Purposive interpretation of wildlife law brings Chiru hair shawls within the ban on scheduled animal articles.

Shawls made from the hair of the Tibetan Antelope (Chiru) were construed as falling within the Wildlife (Protection) Act, 1972. Reading the definitions of "animal article", "trophy", "uncured trophy", "scheduled animal" and "scheduled animal article" together with the prohibition scheme in Chapter VA, the Court applied purposive construction and rejected a narrow literal reading that would exclude hair merely because it is mentioned in the definition of "trophy". It treated the statutory exclusions as exhaustive and held that an article made from Chiru hair is derived from a scheduled animal and is therefore prohibited.

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Issues: Whether shawls made from the hair of the Tibetan Antelope (Chiru) fall within the expressions "animal article" and "scheduled animal article" under the Wildlife (Protection) Act, 1972, and are therefore covered by the statutory prohibition on trade.

Analysis: The definitions in the Act were read as part of a connected scheme. The expressions "animal article", "trophy", "uncured trophy", "scheduled animal" and "scheduled animal article" were construed together, along with the prohibition provisions in Chapter VA, to determine legislative intent. The Court applied purposive construction and rejected a narrow literal reading that would exclude hair merely because it is specifically mentioned in the definition of "trophy". It held that such a construction would defeat the object of the Act, create anomalies, and make the prohibition ineffective. The statutory exclusions were treated as exhaustive, and hair was not among the excluded categories. On that basis, an article made from Chiru hair, including shahtoosh shawls, was held to be derived from a scheduled animal and therefore prohibited.

Conclusion: Shahtoosh shawls made from Chiru hair are covered by the statutory definitions and fall within the prohibition on dealings in scheduled animal articles. The writ petition fails.

Ratio Decidendi: Where a wildlife statute uses connected definitions and a prohibition scheme to protect scheduled animals, an article made from a part or derivative of such an animal is covered if exclusion of that part would defeat the legislative purpose; the statutory text must be construed purposively to give effect to the ban.

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