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5 UPES LR (2020) 57

Covid - 19 vis-à-vis Domestic and International Law Regulating Wildlife Trade

COVID - 19 VIS-À-VIS DOMESTIC AND INTERNATIONAL LAW REGULATING WILDLIFE


TRADE
by
Rama Devi Gudemela*
ABSTRACT
One of the contended causes for the outbreak of Covid-19 is Illegal wildlife trade
and illegal wildlife consumption. It is contended that Covid - 19 has emerged from
Corona virus which is theorized to have jumped from horse shoe bats into humans.
Not only Covid-19 but also many other zoonotic diseases which have emerged in
the past decades like SARs, MERs, Ebola, HIV - AIDS are zoonotic diseases. Approx.
60 percent of these zoonotic diseases have said to emerge from wildlife. The paper
discusses as to the comprehensiveness of CITES, an international treaty regulating
wildlife trade among nations, in addressing illegal wildlife trade menace and how it
aids in preventing the future zoonotic diseases like Covid - 19. A further analysis of
how One Health approach initiated by Food and Agriculture Organisation is
suggested by International Community in preventing the future emergence of
Zoonotic diseases like Covid-19. A proper coordination among the various
International institutions like FAO, OIE, WHO at International level and also strong
coordination is suggested among different agencies at domestic level to prevent
zoonotic diseases to emerge in future. The paper's scope has been limited to the
analysis of laws regulating Wildlife Trade at International and National regimes
thereby discussing the improvements to be made. It is concluded and contended
that the need of the hour is to have stringent legislations regulating Environmental,
Animal and human health at global and domestic arenas to prevent future
emergence of Zoonotic diseases.
Key words: CITES, Illegal Wildlife trade, Covid 19, One Health, Zoonotic disease
INTRODUCTION
Covid-19, is a major catastrophe faced by human race of this century. It is one of
the infectious respiratory diseases emerged from a new class of Corona virus namely
SARS Cov 2. World has witnessed the same coronavirus pathogen causing other
similar respiratory diseases like SARS (Severe Acute Respiratory

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Syndrome Coronavirus) and MERs (Middle East Respiratory Syndrome) but Covid 19,
appears to be the only one with pandemic potential and also unprecedented due to its
nature of spreading rapidly when compared to other viruses. All these are Emerging
Infectious Diseases (EIDs) which can be easily transmitted from human to human.
These diseases have major impact on Global health and Economies. The EID's which
originate in animals and gets transmitted to humans are known as Zoonotic diseases.
These Zoonotic diseases are a major contributing factor to human infectious disease
risk. Scientists believe that seventy-five percent of all new and emerging infectious
diseases are zoonotic, of which the majority have their origins in wildlife.1
International wildlife trade plays an important role in spreading of these zoonotic
diseases. Trade requires close contact among humans, animals and animal products
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during the extraction and exchange process, elevating the risk of a zoonotic pathogen
crossing species lines. Due to the increased commercialization of wildlife, there is a
surge in the scale of zoonotic pathogen movements, which are creating a risk of
spreading the infectious diseases.2 Other zoonotic diseases like Ebola, Monkeypox, HIV
in the past decades were transmitted due to trade in wildlife. The present paper
determines and analyses as to how the International Trade in wildlife can be regulated
in order to prevent the future emergence of new infectious diseases.

It is believed that Zoonotic disease i.e., COVID-19 coronavirus is one of a family of


coronaviruses commonly found in bats. Bats are the primary source of infection, which
is transferred to humans and since then the rapid human to human transfer has been
confirmed widely.3 This disease is originated in a wet market in Wuhan, where a range
of common and exotic animals, both dead and alive, were sold for human
consumption. Though a temporary ban on wildlife trade was announced by the Chinese
government shortly after the outburst of pandemic, but this cannot be a solution to
prevent future outbreaks of viruses which are likely to be propagated by wildlife. The
major reason for zoonotic diseases is due to illegal wildlife trafficking and wildlife
consumption4 . Wildlife trafficking is one of the most lucrative illegal trades in the
world, rivalling in value the trade in drugs, weapons, and human traffic. However, it is
often not treated as a serious crime by many countries.
Hence, there is a need to regulate the wildlife law trade at international level as
Covid-19 is a globally emerged challenge faced by all the countries. Umbrella ban
cannot be imposed on wildlife trade by all nations; this would only worsen

