Bengaluru: India should not import endangered wildlife anymore until it conducts ‘due diligence’ while issuing permits and implements several recommendations to this effect, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) has held after an investigation into animal transfers at Vantara, Reliance’s zoo cum rescue centre.A team from CITES – a multilateral treaty that ensures that trade in endangered species does not threaten their survival – visited the Jamnagar-based facility between September 15 and 20 this year. The inspection was prompted by allegations of discrepancies in the imports of wild animals to Vantara from countries including Congo and Mexico, and investigative news reports that Vantara’s demand for endangered wildlife may have fuelled illegal wildlife trade. On August 25 this year, India’s Supreme Court constituted a Special Investigation Team which included former Supreme Court Justice, J. Chelameshwar, to look into allegations about Vantara. On September 15, the top court absolved Vantara of any wrongdoing. It held that the SIT report had found “no foul play” and that all animal transfers were “carried out in regulatory compliance”. The court also said that they were “closing the matter” and would not entertain any more “objections” to the facility in these regards.A CITES document published earlier this week raised several questions about animal transfers to Vantara and said that India did not conduct ‘due diligence’ while issuing import permits for several transfers to the facility. The CITES investigation revealed numerous concerns in the transfers of wild animals including a lone mountain gorilla from Haiti, chimpanzees from Congo and an orangutan, the document showed. It also mentioned instances of how the Indian government used the recent ‘clean chit’ given to Vantara by the Supreme Court to state that Vantara’s wild animal imports were in order. The CITES has now asked India to get its act together: it has recommended that India not issue any more import permits until it follows due diligent processes and implements CITES recommendations. India has to submit a report about this to the CITES before its 81st Standing Committee meeting.Vantara, in a press release on November 4, has claimed that the CITES gave “a clean chit” to the facility, and that it had noted that all animal transfers to the facility were “fully legitimate and transparent, in accordance with Indian law”. The Wire has written to Vantara for clarifications about this, and also approached the Indian CITES Management Authority (the Union environment ministry), and members of the Supreme Court-appointed SIT for comments. This story will be updated when responses are received.A CITES visit to VantaraVantara, comprising two entities – the Greens Zoological Rescue and Rehabilitation Centre (GZRRC) and its allied Radhe Krishna Temple Elephant Welfare Trust (RKTEWT) – is a facility in Jamnagar, Gujarat, run by Anant Ambani, son of billionaire Mukesh Ambani who heads the Reliance Group. The centre has imported wild animals from other countries that were allegedly in need of “rescue”. News reports such as this one have questioned this. Currently, as per its last available annual report (2023-24), the GZRRC is officially home to 10,360 such ‘rescued’ animals of 345 species.However, an investigative news report by German daily Süddeutsche Zeitung in March this year pegged the number of animals in Vantara at at least 39,000 by December 2024. The report, along with several others such as this one, have alleged that Vantara paid huge sums of money for these animals. Creating such a monetised demand for wild animals had resulted in animals being plucked out from their native habitats, fuelling illegal wildlife trade, the reports said. But this is “baseless” and “misleading”, and all its transfers had proper documentation, Vantara told The Wire in March this year.The issue, however, crept into the meetings of the CITES, the Convention on International Trade in Endangered Species of Wild Fauna and Flora. The Convention, which India is also signatory to, ensures that the international trade in endangered plants and animals does not threaten their survival. For this, it regulates trade in wild species worldwide. For example, member countries are not permitted to trade in animals and plants listed in Appendix-I of CITES, unless under very special circumstances.India has become the source of a lot of such international transfers in recent times. In November 2023, the 77th CITES Standing Committee meeting at Geneva discussed the trade in live animals to India in great detail. The CITES Secretariat said it received information from several sources – including some in Mexico and the Central, South America and Caribbean region – “expressing concerns about the legality of those transactions and the methods used to obtain CITES documents”, as The Wire reported in March this year. However, claiming that India had a “robust system” to ensure the CITES provisions are followed for all animal transfers, India also said it was ready to provide assistance for the CITES Secretariat to visit Vantara and inspect it.That inspection by the CITES team occurred between September 15 and 20 this year. The team from the CITES Secretariat also met representatives from the Ministry of Environment, Forest and Climate Change whose Director General of Forests & Special Secretary is the Indian CITES Management Authority (which can grant permits for animal