Jaisalmer, Rajasthan: Bhopal Singh leaned on his stick, his legs aching after a 35-kilometre walk through dunes and rocky trails. The winter sun cast long, golden streaks over the barren land, while a cold wind whipped up dust from thorny shrubs. It was nearly 3 pm and the desert air was already turning sharp.
The 39-year-old—whose family depends on livestock—lives in Jaisalmer’s Jhalora Bhatiyan village 400 km west of the state capital Jaipur. He was one of those who participated in a three-day protest march against a proposed 600 megawatt (MW) solar power plant proposed by Adani Green Energy Limited in a village called Baiya.
For more than 60 days, local herders and other village folk had been opposing the project for threatening their traditional sacred community groves, known locally as orans.
“The solar project will take over our ‘oran’ land, leaving us without any rights to our pastures and temple,” said Singh. “Trees hundreds of years old will be cut in the blink of an eye. Who will be responsible for destroying our livelihood?”
In November 2024, when Adani Green Energy Limited began its operations by setting up a grid substation, the people of Baiya protested by lying in front of company vehicles.
The state govt had given permission to the company to work on 128 khasras (land parcels), covering 3300 acres, including 229 acres of private land. The substation requires 9.62 acres. Each khasra refers to a specific plot of land with a unique identification number in the government’s land records.
“This is a recurring story from the government’s so-called development playbook,” said Singh. “They push projects at the cost of the communities they affect. What happens to people whose livelihoods, children’s education, and livestock depend on orans? Who will provide for them?”
The Cost Of Green Energy
With over 325 sunny days a year, Rajasthan has emerged as India’s renewable energy hub. The state ranks first in solar power, boasting an installed capacity of 22,860.73 MW, and third in wind power, with 5,195.82 MW.
By early 2024, Rajasthan had surpassed 18 Gigawatts (GW) of solar installations, leading the country in solar energy generation, and is projected to reach 4.5 GW in wind capacity by year-end.
However, this rapid expansion has come at a significant cost, with many projects encroaching on traditional community lands and sparking conflicts (here and here).
For Rajasthani communities that depend on their livestock, orans are more than just pastures. These village commons, often centred around a temple and a waterbody, have been conserved by the local community for centuries.
The villagers also obtain gum, timber, wild vegetables and other forest produce from orans for their livelihood and daily use. They are vital to the area’s pastoral way of life, supporting cows, sheep, and goats while harboring indigenous trees, such as the Khejri (Prosopis cineraria)—the state tree of Rajasthan—and the endangered Rohida (Tecomella undulata).
The orans are also home to the critically endangered great indian bustard, chinkaras (Indian gazelle), and the Indian desert fox.
Activist Sumer Singh, a member of Team Oran—a community-based group focussed on preserving sacred groves in Rajasthan—told Article 14 that solar projects in Fatehgarh and Pokhran, sub-divisions of Jaisalmer district, have forced people to migrate to cities.
“It’s not just about losing land,” he said. “Men migrate to cities for low-paying jobs. Communities that once thrived on shared labour and mutual support are now fractured. The loss of orans is a blow to our identity and heritage.”
Sumit Dookia, scientific adviser to the Ecology, Rural Development & Sustainability Foundation, an NGO working with rural communities for biodiversity conservation, expressed concerns about the impact of solar farms on traditional livelihoods.
“Solar farms are a recent development, and while migration trends aren’t clear, they’re already eroding traditional jobs,” said Dookia. “People will likely shift to roles in packing, loading, unloading, or security, and many will end up landless or with only small fragments of their land.”
Ravindra Singh Bhati, an independent MLA from the Sheo constituency in west-Rajasthan, has been a key voice against renewable energy projects, also leading protests in Baiya.
“The government has allotted land meant for locals to energy companies without informing them, leading to disputes,” said Bhati. “Many villagers are unaware their land has been taken. It’s my responsibility as a people’s representative to voice their concerns.”
On 19 January, 2025, the Rajasthan police booked Bhati after an association of companies alleged he was responsible for stalling renewable energy projects worth Rs 8,500 crore. The Indian Express reported that Bhati faces charges of extortion.
The action followed a recent letter from the National Solar Energy Federation of India to Prime Minister Narendra Modi and Rajasthan Chief Minister Bhajan Lal Sharma seeking “urgent intervention” in Barmer against Bhati’s interference.
The federation quoted the Rs 8,500-crore figure, which the police repeated.
Land Conflicts Impede India's Renewable Energy Push
Addressing the annual conference of the United Nations COP26 in Glasgow in 2022, Narendra Modi announced climate commitments that included achieving net-zero emissions by 2070, sourcing 50% of energy from renewables by 2030 and reaching 500 GW of non-fossil energy capacity by 2030, among others.
A 2021 study by the Institute for Energy Economics and Financial Analysis, estimated that India may require up to 75,000 sq km of land for solar energy and 15,000-20,000 sq km of land for wind energy (the total project area, including space between turbines and other infrastructure) to meet its commitments.
It said that the land that India might need to reach its solar goals alone is equivalent to 1.7-2.5% of India’s total landmass, or 2.2-3.3% of non-forested land.
A 2024 study by the New Delhi-based Council on Energy, Environment, and Water revealed that only 35% of onshore wind and 41% of solar potential in India are situated in areas without historical land disputes.
