The doctrine of finality and res judicata prevent the reopening of settled legal matters investigated by a court-mandated body. Unauthenticated digital evidence lacks the probative value required to initiate fresh criminal investigations against individuals who have already undergone detailed judicial scrutiny.

1. By the present Miscellaneous Application, the applicant/petitioner seeks recall of the Order dated 09.03.2026 passed by this Court in Writ Petition (Civil) No.1113 of 2025 by which this Court declined the reliefs prayed for and affirmed the Order dated 15.09.2025 in Writ Petition (Civil) Nos.783 and 779 of 2025 accepting the Report of the Special Investigation Team¹For short, ‘SIT’ in respect of the affairs of respondent Nos.5 and 6.

2. The case put forth by the applicant is that material has since emerged in inquiries, investigations or prosecutions in Brazil, the United Arab Emirates, Uganda, Peru, Malaysia and Venezuela bearing upon the international acquisition and transfer of animals by respondent Nos.5 and 6 which warrants a fresh investigation by the Indian agencies or by foreign or global agencies. Reliance is also placed on an agenda document SC79 Document 6.3.4 of the Secretariat of the Convention on International Trade in Endangered Species of Wild Fauna and Flora²For short, ‘CITES’ and the decision of the CITES Standing Committee thereon at its 79th Meeting, which, taken with the foregoing foreign material, are said to require registration of cases by the appropriate law enforcement agencies against respondent Nos.5 and 6 and their associated Trust - Khodiyar Animal Welfare Trust and assisting foreign or global agencies in investigation, prosecution, etc.

3. In substance, the following reliefs have been prayed in this Miscellaneous Application:

i. Directions to the Central Government through the Central Bureau of Investigation³For short, ‘CBI’, the Directorate of Revenue Intelligence⁴For short, ‘DRI’, the Wildlife Crime Control Bureau⁵For short, ‘WCCB’, the Customs Department and the Enforcement Directorate⁶For short, ‘ED’, to investigate and coordinate with the foreign proceedings aforesaid and to seize, repatriate or otherwise dispose of any specimen traded in contravention of the Convention and to examine employees of respondent Nos.5 and 6 for leads, evidence or information;

ii. Directions for the issuance of letters rogatory to the said jurisdictions, for INTERPOL notices, and for engagement with the CITES Secretariat, the INTERPOL Wildlife Crime Working Group, the International Consortium on Combating Wildlife Crime, the Wildlife Justice Commission and the Environmental Investigation Agency;

iii. An independent inquiry into the functioning of the Wildlife Division of the Ministry of Environment, Forest, and Climate Change, the CITES Management Authority of India⁷For short, ‘CMA India’ and the Central Zoo Authority; and

iv. Seizure of the specimens held at the Jamnagar facility and its takeover by the Government of India.

4. We have heard the learned senior counsel on behalf of the applicant/petitioner and the learned counsel for respondent Nos.5 and 6 and have perused the material, including the SIT Report. Upon consideration, we are of the clear opinion that none of the directions prayed for can be granted. We, however, propose to issue certain directions to the CITES Management Authority of India to strengthen the regime of compliance with the Convention so as to forestall avoidable controversy.

5. The SIT was constituted by this Court with members of standing and distinction which was presided over by a former Judge of this Court and comprised a former Chief Justice of a High Court, a former Commissioner of Po