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the situation thereby leading the emergence of underground trade markets5 . Hence, a
sustainable and comprehensive regulation are to be put in place by global community.

INTERNATIONAL LAW REGULATING WILD LIFE


The Convention on International Trade in Endangered Species of Wild Fauna and
Flora (CITES)
It is a multilateral agreement with the aim to regulate international wildlife trade
such that it does not threaten species survival in the wild. There are three
classifications made under CITES for the threatened plants and species based on the
level of threat they face.
Appendix 1 completely prohibits the trade in species that are in the danger of
extinction. Appendix 2 consists of the species list that are not threatened with
extinction but that might suffer a decline in number if the trade in these animals are
not regulated. Their trade is regulated by permit.
Appendix 3 consists of those species that are protected in at least one country that
is a CITES member. This member has petitioned other nations for help in controlling
international trade in that species.
Because of the complexity of the global trade in wildlife, CITES collaborates with
organizations such as INTERPOL, the United Nations Office on Drugs and Crime, the
World Bank, and the World Customs Organization through the International
Consortium on Combating Wildlife Crime.
Compliance with CITES requires that signatory countries enforce national legislation
that implements all aspects of the convention. In case of non-compliance, the
Conference of the Parties and the Standing Committee recommends suspension of
trade in CITES-listed species with the non-compliant country until they return to
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compliance. Currently, 25 countries are subject to trade suspensions of CITES-listed


species.6
Role of World Wildlife Fund (WWF)
To enable CITES and its members enforce effectively, World Wildlife Fund (WWF)
plays pivotal role. It addresses illegal and unsustainable wildlife trade as

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a priority issue. The three key areas are concentrated upon by WWF to address this
issue.

Firstly, WWF provides technical, scientific advice to CITES. It also carries out
cutting edge research on illegal wildlife trade routes, the effects of wildlife trade on
particular species and on deficiencies in wildlife trade laws. This information aids
CITES members to keep abreast of new trends and challenges ad also promotes the
inclusion of new species in the CITES appendices.
Secondly, it bans or limits trade in particular species and also to effectively enforce
this. WWF aids in providing equipment, training and funds to under developed and
developing nations for enforcement of the CITES. WWF also helps countries to comply
with CITES regulations by helping to develop programmes, create regulations, runs
workshops, assists enforcement efforts etc.
Lastly, one of the most powerful tools of all for addressing illegal and unsustainable
wildlife trade is to persuade consumers to make informed choices when buying wildlife
-based products.
WWF strives to enable the effective enforcement and implementation of CITES
treaty at domestic levels.
CITES is an International Treaty, with almost all the countries parties to it, with
teeth to regulate wildlife trade thereby banning the species to be put to trade which
are on the verge of extinction. CITES is looked into as a Trade related treaty rather
than environmental law regulating treaty.7 CITES is not authorized to deal with the
health or disease impacts of traded wildlife or any other disease issues. Additionally,
CITES doesn't have any consent to standardize or prohibit trade that may be a menace
to the health of the habitats. CITES also doesn't cover the vast majority of wildlife
species traded commercially for human consumption.
CITES and its members were called to address the impact of COVID-19, ranging
from amending the Convention text, making changes to existing resolutions and
enhancing implementation of existing partnerships or establishing new ones. One such
proposal is to amend the Convention to add a new Appendix IV that would include
species considered to pose a threat to public or animal health8 . But another argument
to this would be that enacting more stricter regulations in Illegal wildlife trade can
lead to emergence of underground or black market trade in wildlife thereby leading to
more detrimental impact on

