From Supreme Court Bench to Vantara Council: Justice Krishna Murari’s New Role Puts Judicial Recusal and Governance Safeguards Under Scrutiny
Former Supreme Court judge Justice Krishna Murari has joined Vantara’s newly constituted independent Governing Council, three years after retiring from the Supreme Court. The appointment has attracted attention because, during his tenure on the apex court, Justice Murari sat on benches that dealt with litigation concerning the Greens Zoological Rescue and Rehabilitation Centre at Jamnagar and the Radha Krishna Temple Elephant Welfare Trust—entities that Vantara now identifies with its animal-care and conservation operations.
Vantara announced the council in September 2026 as its highest-level governance body for conservation, rescue, compliance and future planning. Former CITES Secretary-General John E. Scanlon AO is the independent chair. The voting members also include Justice Murari, wildlife-conservation officials and international zoo and conservation experts, while wildlife veterinarian Dr Kushal Konwar Sarma is an ex-officio member. The council is also to have a role in approving future applications for importing wild animals.
The issue is significant because Justice Murari had already dealt with litigation concerning the Greens Zoological Rescue and Rehabilitation Centre while he was a sitting Supreme Court judge. In Kanhaiya Kumar v. Central Zoo Authority, decided on August 16, 2022, a Bench comprising Justices Dinesh Maheshwari and Krishna Murari considered a PIL challenging the recognition of the Greens centre and seeking a ban on its acquisition of animals from India and abroad, along with an SIT investigation into its management.
The Supreme Court dismissed that petition. The Bench held that it found no legal infirmity in the recognition granted by the Central Zoo Authority and concluded that the centre’s permissions and consequential activities could not be described as illegal or unauthorised on the material before the Court.
Justice Murari was also part of the proceedings concerning the Radha Krishna Temple Elephant Welfare Trust. In Muruly M.S. v. State of Karnataka, the Supreme Court dealt with challenges concerning the transfer, sale, gift or entrustment of wild and captive elephants to private parties, including that trust. A March 3, 2023 judgment authored by Justice Murari expanded the jurisdiction of a High-Powered Committee to deal with issues concerning wild-animal transfers and rehabilitation across India.
The legal history therefore creates a factual overlap between Justice Murari’s former judicial responsibilities and his present institutional responsibilities. That overlap, by itself, does not establish impropriety or suggest that his earlier judgments were affected by any future role. The relevant governance question is narrower: what safeguards should apply when a retired judge subsequently joins an organisation whose constituent entities or activities were previously before benches on which the judge sat?
The question also arises against the backdrop of the Supreme Court’s more recent scrutiny of Vantara. In August 2025, the Court constituted a Special Investigation Team headed by former Supreme Court judge Justice Jasti Chelameswar to investigate allegations concerning animal acquisition, imports, welfare and financial and regulatory issues. The SIT worked with multiple agencies, including the Central Zoo Authority, Wildlife Crime Control Bureau, CITES authorities, CBI, Enforcement Directorate, DRI and Customs.
On September 15, 2025, the Supreme Court accepted the SIT’s conclusions that it found no violation of the specified wildlife, customs, foreign-trade, financial and other laws in the matters it investigated. The Court closed the complaints covered by the report. That finding is an important part of the current legal record and should be distinguished from the separate question of institutional governance following Justice Murari’s appointment.
The governance framework has subsequently evolved. Vantara informed the Supreme Court in August 2026 that it had imposed a 12-month internal moratorium on applications to import animals, beginning from June 5, 2026. Under the newly announced structure, future import applications after the moratorium are to require prior written approval of the Governing Council following an internal due-diligence process.
Against that background, one safeguard under consideration is a formal conflict-of-interest and recusal policy. Such a policy could require any council member to disclose previous judicial, professional or institutional involvement with a matter and automatically abstain from deliberations concerning a specific transaction, acquisition, dispute or regulatory question that directly overlaps with proceedings in which the member participated.
A second possible safeguard is a transparent cooling-off framework for retired judges joining private organisations. There is an important distinction here: a general mandatory cooling-off period of the kind proposed by critics is a policy proposal, not a rule established specifically by the material reviewed for this appointment. Any such framework would need to define its duration, covered organisations, exceptions and whether it applies only to parties before the judge or also to entities subsequently connected to those parties.
A third safeguard concerns institutional transparency. If the Governing Council exercises meaningful authority over future animal imports, its credibility could be strengthened through clearly published eligibility criteria, conflict-of-interest disclosures, independent expert assessments and an auditable record of the reasons for major decisions. Commercially sensitive or legally protected information could remain confidential while the governing principles and aggregate decision-making record are made public.
A fourth safeguard would be structural independence. Vantara’s announced council already places an independent chair and several external experts alongside Justice Murari, and Vantara says active employees will not hold voting positions. Maintaining a majority of genuinely independent members, together with clearly defined voting and recusal rules, could help separate operational management from oversight.
The broader issue is therefore not whether Justice Murari’s appointment retrospectively alters the Supreme Court judgments he participated in. Those judgments remain judicial decisions rendered at the time on the records before the Court. The governance issue is whether Vantara’s new oversight mechanism can demonstrate sufficient independence when some of its responsibilities concern subjects connected to litigation previously considered by a member of the council.
For an institution operating in an area as closely regulated as wildlife acquisition, transfer and international importation, the distinction between legal compliance and perceived institutional independence is particularly important. The Supreme Court-appointed SIT’s findings address the former for the matters it investigated; robust disclosure, recusal and audit mechanisms can address the latter going forward.
Justice Murari’s appointment thus places unusual emphasis on the design of the council itself. Clear conflict rules, case-specific recusals, transparent due diligence and independently auditable decisions would allow the council to benefit from judicial experience while reducing questions about institutional overlap with matters that were previously before the Supreme Court.