transfers), members of the Wildlife Crime Control Bureau (Regional Deputy Directors of the WCCB are designated as Assistant CITES Management Authorities), the Central Zoo Authority (which is a CITES Scientific Authority), the Customs Administration of India and several other Union government departments. Earlier this week, the CITES published a “compliance document” about this investigation, listing its findings and recommendations. These are the highlights:Several animal transfers to Vantara raised concerns. These included the use of wrong codes for transfers, how the export and import numbers of animals under some permits did not tally, and more.India – specifically, the Indian CITES Management Authority – did not conduct ‘due diligence’ in verifying the sources of wild animals and issuing import permits. India even issued import permits on the basis of forged export permits from Cameroon to bring in eight chimpanzees to Vantara. According to CITES, India should not issue any more import permits for wild animals from other countries until it has fully implemented CITES recommendationsIndia has to submit a report to the CITES before the 81st meeting of the Standing Committee about how it is implementing these recommendations.Import concernsThe CITES compliance document said that while it has “not found evidence of animals being imported to India without CITES export permits or re-export certificates and, for Appendix-I species, import permits”, several imports “still raise questions regarding the origin of the specimens”, the application of exemptions to these animals’ trade, the use of source and purpose-of-transaction codes, and “the exercise of due diligence by India”.One concern, for instance, is the wrong usage of CITES codes for animal transfers. The CITES assigns codes to animal transfers to identify their source and purpose of transfer. For instance, Source Code ‘C’ refers to animals bred in captivity, and Purpose-Of-Transaction Code ‘T’ means for a commercial purpose while ‘B’ means the animals are being transferred for breeding purposes.“Various imports raise questions, particularly with regard to the origin of the specimens concerned and/or the source and purpose codes used for the transactions,” the CITES report noted.In the case of a transfer of nine chimpanzees to Vantara, the export permit from the Democratic Republic of the Congo stated that all were “in captivity (Source C)”. However, the CITES pointed out that the fact that the animals “are” in captivity is not sufficient to justify the use of source code C – they have to be bred in captivity.“The Secretariat is of the view that the exercise of due diligence by India would have allowed to clarify the situation and obtain full traceability of the specimens prior to the export,” CITES noted.The CITES also said that “questions could be raised regarding the imports of 54 specimens traded under source code I”. Source code I refers to confiscated or seized animals. These 54 animals include 10 jaguars, 10 ocelots, 10 margays and 10 jaguarundis declared seized and traded by Mexico, as well as 4 chimpanzees, one orangutan and 8 cheetahs traded by the United Arab Emirates and declared with unknown country-of-origin.Some animals that came into India listed as “captive-bred”, therefore, may not have been captive-bred: so one possibility is that they were collected from the wild. The CITES also said that there was a need to clarify how the GZRRC and RKTEWT acquired some specimens and the codes used for this trade. “Complying with these conditions is essential to ensure that the operations of the GZRRC and RKTEWT do not inadvertently become a driver of illegal harvest of wild animals that are later declared as captive-bred,” CITES noted.Numbers do not tallyAnother concern was that some of the numbers of animals imported to India, and exported from their source countries, did not tally. One example is the import of African cheetahs from Mexico to Vantara. The number of animals cleared for export and import do not tally in different databases. For instance, the CITES Trade Database recorded an export of 14 cheetahs from Mexico to India (to Vantara). But the same database recorded an import of 24 cheetahs from Mexico. Meanwhile, the Indian CITES Management Authority cleared only 12 cheetahs for import into the country. And ultimately, none of these transfers took place, India later told CITES: no cheetahs had been imported from Mexico into India at all. So why was there a paper trail? The CITES has recommended that India update the CITES Trade Database on the status of transfers too. “The data provided by Parties in their annual reports should record the actual trade that took place, rather than issued permits, in order to provide a correct basis for monitoring the trade of CITES-listed species”, CITES said.The documentation of the lone mountain gorilla at Vantara also raised concerns about India’s lack of ‘due diligence’, the CITES inspection found. Vantara sourced this animal from the United Arab Emirates (UAE) in 2024. Its country of origin was Haiti, and it had a source code ‘C’ (bred in captivity). Haiti is not naturally home to mountain gorillas – so the animal had obviously come from elsewhere. Haiti is also not signatory to the CITES. There is also no record of the transfer of any gorilla species to Haiti in the CITES Trade Database, the CITES noted. According to the Indian CITES management authority, the justification for the import