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human environment. It's an ongoing debate9 . Another approach and considering the
timely need to regulate this illegal wildlife trade is to take precautionary and public
health-based approach, by ending all types of commercial trade in wildlife (particularly
birds and mammals) for consumption. A study held that trade/market-based approach
is better than a species-by-species approach which can result in a higher probability of
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achieving the goal of preventing another zoonotic pandemic.10

In this direction, governments needs to consider working collaboratively through


the United Nations and its other organizations such as World Health Organization
(WHO), World Organization for Animal Health (OIE), Food and Agriculture Organization
(FAO), etc. to espouse a strong protocol and guidance on this issue. Therefore, CITES
cannot be the sole remedy to this problem. Lest, it may invite many such amendments
to be made to existing CITES agreement in order to bring under its purview even
including the matters relating to Public health which will not on par with the CITES
framework. Additionally, it is argued by environmental scientists that there is a dire
need to provide for a different Convention in relation to Zoonotic diseases spread and
some argue that CITES apart from being expanded, there is a pressing need to
strengthen CITES and reinforce the architecture of global environmental law in which
it is embedded.11
One Health Approach (OH Approach)
One Health is a collaborative, multisectoral and transdisciplinary approach working
at the local, regional, national and global levels. The approach calls for close
integration of human, animal, environmental and ecosystem health. Its an integrated
approach for preventing and mitigating health threats at the Animal-human-plant-
environment interfaces with the objective of achieving public health, food and nutrition
security, sustainable ecosystems and fair trade facilitation. OH approach designs and
implements the programmes, policies, legislations and research in the direction of
achieving its objectives as strategies.12 Different sectors at domestic and global levels
communicate and collaborate to accomplish better public health outcomes. To promote
one Health in the food and agriculture sectors and to the protection of the human
rights to health and to a healthy environment, FAO closely collaborates with the World
Health Organization (WHO), the World Organisation Animal Health (OIE), the UN
Environment Programme (UNEP), other UN System entities and international
organizations. One of the strategic approaches in OH is through implementation and
enforcement of various legislations at International and

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Domestic levels. Through legislations, One Health objectives can be effectively


translated into concrete, sustainable and enforceable rights, obligations and
responsibilities, paving the way for inter-sectoral collaboration. With well-established
coordination mechanisms, where each institution or government agencies knows its
role, will a governments of States be able to react with due consideration of all the
interests and areas involved.

FAO had stated that One Health objective can be achieved by bringing changes in
the different spheres of legislations. The following legislations at domestic levels,
centred around health together contribute towards Global health. All such legislations
can collectively prevent any kind of emergence of zoonotic diseases. One of such
legislations from One Health legislations which aids in curbing the illegal wildlife trade
and consumption is CITES to a certain extent. The observation reveals that CITES does
not deal with any such law regulating human and health based approach and also
wildlife consumption, the international law cannot alone rely on one legislation,
however all the below legislations would help in preventing the future emergence of
zoonotic diseases.
FAO also stated that there have to be constant changes made for sanitary and
phytosanitary measures and other environmental legislations should be made
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mandatory and practised13 . It is a fact that taking close food safety and quality related
legislations also directly contributes towards One Health. Such kind of practice would
provide a supporting system for governments to monitor and control the safety and
quality of food products and prevent the transmission of food-borne diseases,
including zoonosis that can be transmitted through food.
In the same way, certain standards and recommendations of the OIE, including its
Terrestrial and Aquatic Animal Health Codes are introduced and applied by the animal
health legislation.14 This legislation is usually applicable to all animals and it
contributes to wildlife health. Animal health legislation makes provisions for the
national veterinary authority. The legislation mandates to regulate, control and foster
animal health. It also includes the power to exercise veterinary surveillance and
control, and to adopt and implement sanitary measures. Finally, it also provides the
legal basis to prevent and contain the occurrence and spread of zoonosis.
The conservation of their ecosystems can definitely ensure perfect health. A
forestation would guarantee proper and safe inhabitation which would also halt the
degradation of their biodiversity. The legislation pertaining to the conservation and
management of forests and their resources also would ensure to achieve the objective
of One Health and also to safeguard the wildlife in

