New Dellhi/Dehradun: Senior Indian Forest Service (IFS) officer Sanjiv Chaturvedi has sought the withdrawal of two Uttarakhand government orders concerning postings and additional charges in the state forest department, alleging that the arrangements may violate cadre rules and create conflicts between administrative, commercial and regulatory responsibilities.
In a representation dated September 2, addressed to R K Sudhanshu, Principal Secretary (Forest), Chaturvedi challenged orders issued on April 13 and August 5. He raised concerns over the allocation of multiple senior responsibilities to individual officers and the possible implications for administrative accountability, statutory oversight and regulatory independence.
2002 batch IFS officer of Uttarakhand cadre, Mr Chaturvedi clarified that his objections were directed at the administrative arrangements rather than at any individual officer. His representation focuses on whether the existing distribution of responsibilities complies with applicable rules and safeguards the independence of institutions entrusted with wildlife protection, forest management and biodiversity regulation.
Neena Grewal’s Multiple Charges Raise Questions Over Regulatory Independence
One of the principal objections raised by Chaturvedi concerns the posting of 1993-batch IFS officer Neena Grewal as Principal Chief Conservator of Forests (Wildlife), while she continues to hold additional charge as Chief Wildlife Warden and Managing Director of the Uttarakhand Forest Development Corporation.
Chaturvedi has questioned the concentration of these three responsibilities in one officer, arguing that it could violate rules governing the assignment of additional charges and create a potential conflict of interest between commercial operations and statutory regulatory functions.
The Uttarakhand Forest Development Corporation undertakes commercial activities, including timber extraction and riverbed mining. In contrast, the Chief Wildlife Warden exercises statutory and regulatory powers relating to wildlife conservation and protected areas.
According to Chaturvedi’s representation, placing the management of commercial forestry activities and wildlife regulation under the same officer could compromise the separation between activities that may require regulatory scrutiny and the authority responsible for overseeing their legality.
He has also questioned the arrangement under which the same officer could be involved in overseeing wildlife-related projects while being responsible for independently assessing whether those projects comply with applicable legal and environmental requirements.
The central concern, as outlined in the representation, is that administrative arrangements should preserve the independence of regulatory decision-making, particularly where commercial operations and wildlife conservation responsibilities intersect.
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Corbett Tiger Reserve and Pakhro Tiger Safari Case Cited
Chaturvedi has also referred to Supreme Court proceedings concerning illegal tree felling and construction associated with the Pakhro Tiger Safari project in Corbett Tiger Reserve.
The reference highlights the importance of independent oversight in matters involving protected forests, wildlife conservation and compliance with judicial directions. Chaturvedi argued that the allocation of responsibilities should ensure that wildlife-related projects are examined independently and that the authorities responsible for regulatory supervision can discharge their duties without potential conflicts arising from overlapping administrative roles.
The Pakhro Tiger Safari controversy has brought scrutiny to forest management and compliance issues in the Corbett landscape. In this context, Chaturvedi’s representation raises questions about whether the existing administrative structure provides adequate institutional separation between project-related responsibilities and regulatory supervision.
His argument is that the independence of the oversight mechanism becomes particularly important when projects are subject to judicial scrutiny and require adherence to specific court directions.
Potential Self-Appraisal Issue in Wildlife Administration
Another issue flagged in the representation concerns the annual performance appraisal system for senior forest officers.
Chaturvedi referred to a 2021 state government order under which the Principal Chief Conservator of Forests (Wildlife) serves as the reporting officer for the Chief Wildlife Warden’s annual performance appraisal.
Since Neena Grewal holds both positions, Chaturvedi argued that the arrangement could effectively result in an officer assessing her own performance. He described this as an administrative anomaly that requires examination.
The objection raises a broader question about the compatibility of overlapping appointments with established reporting and accountability mechanisms. Performance appraisal arrangements are intended to provide an appropriate supervisory assessment of an officer’s work. When the reporting and assessed positions are held by the same person, the intended separation of responsibilities may be undermined.
Chaturvedi’s representation therefore seeks attention to the practical consequences of combining the two posts, in addition to the questions surrounding the legality of assigning multiple charges.
S P Subudhi’s Additional Charge as Biodiversity Board Chairman Questioned
Chaturvedi has also questioned the April 13 government order assigning S P Subudhi, Principal Chief Conservator of Forests (Van Panchayat), the additional charge of Chairman of the Uttarakhand Biodiversity Board.
His objection centres on the relationship between the responsibilities of Van Panchayats and the regulatory functions of the Biodiversity Board.
Van Panchayats play a role in the management of community forests and associated natural resources. The Uttarakhand Biodiversity Board, meanwhile, performs regulatory functions relating to access to biological resources and associated biodiversity governance.
According to Chaturvedi, assigning both responsibilities to the same officer could create a potential conflict between the management of resources through Van Panchayats and the regulatory oversight exercised by the Biodiversity Board.
The concern is whether an officer responsible for one institutional framework should simultaneously lead a body that regulates matters involving the same or related biological resources. Chaturvedi has argued that such arrangements warrant scrutiny to ensure that management responsibilities do not compromise the independence of regulatory functions.
The objection adds another dimension to his broader argument that senior-level postings should be structured in a manner that avoids overlapping responsibilities where the functions of different institutions may intersect.
B K Gangte’s Appointment to Uttarakhand CAMPA Also Under Scrutiny
The representation further raises questions about B K Gangte’s appointment as the ex-cadre Chief Executive Officer (CEO) of Uttarakhand’s Compensatory Afforestation Fund Management and Planning Authority (CAMPA), while he holds additional charge as Additional Principal Chief Conservator of Forests (Research, Management and Training).
Chaturvedi has sought clarity on the cadre status of the CEO position, the applicable pay levels and the permissible number of such senior deputation posts.
The issue concerns the administrative framework governing ex-cadre appointments and the allocation of senior-level responsibilities. Chaturvedi’s representation questions whether the appointment and accompanying additional charge conform to the relevant service and cadre provisions.
By seeking clarification on the post’s status, pay structure and the number of permissible senior deputation positions, he has called for greater clarity on the rules governing such appointments.
The issue is distinct from the potential conflicts of interest raised in the wildlife and biodiversity cases, but it forms part of the same representation challenging the administrative arrangements reflected in the two government orders.
Chaturvedi Seeks Withdrawal of Orders Issued on April 13 and August 5
Through his September 2 representation, Chaturvedi has sought the withdrawal of the two government orders and raised questions concerning the applicable service rules, the assignment of additional charges and the separation of administrative and regulatory responsibilities.
The issues identified in the representation span several areas of the forest administration: wildlife protection, commercial forestry, biodiversity regulation, community forest management, performance appraisal and senior deputation appointments.
Taken together, his objections call for an examination of whether multiple responsibilities can be assigned to the same officer when the posts involve potentially intersecting functions or require independent supervision.
The representation does not merely question individual postings. It focuses on the institutional safeguards needed to maintain accountability, prevent conflicts of interest and ensure that statutory responsibilities are discharged independently.
As of the time of reporting, no formal response from the Uttarakhand forest authorities was available. The state’s position on the objections, including whether the challenged orders will be reviewed or withdrawn, therefore remains unknown.
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