From Supreme Court Bench to Vantara Council: Justice Krishna Murari’s New Role Puts Post-Retirement Safeguards Under Scrutiny
Former Supreme Court judge Justice Krishna Murari has joined Vantara’s newly constituted independent Governing Council, placing his appointment at the centre of a renewed discussion about judicial ethics, institutional independence and safeguards when retired judges assume roles connected with organisations whose activities they previously encountered judicially. Vantara says the council will oversee conservation, rescue, compliance and future governance, and will have the final say on future applications to import wild animals.
The issue has a particularly specific judicial backdrop. On August 16, 2022, Justice Krishna Murari, sitting with Justice Dinesh Maheshwari, heard Kanhaiya Kumar v. Central Zoo Authority, a PIL concerning the recognition of the Greens Zoological Rescue and Rehabilitation Centre at Jamnagar and its permission to acquire animals from India and abroad. The centre is now associated with Vantara. The Supreme Court dismissed the petition, finding no legal infirmity in the recognition granted by the Central Zoo Authority.
The 2022 order is important because it establishes a direct historical judicial connection, rather than merely a general professional association. The petition had challenged the permission granted to the Jamnagar facility and had sought restrictions on animal acquisitions as well as an investigation into its management. The bench concluded that the material before it did not establish illegality or justify interference, while also noting that the Central Zoo Authority exercised supervisory responsibility over the field.
That history, however, needs to be distinguished from the much broader proceedings that came later. Justice Murari retired from the Supreme Court in July 2023 and therefore was not a member of the bench that dealt with the subsequent Vantara-related proceedings in 2025. In September 2025, the Supreme Court considered a Court-appointed Special Investigation Team’s examination of allegations concerning Vantara’s animal acquisitions, imports, welfare practices, regulatory compliance and related issues. The Court accepted the SIT’s findings, which reported no violations of the applicable laws and regulations on the matters examined.
The 2025 SIT exercise was extensive. Its terms of examination included acquisition sources and permissions, animal welfare, veterinary care, mortality, breeding, conservation, possible wildlife smuggling, financial and anti-money-laundering issues, and several individual animal transfers. The SIT report also considered the transfer of the elephant Madhuri and other international wildlife movements.
Vantara’s new governance structure is consequently significant. The five voting members include Justice Murari, former CITES Secretary-General John E. Scanlon AO as independent chair, Association of Zoos and Aquariums executive Craig Hoover, former Karnataka Chief Wildlife Warden Subhash K. Malkhede and conservation expert Greta F. Iori. Wildlife veterinarian Dr. Kushal Konwar Sarma is an ex-officio, non-voting member. Vantara has said that its employees will not hold voting positions on the council.
One of the council’s most consequential functions concerns future wildlife imports. Under Vantara’s announced governance commitments, no application to import wild animals will be made before June 5, 2027. After that date, any proposed application will require prior written approval from the independent Governing Council following an internal due-diligence process.
Against that background, the question of safeguards is principally an institutional-governance question rather than an allegation of wrongdoing. The existing public record does not establish that Justice Murari has acted improperly by accepting the appointment. Nor does his 2022 judgment establish that he has any continuing legal interest in the matters he adjudicated. The concern is instead whether the governance structure should contain mechanisms capable of addressing both actual conflicts and situations that could reasonably create an appearance of conflict.
A formal recusal framework would therefore be one important safeguard. It could require disclosure of matters in which a council member previously participated judicially, followed by mandatory recusal from decisions directly concerning those proceedings, legacy acquisitions or disputes that were materially before that member’s court. Such a mechanism would not imply that the earlier judicial decision was improper; it would separate historical adjudication from present institutional decision-making.
Transparency could provide a second layer of protection. If the council is to exercise final authority over future animal-import applications, publishing the broad due-diligence standards, categories of information considered, applicable regulatory clearances and reasons for major decisions could make the process independently verifiable. Where confidentiality or wildlife-security considerations prevent disclosure of particular documents, the existence and scope of the review could nevertheless be recorded.
Independent auditing could strengthen that arrangement further. Decisions concerning major acquisitions, imports, transfers or compliance could periodically be reviewed by an external expert or auditor who has no financial or operational connection with Vantara. Publishing periodic summaries of those reviews would allow the public and regulators to distinguish between internal assurances and independently examined compliance.
The proposed cooling-off principle is more complicated. India presently has no general constitutional cooling-off period preventing retired Supreme Court judges from accepting post-retirement appointments. The Union government told Parliament in December 2024 that the Constitution contains no such provision, although Article 124(7) prohibits a retired Supreme Court judge from pleading or acting in any court or before any authority within India.
The Supreme Court also declined in 2023 to judicially impose a blanket two-year cooling-off period for retired constitutional-court judges, observing that the question would have to be addressed through legislation rather than by a judicial direction of the kind sought in that PIL.
That does not prevent organisations from adopting stricter internal standards. A prospective policy could distinguish between ordinary post-retirement public-interest appointments and appointments involving an organisation whose specific activities were previously before the judge. Such a policy could provide enhanced disclosure, a defined waiting period, or special recusal requirements in the latter category without necessarily treating every post-retirement role as inherently problematic.
For Vantara, the credibility question is therefore likely to turn less on Justice Murari’s presence alone and more on whether the council can demonstrate genuine independence in practice. Its composition, voting procedures, conflict disclosures, recusal records, external review and transparency over future import decisions will provide tangible indicators of how the new oversight model operates.
The development also illustrates the broader unresolved debate surrounding post-retirement roles for constitutional-court judges. The present legal position permits such appointments in the absence of a specific statutory prohibition, while concerns about perceived conflicts and public confidence have repeatedly prompted calls for clearer safeguards. The 2023 Supreme Court proceedings and the Union government’s 2024 parliamentary response both demonstrate that the issue remains one for institutional and legislative consideration rather than an established blanket prohibition.
In Justice Murari’s particular case, the documented connection is therefore precise: he was part of the 2022 Supreme Court bench that adjudicated a challenge concerning the Jamnagar zoological and rescue facility’s recognition and animal-acquisition permissions, and he has now joined the organisation’s governing structure several years after retirement. The subsequent 2025 Supreme Court investigation and its findings occurred after his retirement and before his appointment to the new council.
The strongest institutional safeguard would consequently be one that preserves the distinction between those two roles: judicial decisions should remain matters of the judicial record, while present and future Vantara decisions should be subject to independent, transparent and documented governance. That approach would protect not only against actual conflicts but also against doubts about impartiality—an important consideration whenever former constitutional-court judges move into positions involving organisations connected with matters they previously encountered from the Bench.