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forest areas.15 It is also evident that such laws establish effective enforcement
mechanisms, thereby resulting in the preservation of forests and trees. It is significant
to understand the main causes of unregulated deforestation and forest degradation aid
indesigning forest and environmental legislation to address the issues.

A wide range of relevant cross sectoral policies should be reflected and given effect
in Wildlife and fisheries legislation. Such kind of legislation would lead to
environmental sustainability (including biodiversity and ecosystem preservation), socio
-economic development, gender equity, and animal health and food safety.
Additionally, it should be noted that legislation should consider customary use and
traditional knowledge, vulnerable and indigenous peoples’ rights, and human-wildlife
conflicts. 16
The impact of the COVID 19 pandemic and the possibility of future prevalence and
outbreaks can be minimized by the natural environment for human, animal and
environmental health together well managed can guarantee and these can ensure a
rapid response to mitigate such a pandemic. Such kind of collective approach
regarding environment, human and animal proliferate the immediate need for
adopting One Health Approach. It is quite evident that One Health Approach has to be
adopted at International and Domestic level to prevent the zoonotic diseases in future.
It is evident that the One Health approach is in an emergent stage in India.
However, there have been many regulatory measures and crosscutting policies that
are operating and conducive for further development of the approach. The Food Safety
and Standard Act, 2006 stipulates the limits for contaminants, naturally occurring
toxic materials, antibiotic residues, pesticides, heavy metals, veterinary drug residues,
etc. Government-initiated control programs for zoonotic and highly communicable
diseases such as rabies, brucellosis, and food-and-mouth disease are available. In this
regard, a manual for handling zoonotic diseases has been published by the Centre of
Zoonosis, National Centre for Disease Control, India.17 Of late, there is “Make in India”
initiative, which supports the development of medical equipment, drug, vaccines, and
technology innovations18 that can be used to address zoonotic diseases. A process of
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consultation has been initiated regarding an appropriate organizational structure for an


OH hub in India to support intersectoral activities involving both the

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human and animal health sectors, working with government engagement on OH


initiatives.19

A process of consultation has been initiated regarding an appropriate organizational


structure for One Health hub in India to support inter-sectoral activities involving both
the human and animal health sectors, working with government engagement on OH
initiatives. Nevertheless, very little has been done with respect to Illegal Wildlife
Trade. The One Health approach is just in the initial stages in India. The laws are there
in place, but the implementation and enforcement is always a concern in India. The
International law objective has to be implemented within the local.
There has to be cooperation of human, animal, and environmental health partners
for the successful public health interventions. There should also be professionals in
human health (doctors, nurses, public health practitioners, epidemiologists), animal
health (veterinarians, paraprofessionals, agricultural workers), environment
(ecologists, wildlife experts), and other areas of expertise is needed to communicate,
collaborate on, and coordinate different activities. There are a few other relevant
players in a One Health approach which include law enforcement, policymakers,
agriculture, communities, and even pet owners. No one person, organization, or sector
can address issues at the animal-human-environment interface alone, a collaborative
approach like One Health is the need of hour to prevent the outbreak of future zoonotic
diseases.
WILDLIFE PROTECTION LAWS IN INDIA
With the emergence and because of Covid-19, as studies indicate that 60 per cent
of Emerging Infectious Diseases such as HIV, Ebola, SARS, Covid-19 are affecting
humans.20 This resulted in giving importance to the conservation of wildlife in its
habitat. Approximately 60 to 65 per cent of these originate in wildlife.21 Wildlife
habitats such as Protected Areas and other categories of landscapes rich in wilderness,
are also important life-supporting systems that play a predominant role in
guaranteeing food and water security, climate change resilience, and natural hazard
regulation, among several other ecological, economic and cultural services.

