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Issues: Whether the State was required to implement the Centrally Sponsored Scheme for integrated wildlife habitat development and take immediate conservation measures for the protection of the wild buffalo.
Analysis: The statutory framework under the Wildlife (Protection) Act, 1972, read with the constitutional duty under Article 51A(g) and the State's obligation under Article 48A, places responsibility on the State to protect wildlife and its habitat. The Act recognises protected areas, including sanctuaries, conservation reserves and community reserves, and empowers the State to take measures for conservation and management of wildlife. Wild buffalo being included in Schedule I and being a highly endangered species, the Court treated its protection, habitat preservation, prevention of interbreeding with domestic buffalo, scientific monitoring, genetic profiling, training of officials and submission of annual operational plans as necessary conservation measures.
Conclusion: The State of Chhattisgarh was directed to fully implement the Integrated Development of Wildlife Habitats scheme and to take immediate steps to conserve the wild buffalo, prevent interbreeding, maintain genetic purity, and undertake monitoring and research measures.
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