Guwahati: A recent report by the Secretariat of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), presented to the Standing Committee, has identified critical failures in due diligence and in adherence to international trade rules concerning the large-scale import of endangered species into India by the Greens Zoological Rescue & Rehabilitation Center (GZRRC) and the Radha Krishna Temple Elephant Welfare Trust (RKTEWT) at Jamnagar in Gujarat.
Greens Zoological Rescue & Rehabilitation Center (GZRRC), also known as Vantara, is managed by Reliance Industries chairman Mukesh Ambani’s youngest son, Anant Ambani.
The report, presented at the 79th meeting of the CITES Standing Committee (SC79), stems from a verification mission conducted in India in September 2025 to examine the acquisition procedures of GZRRC and RKTEWT.
Secretariat flags legal concerns
Although the Secretariat acknowledged that GZRRC and RKTEWT maintain “exceptionally high standards” for facilities and veterinary care suitable for housing Appendix I animals, its assessment concluded that India’s handling of these imports may contravene fundamental principles of the Convention.
The Secretariat’s review identified multiple major irregularities surrounding the acquisition of thousands of animals, in particular the 2,132 Appendix I specimens imported by GZRRC.
Inadequate due diligence on permits
The Indian CITES authorities admitted that their standard due diligence procedures typically did not extend beyond verifying the authenticity and validity of export permits or re-export certificates with the exporting country’s Management Authority (MA).
The Secretariat stressed that India accepted permits “on face value” even when circumstances—such as high-risk origins—should have warranted stricter scrutiny.
Misuse of the “bred in captivity” designation (source code C)
The reports points out that a vast majority of the imported Appendix I specimens—2,049 individuals—were traded using source code C, denoting “bred in captivity.”
The Secretariat expressed concern that many of these specimens may not meet the strict CITES criteria defined in Resolution Conf. 10.16 (Rev. CoP19), which generally requires animals to be of the second generation (F2) or subsequent generations in order to qualify as genuinely captive-bred.
Large imports inconsistent with Article II’s exceptional-circumstance requirement
The Secretariat noted that the sheer number of imports of Appendix I species appears inconsistent with Article II, paragraph 1, of the Convention, which requires that trade in these highly endangered species be authorized only in “exceptional circumstances.”
Trade from high-risk, non-range States
Indian authorities failed to apply sufficient due diligence when Appendix I species—such as cheetahs, chimpanzees, gorillas and orangutans—were imported from countries that are not range States for those species and are not known for captive breeding.
This included specimens coming from the United Arab Emirates, Iraq and the Syrian Arab Republic. The Secretariat pointed to an instance in which a bonobo was re-exported from the United Arab Emirates with Iraq listed as the country of origin, despite Iraq not being a bonobo range State or being known for breeding the species.
Conflicting accounts on mode of acquisition
The report states that GZRRC and RKTEWT representatives stated that animals were not purchased but instead were rescued, confiscated or donated. However, information provided by the Czechia Management Authority included invoices listing animals acquired, price per unit and taxes, suggesting that the animals exported to GZRRC were sold. The Secretariat regarded this inconsistency as material to transparency and compliance.
Attraction of forged permits and trafficking attempts
According to the report, the high volume of acquisitions by GZRRC and RKTEWT appears to have attracted the attention of entities attempting to traffic animals. The Secretariat received copies of forged export permits for eight chimpanzees allegedly from Cameroon.
Indian authorities initially granted import permissions without sufficient due diligence and only cancelled them after GZRRC’s own internal inquiry raised red flags.
Discrepancy in purpose codes for re-exported animals
In the case of two snow leopards re-exported from Germany, the German MA issued the export permit with purpose code T (commercial) because it was not convinced the criteria for purpose code Z (zoological) were met.
Nevertheless, the Indian MA, relying on a donation letter from the importer, issued the import permit with code Z without contacting the German MA for clarification. The Secretariat highlighted this as an example of insufficient cross-party verification.
Immediate recommendation: halt Appendix I imports until controls are reinforced
The CITES Standing Committee was invited to recommend that India not issue any further import permits for specimens of species listed in Appendix I until India has fully implemented reinforced due diligence and control measures and provided evidence of that implementation to the Secretariat.
Secretariat’s urgent appeal to India
The Secretariat urged India to review and strengthen its import procedures by implementing robust, risk-assessment-based due diligence designed to systematically detect irregularities prior to issuing permits.
It requested that India increase scrutiny in cases where species unlikely to be captive-bred are presented as such or when the origin of an animal is unclear.
The Secretariat asked India to liaise with exporting and re-exporting Parties—including the Democratic Republic of the Congo, Germany, Mexico, Iraq, the Syrian Arab Republic and the United Arab Emirates—to verify that imported animals comply with CITES provisions, particularly the definition of “bred in captivity.”
The Secretariat also requested that India assess and ensure that its CITES Management Authority is sufficiently resourced to carry out its complex functions, coordinating closely with the Scientific Authority and the Wildlife Crime Control Bureau (WCCB).
Secretariat warning on risks of continued lax controls
The Secretariat stressed that without reinforced due diligence, India risks inadvertently importing animals that may have been sourced from the wild but falsely declared as captive-bred.
It warned that the high level of acquisitions could become a potential driver of demand for illegally sourced animals, undercutting CITES objectives and international conservation efforts.