voluntarily’ agree to relocate, the terms and conditions of which, as laid out in the NTCA guidelines, are not adhered to.

In most sites, women reported that rehabilitation provided fell far short of the lucrative verbal promises provided at the time of forcing consent on them. People were relocated before completion of rehabilitation, as in the most recent relocation in Kawal tiger reserve of Telangana, in violation of law. Here unmarried women were not even considered eligible for compensation and hence, their right to give consent or to demand for entitlements, was simply dispensed with. The most accessible resource in relocated colonies is liquor shops, and not schools, hospitals or livelihood opportunities, as reported by the women.

Women in Kaimasan village in Panna, Madhya Pradesh, discuss the problems they face from the norms around the tiger reserve. Picture courtesy Dhaatri Resource Centre

In many tiger reserves, there is no ‘relocation’ in the buffer areas, but many restrictions are imposed. From prohibiting entry into their own agricultural lands, disallowing the collection of forest produce to restriction of grazing and wild-food gathering by fencing off lands within the boundaries of villages. Without any due processes of law in settlement of forest rights, compensation or formal land acquisition procedures being laid out, local people’s survival is made impossible, and hence, they feel compelled to migrate. 

The NTCA, in its rejoinder, claimed ignorance of what a fortress model of conservation is, even while it creates fenced fortresses of conservation where local people are denied entry. 

All the above examples, and there are many such in each tiger reserve affected area, demonstrate how the ‘voluntary’ nature of relocation has made survival impossible for these communities both in their ancestral lands and in relocated sites.

Destroying the livelihood and incomes of local communities forces them to migrate in search of wage labour outside. 

That the Jenu Kuruba women have been vexed with the ‘greener’ pastures outside their native village as promised to them, and have decided to reclaim their right to live in their forest, restore their traditional knowledge practices, honey collection being a unique expertise of this particularly vulnerable tribe, and demand for their constitutional rights to forest management, is a story of the post-colonial freedom struggles that  many marginalized communities have to put up, in order to exercise their fundamental rights within the constitution.

What is urgently required is an extensive audit, including gender audits, of all the tiger reserves to review the processes of ‘voluntary’ relocation, ‘prior informed consent of local people’ and ‘co-existence opportunities for livelihood’. 

Most of all, a thorough investigation needs to be conducted into the violation of the entitlements of women and children, their health, dignity and right to life which have been affected by these conservation projects. It is not only the women from the Jenu Kuruba tribe, but tribal and other forest dwelling women from all the Protected Areas in India who are resisting this model of fortress conservation. Conservation of forests and wildlife cannot be disconnected from the local communities who are integral to these habitats, and hence a community led conservation of co-existence should be adopted. 

Bhanumathi Kalluri works with tribal women on their forest rights, livelihood and food security and for gender equality in governance of natural resources.