Many green energy projects across the states have led to conflict with locals over land use and displacement concerns, Article 14 has reported. (here and here)
Legal Ambiguities & Community Fears
Since independence, orans have been classified as wastelands, a bureaucratic designation that went largely unnoticed by locals until 1999, when a private solar company began clearing trees from the Degrai Oran in Jaisalmer.
It was then that communities discovered that many orans were not registered in government records and officially labelled as wastelands.
This misclassification made it easier for the revenue department to reallocate the land for industrial or infrastructural purposes, bypassing local consultation.
Following the landmark T N Godavarman Thirumulpad case in 1996, the Supreme Court ordered states to classify "deemed forests"—areas not officially notified but meeting forest criteria under the Forest Conservation Act, 1980 (FCA).
In 2005, the Supreme Court’s central empowered committee (CEC) recommended classifying all sacred groves as forests, except for “small fragmented areas, which are difficult to manage.”
After many follow-ups by interlocutory applications, on 18 December 2024, the Supreme Court instructed the Rajasthan government to fully comply with the CEC’s instructions and form a committee to identify arid areas with grasslands, rocky outcrops, and stony deserts and to consider them as deemed forests.
It also emphasised the importance of mapping Rajasthan’s orans through on-ground surveys and satellite data to ensure their scientific classification and formal notification as forests.
Krishi Avam Paristhitiki Vikas Sansthana (KRAPAVIS), an Alwar-based organisation working to ensure sustainable livelihoods for rural pastoral communities, estimated that Rajasthan's orans span around 600,000 hectares.
“Of the 25,000 orans recorded in the public domain, only about 5,000 have been formally recognized so far,” said Aman Singh, founder of KRAPAVIS.
Celebrating the SC’s judgment, Aman Singh, also a petitioner in the case, told Article 14, “From a conservation point-of-view, it’s a good move. This is a concrete step to protect orans by making sure the locals’ rights are intact.”
Can ‘Deemed Forest’ Status Protect Orans?
In Jaisalmer, Sumer Singh, was not happy with the “deemed forests” status. “We do not want the forest department taking the ownership of our land and robbing us of our land rights,” he said.
Parul Gupta, a conservation lawyer practising in the SC and the National Green Tribunal, explained that the deemed-forest designation was more nuanced. When an area is declared a deemed forest, the rights of the local community do not cease to exist, he said.
“The judgment talks about the Forest Conservation Act and it also talks about the community reserve,” said Gupta. “If a proposal comes in the future, which says that this particular land would be diverted for non-forest use, then the local communities would be asked.”
Villagers are unsure if the Supreme Court ruling is enough to protect the orans.
“The Supreme Court's directions are framed as recommendations rather than directions,” said Gupta. “This lack of clarity has fueled mistrust among villagers, who are already wary of government actions regarding orans.”
Pooja Chandran, an environmental lawyer at the Foundation for Ecological Security, a nonprofit working to conserve land, forest and water resources, shared the concerns of locals regarding potential changes in the governance of their land.
“Local communities are apprehensive about the judgment’s potential to enforce a more rigid approach to managing orans,” she said.
While the judgment acknowledges the importance of traditional knowledge and cultural practices, Chandran warned that assigning responsibility to the forest department could undermine the community-based conservation that has sustained these areas for generations.
“Departmental oversight could unintentionally limit the access and rights of the people who have nurtured these areas for generations,” she added.
Chandran also pointed out the need for greater clarity in the judgment and its implications for local governance.
“When it comes to resource governance and the management of natural resources, ambiguity can sometimes result in significant bureaucratic discretion,” she said. “This flexibility, if not carefully managed, might lead to decisions that don't fully reflect the interests of local communities.”
Chandran emphasised that sacred groves were symbols of community custodianship rather than just ecological assets.
“Sacred groves are deeply rooted in unique cultural, spiritual, and social traditions that have preserved them for centuries,” said Chandran. “Reducing them to mere forests, or resources to be managed, risks erasing the very essence of what makes them so invaluable.”
'The Struggle Shall Continue’
Experts have also raised concerns over the 2023 amendments to the FCA, warning that they weaken protections against the conversion of forest land for non-forestry purposes.
Under the original FCA of 1980, converting forest land to non-forest use had restrictions but under the amended FCA, certain exemptions allow the state governments to clear deemed without central government approval.
This change could make it easier for green energy companies to divert forestland for their projects.
Article 14 sought comment via email from Arijit Banerjee, principal chief conservator of forests, Rajasthan, and Ramesh Pandey, inspector general of forests, about the concerns of local communities over the orans. We will update the story if they respond.
On 6 January 2025—the second day of the protest march—the locals received word from the district administration that Adani Power had agreed to build the 600 MW solar power project on non-oran land, releasing 507.5 acres of village land.
The district administration has now approved construction only on 116 khasras.
As the protestors celebrated their collective victory, Bhopal Singh said that the fight was not over.
"We are not against development, but we won’t let our land, livelihood, and culture be taken by energy companies,” he said. “The struggle for protecting orans shall continue."
(Aman Singh is an independent journalist based in New Delhi. He covers issues related to environment, health, labour, tech and social justice.)
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