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It is quite evident that usually, when people think about wildlife, they do not think
beyond Protected Areas (Henceforth addressed as PAs), or areas declared as Wildlife
Sanctuary and National Parks under the Wildlife (Protection) Act, 1972 (WPA). Hence,
this results for the reasons why we are still in the process of declaring new PAs. New
categories of PAs such as Conservation Reserve and Community Reserves were
inserted into the WPA in 2002. As per Protected Areas and other effective area based
conservation measures, The Aichi Target 11, Convention on Biological Diversity reveals
that by 2020 at least 17 per cent of terrestrial and inland water, and 10 percent of
coastal and marine areas important for biodiversity and ecosystem services, must be
conserved.22 India was supposed to bring 20 per cent of the country's area, which is
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rich in biodiversity and ecological value, under conservation by designating them as


Protected Area, and undertaking other conservation measures, as per the National
Biodiversity Targets under the convention.23
Law regulating Protected Areas under Wildlife (Protection) Act, 1972
Using Protected Areas (Henceforth addressed as PA) as one of the tools, the
standard approach to wildlife conservation in India focuses on saving particular species
from extinction. India has managed to add 5 per cent of its geographical area under
PA where many of these PAs are very small in size though the number may appear
high.24
It is quite evident that most PAs, in reality, are administrative boundaries created
out of convenience. Therefore, these cannot be treated as inclusive of all wildlife
habitats in the country. In fact, declaration of any PA and its buffer zone (such as Eco-
sensitive Zones) is a political process, and the declared boundaries do not necessarily
overlap with actual ecological needs. Additionally, strong protection within PAs has
indicated that they have exceeded their carrying capacity, forcing wildlife to move
outside their administrative boundaries. Further, the protection of habitats outside PAs
is even more important.

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Prominence of Territorial Forests


Statistics also reveal that almost 20 per cent of India's geographical area is under
some kind of conservation planning. These are solely managed for biodiversity
conservation, which includes a large tract of lands managed by State Forest Divisions
and private owners apart from the Protected Areas.25 These forests, referred to as
Reserve Forest (RF), State Forest (SF), Protected Forest (PF) etc, are regulated under
Indian Forest Act, 1927 and various other state legislations.
The State-owned forests are often referred to as Territorial Forests (TF). Such
forests harbour nearly all of India's 36 endemic mammals. They act as important
connectors with the more strongly guarded, but scattered, network of PAs across the
country. Similarly, some TFs are also one of the most human-dominated wildlife areas.
These TFs are prone to heightened human-wildlife conflict and poaching. TFs remain
neglected under India's patchwork of laws, in spite of their valuable ecological
importance.
India's PAs were designated under the Wildlife Protection Act (WPA), 1972. These
PAs have received increased protection, better resources and the benefit of specialised
scientific training of wildlife. Alternatively, TFs include Reserve Forests. These TFs are
governed by officers of state forest departments using the vehicle of the colonial
Indian Forest Act, 1927. These departments have historically been more concerned
with the extraction of commercially valuable forest produce, with little concern for
wildlife protection.
The WPA provides very limited protection to wildlife habitats inside TFs except for
cases of poaching. For example, the prior recommendation of the National and State
Boards of Wildlife (NBWL/SBWL) is required for any activity involving the use of PAs.
Nevertheless, no such recommendation is required for wildlife habitats outside PAs,
although they may be just as rich in wildlife or important wildlife corridors. It is
unusual for agencies under the WPA to intervene in issues related to wildlife habitat
protection in areas like TFs except for the National Tiger Conservation Authority
(NTCA), which is responsible for protecting tiger reserves.
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CONCLUSION AND SUGGESTIONS


It should be noted that future of wildlife conservation in India solely depends on
how well governments are able to maintain and manage TFs. This requires a
systematic and scientific approach and sufficient resources. All TF divisions in India
should compulsorily plan to work towards wildlife conservation plans, efficient
monitoring mechanisms and measures for mitigating human-wildlife

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conflicts. Such efficient, effective and comprehensive management requires an


independent expert body at the national level that can assume primary responsibility
for the protection of wildlife habitats. Such bodies also should advise central and state
governments on all matters related to wildlife management and human-wildlife
interaction.

