The site-inspection report indicated that the Adani company’s proposal entailed cutting 570,666 trees. This included 148,526 trees with girths of less than 30 centimeters. The report said that the forest was of a tropical dry deciduous type, including a large number of species that provide very good timber, such as Saal (Shorea Robusta) and Sagvan (teak). Other species of important trees which will be permanently removed in large numbers belong to Chaar (Cuddapah almond) and Sendha (Crepe Myrtle). The Chaar tree produces an edible fruit whose seeds are used for making spices and medicines. The Sendha tree is known for its strong timber quality; its bark is rich in tannins and used for making a black dye. Many Tendu (Coromandel Ebony) trees, which produce an edible fruit and whose leaves are used for wrapping a traditional Indian cigar known called a beedi, also face the axe, as do Mahua trees whose fragrant flowers are used for fermenting a heady liquor. Most of these trees have multiple uses for forest-dependent communities such as the Baiga. Other important trees include medicinal plants such as the Hareda (Terminalia Chebula), the Baheda (Terminalia Bellirica) and Amla (Indian gooseberry).

The inspection revealed that the state government has, under the India’s landmark Forest Rights Act, 2006, provided legal rights for 49 tribal families to collect minor produce from the forest land that has been sought to be cleared. But local communities told this correspondent that many more families living in the area are also forest-dependent.

‘The number of tribal families dependent on minor forest produce is much more than what the government says,’ Amar Baiga (28) told this correspondent. ‘The forest produce that we collect is hardly ever recorded properly. These forests are rich in bamboo plants which we collect and sell for various purposes. My family, for example, has never been officially provided with individual rights over forest land, even though we depend on its resources. In fact, the government itself procures Tendu leaves from us through intermediaries.’

A wide variety of medicinal and fruit-bearing trees comprise the forest land. While nearly 600,000 trees will be felled, land identified for compensatory afforestation – that is, for planting of new trees to make up for the lost forest – is not free of encumbrance. The largescale felling of trees will adversely impact the livelihoods of local tribal communities who are dependent on the resources of the forest. It will also hamper the free movement of animals such as leopards and elephants – species protected under India’s wildlife laws and described as endangered under various internationals covenants, including CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) to which the country is a signatory.

More than two dozen families belonging to the Baiga tribal community, which has been categorised as a particularly vulnerable tribal group (PVTG) in several other Indian states, live in these forests. Their houses are located just outside the forest areas that have been identified for clearing. The community has managed these forests for generations. The families told this correspondent, during a field visit in April 2023, that their lives will be seriously impaired if the vegetation is cleared. The Madhya Pradesh government, unlike other Indian states, has not conferred PVTG status upon the Baiga community of Singrauli, leaving them bereft of relevant government-welfare schemes.

‘Our children do not go to school,’ Lanka Baiga (30), who lives with his six children in a primitive dwelling, told this correspondent. ‘We do not seek employment outside these forests. These forests provide for all our needs. For generations, we have lived in these forests, practising small-scale farming. We drink water directly from the streams that flow through the forest. Our relationship with the trees and wildlife of these forests is fundamental.’

According to the forest department’s report, wildlife such as bears, hyenas, wolves, jackals and leopards are known to be prevalent in the area. The inspection report does not provide numbers for these animals. It states that the forest earmarked for destruction comprises 16 plots, identified as ‘compartments’ by the department, and that one of these plots overlaps with an elephant corridor. Elephants move through these ‘corridors’ in search of food and water. The department cited in its report the rules which prohibit diversion of any forest land that is part of an elephant corridor. According to these rules, if ‘diversion’ (that is, destruction) of forest land from an elephant corridor is inevitable, for whatsoever purpose, an alternative corridor must be first established for the safe passage of the animals. The rules also state that no temporary or permanent constructions should be undertaken in elephant corridors, even if ‘diversion’ of forest land is permitted.

Despite the above report, the Madhya Pradesh government recommended the clearance of the forest on 19 January 2024. After the enactment of India’s Forest (Conservation) Act, 1980, the total forest area approved for destruction in the Singrauli district totals 6790.91 hectares in 37 different cases. However, the Dhirauli project alone envisages destroying an area that is more than one-fifth of the of total forest land that has been lost in the past 44 years.

‘Apart from the Baiga families, there are families belonging to other tribal communities like the Gond, the Khairwar and the Agaria living at the edge of the proposed mining sites,’ Devi Singh, a local village chief, told this correspondent. ‘These communities are low on most socio-economic indicators, are largely illiterate, and therefore depend on the forest for survival. Once the area around the mining project is cordoned off, these families will find it difficult to travel outside their immediate household precincts. The mine will block an important footpath through the forests.’

The Union Ministry of Environment, Forests & Climate Change (‘the ministry’), to which the proponent’s application was sent for final approval, has pointed to many deficiencies in the way the proposal was recommended by the state government. In a letter issued on 2 February 2024, the ministry flagged that the proposal needs approval from Madhya Pradesh’s wildlife department, too, because the project not only falls in the path of an elephant corridor but also in an area where leopards have been observed.

It was pointed out that a biodiversity study is required prior to the approval because of the presence of very dense forests. The ministry objected to the Adani company’s proposal to dump mining waste within forest land. The Adani company has said that 225.4 hectares of forest land will be used for dumping of overburden, while 6.3 hectares will be used for developing mining infrastructure. The forest department, in its report, had not taken cognisance of the total area to be used for dumping of overburden. The ministry asked it to ‘explore the possibility of shifting’ the ‘non-site-specific components’ of the mining plan outside forest land. The state government has also been asked to furnish information on how coal will be transported through the forest land and its possible impacts on the biodiversity of the region.