of the mountain gorilla was “the need for rescue of the animal from conflict and civil unrest in Haiti”.Nonetheless, “a higher degree of due diligence should be applied as this is an Appendix I species, declared with a non-Party and non-range State as country of origin, and traded under source code C”, the CITES said.A researcher who studies illegal wildlife trade but did not want to be named told The Wire that the need for rescued animals must be questioned, especially those of individuals of endangered species. “Why can’t these animals be housed close to their natural range where they might have a chance of being reintroduced back to the wild,” the researcher asked. “India should seriously consider putting a halt to such transfers.”Yet another concern was that some invoices of animal transfers into Vantara suggested that more money may have been involved than the usual amount it costs for insurance, freight and customs duties for the transfers. Imports from Czechia fall in this category, CITES said.“Invoices provided by the MA [Management Authority] of Czechia seem to contradict the claim that these exports involved only expenses associated with the cost of insurance, freight and customs duties, as indicated in the reply received from India,” it noted. What else did the expenses cover? The CITES did not specify.Vantara Now Home to 41,000+ animalsA press response from Vantara to The Wire in March this year had said that the German daily SZ’s claim that the GZRRC received more than 30,000 animals in a year was “deliberately misleading” and that the actual number of animals at the centre, as well as the numbers of each species, is publicly available in their annual report that is also published on the website of India’s Central Zoo Authority (CZA). The latest annual report available is for the year 2023-24. This document said the GZRRC was home to 10,360 wild animals of 345 species as of March 2024. The annual report for 2024-25 has not yet been uploaded on the CZA website.As per the CITES compliance report, as of September 11 this year, the GZRRC holds 41,839 animals and the RKTEWT holds 5,794 animals.The recent CITES compliance document also shows that Vantara has accepted wild animals that are not just bred in captivity. CITES Source CodeNumber of SpecimensC (Bred in Captivity)2,049I (Seized or Confiscated animals)54D (Appendix-I animals bred in captivity for commercial purposes)17F (Animals born in captivity)9W (Specimens taken from the wild)3Table: The source codes of Appendix-I species housed at Vantara. Data from CITES Compliance Document SC78 Doc. 6.3.4. However, in its communication to The Wire in March this year, Vantara had said that it only accepts animals classified as captive-bred by their CITES permits. The recent CITES compliance document shows that this is not true. No ‘due diligence’ by IndiaThe CITES document is clear: India did not conduct “due diligence” when it came to CITES regulatory mechanisms and thus potentially resulted in animals sourced from the wild being traded into the country. “However, several imports still raise questions regarding the origin of the specimens, the application of Article VII, paragraphs 4-5 [which deals with trade exemptions under special circumstances] and the use of source and purpose-of-transaction codes, and the exercise of due diligence by India,” the document noted.This lack of due diligence, the CITES document said, had occurred in a number of cases.For instance, the large number of imports of wild animals listed under Appendix-I of CITES to Vantara (including cheetahs, chimpanzees and orangutans) from countries that these animals are not usually found in, and do not conduct captive breeding of, “should have triggered additional due diligence from India” — but this was not done, CITES noted.Another instance was the import of a critically endangered Tapanuli Orangutan (Pongo tapanuliensis, an Appendix-I species under CITES) from the UAE to Vantara. Its country of origin was listed as Indonesia, and it had a source code ‘C’ – which means bred in captivity. But all three species of orangutans in the world are rare in breeding programmes, critically endangered, and endemic to Indonesia and Malaysia, the CITES noted: “Thus, it would have been important to implement strict and increased due diligence to verify that the specimen met the definition of “bred in captivity” in Resolution Conf. 10.16 (Rev. CoP19), and was not, in fact, a specimen of wild origin from Indonesia.”“More broadly, India should have exercised due diligence in cases of trade in species which are known not to breed well in captivity…Without exercising such due diligence, India runs the risks of importing animals, which may have been sourced from the wild and traded as captive-bred, or which have not been bred in captivity as defined in Resolution Conf. 10.16 (Rev. CoP19),” the CITES document noted. “For these reasons and considering the quantity of specimens being imported by the GZRRC and RKTEWT, it is advisable that India reviews as a matter of urgency its import procedures and implements much stronger due diligence procedures, based on a risk assessment to ensure that due diligence is exercised systematically and consistently in order to detect any irregularity prior to the issuance of import permits and shipment of animals,” it stated.Fake permitsThe CITES noted that the export permits issued by Cameroon for eight chimpanzees that were to arrive at Vantara were fake. This