Establishment of National Authority to regulate other species of wildlife is the need


of the hour. The new body at National level which has powers similar to NCPA should
be established. This authorised body should have wider jurisdiction for the protection
of all scheduled wildlife species and their habitats, irrespective of the ownership of
land. This new authority should provide a breather to toothless bodies like the Wildlife
Crime Control Bureau (WCCB), as these cannot exercise independent authority to curb
poaching but are reliant instead on state forest officers and the police.
Correspondingly, other bodies such as the National and State Biodiversity Boards
under the Biodiversity Act, 2002, and the National and State Boards of Wildlife
(NBWL/SBWL) are essentially advisory bodies. These bodies must be made part of this
independent authority. The NTCA can be made a part of it or any such other
authoritative body could be created to oversee different identified priority species with
the powers similar to NTCA.26 The working plans and other management activities
proposed by forest divisions should be approved by this national authority. It must
ensure their compatibility with regional wildlife requirements, facilitate framing of
guidelines, encourage research, prevent ecologically unsustainable land use, organise
training of frontline staff in the management of human-wildlife interactions, and most
importantly facilitate community-driven conservation efforts.
Surveillance of animal health should be strictly ensured. It is fundamental to track
the globally emerging new outbreaks. There should be strong interdisciplinary network
of partners to improve surveillance and monitoring. The awareness of farmers,
livestock managers, and environmentalists should be enhanced concerning the OH
approach and zoonotic diseases. Eventually, a national disease registry of zoonotic
diseases needs to be developed. There should be an increased use of technology to
improve the living environment of animals and monitoring and treatment of diseases
should be motivated. More importantly, prevention through increased vaccination
coverage should be targeted. Some of the best practices need to be developed and
adopted based on the learning from the use of OH approach to combat zoonotic
diseases globally.

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A stringent legislation at domestic level is necessary in regulating wildlife trade


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along with CITES at international level. However, regulating wildlife laws alone would
not put any end to the emergence of future pandemics; a collective approach as in
case of “One Health” legislations together would prevent the emergence of future
pandemics.
———
*Assistant Professor, ICFAI Law School, IFHE University, (A Deemed-to-be University) established under Section
3 of UGC Act, 1956, Hyderabad.
1 Jones K.E., Patel N.G., Levy M.A., et al., “Global Trends in Emerging Infectious Diseases”, 451 Nature 990
(2008).
2C. Perrings, S. Levin, et al., “The Economics of Infectious Disease, Trade and Pandemic Risk”, 15 Eco Health,
241 (2008).
3J.S. Mackenzie, D.W. Smith, “COVID-19 : A Novel Zoonotic Disease Caused by a Coronavirus from China : What
We Know and What We Don't”, 41 Microbiol 45 (2020).