The ministry has also asked the state government to provide details of the ‘forest crops and diameter classes of valuable trees’ identified for felling. The plan for felling the trees (to be done in phases) has also been demanded. The ministry has questioned the fate of at least five high-voltage electricity transmission lines passing through the forest area identified for clearing but nevertheless provided approval, in a letter dated 22 January 2024, for an alternative patch of forest land to shift these transmission lines.

For compensatory afforestation, the Adani company identified 45 patches of land in four districts of Madhya Pradesh: Sagar (33.56 ha), Raisen (9.89 ha), Shivpuri (757.88 ha) and Agar Malwa (596.21 ha). Three of these forty-five patches, the ministry has pointed out, are located on an earthen dam which may not be fit for planting trees. Another major issue raised by the ministry is that two patches in Shivpuri district are already part of a reserved forest and fall within an important tiger corridor.

The ministry has also flagged that the proposed coal mine is near the Sanjay Dubri Wildlife Sanctuary, which is a protected area and is also part of an important tiger reserve. The Madhya Pradesh government has issued a letter to the project proponent highlighting the ministry’s requirement for mitigation measures against the proximity of the proposed project to the wildlife sanctuary.

‘The Sanjay Dubri Wildlife Sanctuary is located at a distance of 10.07 Km from the proposed forest land for diversion. Moreover, the state government informed that the proposed area is falling within the 1 km of the elephant corridor as per the prevailing working plan for the period 2019-20 to 2028-29. Further, movement of leopard (Tendua) reported in the SIR [site inspection report] of the DFO [divisional forest officer], Singrauli. Therefore, the comments from CWLW [Chief Wild Life Warden; of Madhya Pradesh] along with proposed mitigation measures need submission,’ stated the letter issued to the project proponent of 6 February 2024.

The Adani Group has said in its response of 11 March 2024 – that the coal block is at least five kilometres from the elephant corridor. It has also said that no wildlife approval is required for the project because the site is more than 10 km from the Sanjay Dubri Wildlife Sanctuary. (Wildlife approvals in India are required only if a project is proposed within the notified eco-sensitive zone surrounding a protected area. In cases where no such has been notified or delineated, the default boundary of the eco-sensitive zone is considered to have a radius of 10 km around the protected area.)

‘Although, the proposed forest area is more than 10 km from Protected Area [Sanjay Dubri Wildlife Sanctuary], but we have prepared a wildlife management plan, which is duly approved by CWLW [Chief Wildlife Warden],’ the project proponent has said in its reply.

Adani has also said that the plan includes measures to mitigate human-leopard conflict and other habitat conservation measures, in response to observations of leopards in the forest area that has been earmarked for destruction.

The project proponent also says it has reduced the proposed external dumping area within the forest from 225.40 to 132.28 hectares. It has assured the ministry that no mining-related infrastructure whatsoever will be constructed within designated forest land. It has provided a phase-wise plan for the felling of the trees. The project proponent has refused to bear the onus of encumbrances attached to the land identified for compensatory afforestation, including the overlapping of two patches with a tiger corridor. It has stated that the forest department has itself provided it with no-objection certificates for carrying out compensatory afforestation over land that has now been identified as encumbered.

Surprisingly, though the ministry has already granted environmental clearance for the project, it has asked the Madhya Pradesh government to justify the rationale for opening the pristine forests for coal mining.

‘As per DSS [decision support system] analysis the proposed area is falling in Inviolate or In High conservation zone value (HCV) with majority area falling in Very Dense Forest category. The state shall submit the justification for proposing such pristine area for mining. Further, keeping in view the conservation value of the area, the state shall intimate whether any impact assessment/biodiversity study taking into account the impact of mining has been carried out or not. If so, the details be provided,’ the ministry has said.

The Modi government has previously allowed diversion of 259.239 hectares of forest land for the Suliyari coal mining project in Singrauli. The Suliyari project belongs to a government-owned mineral development corporation of the south Indian state of Andhra Pradesh which, in turn, has appointed an Adani Group company as the mine’s developer and operator (MDO). The Suliyari block adjoins the southwest boundary of Dhirauli. Approximately 55% per cent of Dhirauli is covered with forests. Two other blocks to the immediate northeast of Dhirauli – Mahan (97% forest cover) and Mara II Mahan (90% forest cover) – were listed for auction by the Narendra Modi government in March 2023 but with the pre-condition that only underground mining would be permitted. In an e-auction held on 12 March 2024, an Adani Group subsidiary – Mahan Energen Limited – won the bid for Mara II Mahan block. Though the forests covering these four coal blocks are part of one contiguous range, it is unknown why separate parameters were adopted for the various proposed coal mines within them.

Impacts on water resources

The presence of various water bodies such as streams within the forest area earmarked for clearing for the coal mine has been flagged by the ministry. It has asked the state government to provide mitigation measures to offset the adverse impact of mining on such water resources along with a no-objection certificate from the relevant department. In earlier articles, AdaniWatch has highlighted how the Modi government provided clearance to the Adani Group’s coal projects in Singrauli district despite the fact that many water bodies will be impacted by the mining activities. During the field visit, this correspondent also found that local communities, including tribal households, were dependent on these water bodies for drinking purposes, for household needs, for irrigation and also to maintain their livestock.