meant that India, without conducting ‘due diligence’, had issued import permits for this transfer without verifying the forged export permits, CITES said.The transfer, incidentally, did not happen because Vantara did not conduct it – because the entity at Cameroon “had not allowed the GZRRC representatives and veterinary experts to visit or inspect the animals and facility in question”. “The fake permits brought to the attention of the [CITES] Secretariat may suggest that the large number of acquisitions of live animals by the GZRRC and RKTEWT has attracted attention, and that certain individuals or entities could attempt to exploit this as a way to traffic animals. This shows that there is a need for caution to ensure that imports of large numbers of animals by these facilities are not inadvertently creating a demand for illegally sourced animals. Reinforced due diligence in this regard is crucial,” the CITES meeting minutes said.A contrast to India’s reportSo why is the stand of the CITES about imports of wild animals to Vantara significant for conservationists and concerned citizens? It is the result of an inspection by a CITES team (along with an independent, international zoo curator). And it found that there are numerous concerns about some animal transfers to the facility from other countries. This is entirely contradictory to what a supposedly similar Indian investigation of the same facility and documentation found just two months ago.The recent CITES compliance document shows that the Indian CITES Management Authority – the Director General of Forests and Special Secretary under the Union environment ministry – used the recent ‘clean chit’ by the Supreme Court to say that all animal acquisitions by Vantara were “carried out in regulatory compliance without any violation” of the provisions of any law in India, including the Wild Life (Protection) Act 1972 and the Prevention of Money Laundering Act 2002.“The Indian MA finally relied on another finding of the Supreme Court according to which “where animals are procured by “Donor Zoo” in accordance with the law applicable to them and transferred to Vantara entities, once the export is under a valid export permit, such transfer or donation cannot be treated as a contravention of Indian law or CITES,” the CITES document read.It also raises another important question: if the CITES inspection team unearthed so many concerns regarding animal transfers to Vantara that were permitted by India, why did the SIT that said that it had conducted a detailed investigation not discover these concerns too? One ecologist who has been following the issue but did not want to be named told The Wire that the CITES stand puts in “bad light” not only India’s regulatory agencies (such as the Indian CITES Management Authority under the Union environment ministry) but also the “honorable Supreme Court”.The Wire has written to the Union environment ministry, and members of the Supreme Court-appointed SIT for comments. This story will be updated if responses are received.India needs to take actionIndia appears to have accepted that more “due diligence” needs to be done. Indian CITES authorities have recognised that they were not fully aware of the conditions for the use of different codes for animal transfers, per the CITES. The CITES document also noted that the authorities “recognized that the due diligence implemented did not normally extend beyond the verification of the presence of an export permit or re-export certificate, and the verification of its authenticity and validity with the MA of the exporting/re-exporting country”.“Representatives from the Indian MA [Management Authority] and SA [Scientific Authority] expressed appreciation for the guidance provided on these issues and confirmed that they would work on improving their processes and procedures. The Indian MA has reiterated thiscommitment in writing in its submission to the Secretariat for the preparation of the present document. The management of the GZRRC and RKTEWT also indicated their willingness to be in full compliance with CITES and to develop their own due diligence approach,” the document read.India’s work in this regard is now cut out: CITES recommends that India not issue any more import permits until it follows due diligent processes and implements its recommendations. India has to submit a report about this to the CITES before its 81st Standing Committee meeting.According to CITES, there is also a need to clarify the mode of acquisition of the specimens by the GZRRC/ RKTEWT and codes used for such trade. ‘Clean chit’ to Vantara?Vantara, in a press release on November 4, claimed that the CITES gave “a clean chit” to the facility. However, the CITES compliance document does not say this.The Vantara press note had also claimed: “The [CITES] report stated that India’s wildlife protection and regulatory mechanisms meet international standards, and that Vantara is setting new benchmarks in animal conservation. CITES also observed that the Government of India has ensured that all animal import processes undertaken by GZRRC and RKTEWT are fully legitimate and transparent, in accordance with Indian law.”This, however, is not the entire picture. The Wire has written to Vantara for clarifications about these extrapolations of the CITES compliance document and the story will be updated if a response is received.Note: Justice Chelameshwar’s designation has been corrected with an update since publication.