4 Jillian Louis, “COVID-19 : The Death Blow to Wildlife Trafficking?”, The Asean Post Team (Mar. 9, 2020),
<https : //www.theaseanpost.com/article/covid-19-death-blow-wildlife-trafficking>.
5 Perhaps the most prominent application of a trade ban in response to zoonotic disease risk was the European
Union's 2007 ban on the import of wild-caught birds in an attempt to curb the spread of avian influenza. While
the ban was effective in eliminating legal wild bird trade to Europe, it also opened new trade routes that spread
the birds and disease risk to new world regions.
6 Convention on International Trade in Endangered Species. See
<https : //www.cites.org/eng/resources/ref/suspend.php>.
7
Malavika Vyawahare, “As COVID-19 Pandemic Deepens, Global Wildlife Treaty Faces an Identity Crisis”,
Mongabay (May 15, 2020), <https : //www.news.mongabay.com/2020/05/as-covid-19-pandemic-deepens-global
-wildlife-treaty-faces-an-identity-crisis/>.
8
End Wildlife Crime, see <https : //www.endwildlifecrime.org/cites-amendments/>.
9
Tanya Rosen, “The Evolving War on Illegal Wildlife Trade”, IISD (Oct. 6, 2020),
<https : //www.iisd.org/articles/evolving-war-illegal-wildlife-trade>.
10 Jillian Louis, supra note. 4.
11
Malavika Vyawahare, supra note 7.
12 UN Food and Agricultural Organisation, see <http://www.fao.org/asiapacific/perspectives/one-health/en/>.

13 “One Health Legislation : Contributing to Pandemic Prevention through Law”, UN Food and Agricultural
Organisation (July 2020), <http://www.fao.org/3/ca9729en/CA9729EN.pdf>.
14
Ibid.
15
Ibid.

16 Ibid.
17 Zoonosis Division, National Centre for Disease Control, Zoonotic Diseases of Public Health Importance, Ministry
of Health and Family Welfare, India, (2016), <https : //www.ncdc.gov.in/WriteReadData/l892s/File618.pdf>.
18 See Make in India, <http://www.makeinindia.com.

19P. Chatterjee, S. Bhaumik, et al., “Protocol for Developing a Database of Zoonotic Disease Research in India”,
7 (12) BMJ Open e017825 (2017).
20Institute of Medicine (US) Forum on Microbial Threats, Microbial Evolution and Co-Adaptation : A Tribute to
the Life and Scientific Legacies of Joshua Lederberg : Workshop Summary, Washington (DC), “Infectious Disease
Emergence : Past, Present, and Future”, 5 National Academies Press (2009),
<https : //www.ncbi.nlm.nih.gov/books/NBK45714/>.
21R.M. Vorou, V.G. Papavassiliou et al., “Emerging Zoonoses and Vector-Borne Infections Affecting Humans in
Europe” 135 (8) Epidemiol Infect 1231 (2007).
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22
Secretariat of the Convention on Biological Diversity, Protected Areas in Today's World : Their Values and
Benefits for the Welfare of the Planet, CBD Technical Series No. 36 (2008).
23Government of India, National Biodiversity Authority, Achievement of Aichi Biodiversity Targets 11 and 16
Success Stories from India, Ministry of MoEFCC, (2008), <http://www.nbaindia.org/uploaded/pdf/Aichi%
20target%20design%20low%2014-11-2018.pdf>.
24For example, Maharashtra's Mayureshwar Supe Wildlife Sanctuary is 5.14 sq km in size, while the Mahavir
Swami Wildlife Sanctuary in Uttar Pradesh is only 5.4 square kilometres (sq km) big, and Himachal Pradesh's
Renukaji Wildlife Sanctuary is a mere 4 sq km.
25
Joshi Gopa, Forest Policy and Tribal Development, Cultural Survival Quarterly Magazine (June 1989),
<https : //www.culturalsurvival.org/publications/cultural-survival-quarterly/forest-policy-and-tribal-
development>.
26NTCA is the overarching body for conservation of tigers in India. Its main administrative function is to approve
the Tiger Conservation Plan prepared by the State Governments and then evaluate and assess various aspects
of sustainable ecology and disallow any ecologically unsustainable land use such as, mining, industry and other
projects within the tiger reserves. The Tiger Conservation Plans sent by State Government need to be approved
by the NTCA first.
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rule/ regulation/ circular/ notification. All disputes will be subject exclusively to jurisdiction of courts, tribunals and forums at Lucknow only. The
authenticity of this text must be verified from the original source.

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