INTRODUCTION
There is something uniquely striking about the presence of the Indian one-horned rhinoceros; a quiet strength that reflects both resilience and continuity. In Assam, this remarkable species is far more than just wildlife; it is deeply intertwined with the state’s cultural identity, economic vitality, and social fabric.
A century ago, when protection efforts began in the floodplains of Kaziranga National Park, only a handful of one-horned rhinos remained. Today, their numbers have risen to more than 2,400, accounting for nearly two-thirds of the world’s population. India now holds almost 70% of the global population of this species, making Assam the undisputed stronghold of the one-horned rhinoceros.
This remarkable recovery, however, has not come without challenges. Even as the rhino population steadily increased over the decades, threats like poaching continued to test conservation efforts. Yet, the survival and growth of the species stand as a testament to the resilience of both nature and the people committed to protecting it.
For Assam, the one-horned rhinoceros is not only an ecological success story but also a symbol of pride. It is a driver of tourism and livelihoods, and a defining element of the state’s identity. In many ways, Assam without its one-horned rhino is almost unimaginable, for the two are inseparably linked in spirit and significance.
THE KAZRINRANGA MODEL
At the turn of the 20th century, the fate of the one-horned rhinoceros in Kaziranga National Park hung by a thread. By 1908, their population had plummeted to a shocking low of around just 12 individuals, pushing the species to the edge of extinction. Rampant hunting and habitat loss had nearly erased these iconic animals from Assam’s landscape.
However, a remarkable conservation journey began with strong government intervention and sustained policy efforts. Over the decades, targeted conservation strategies gradually reversed this decline.
Yet, the biggest hurdle remained poaching, which peaked alarmingly in the late 20th century. The year 1992 recorded the highest number of poaching incidents at 49, with similarly troubling figures, over 40 cases, in years like 1985, 1986, 1989, and 1993.
A turning point came after 2016, when intensified measures under the state government drastically improved the situation. Poaching dropped by an impressive 86%, reflecting the success of a strict “zero tolerance” policy.
The success led to the emergence of the “Kaziranga Model” as a globally recognised benchmark in wildlife conservation. Central to this model is a robust protection system, including a commando-style special protection force and a dense surveillance network.
Today, the park is guarded by 233 anti-poaching camps, each staffed with three to five personnel, ensuring one camp roughly every 5.82 square kilometres.
The results have been striking. In the last five years, only five poaching incidents have been recorded, with zero cases reported in both 2022 and 2025. Meanwhile, the rhino population surged from 2,048 in 2009 to 2,613 in the 2022 census.
Beyond conservation, eco-tourism has flourished, with visitor numbers rising by 205%, from 1.31 lakh in 2014 to over 4 lakh in 2025, showcasing how protection and sustainable development can go hand in hand.
BUT WHAT ABOUT HUMAN RIGHTS?
The shoot-at-sight policy in Kaziranga National Park raises serious human rights concerns, particularly because it fails to distinguish between actual poachers and innocent civilians. Many villagers residing near the park depend on forest resources and may accidentally enter the area due to the absence of clear boundaries, as the park often merges seamlessly into the nearby fields and settlements. In such a context, treating every unauthorised entry as a threat creates a dangerously broad scope for the use of lethal force.
From a legal perspective, such a policy must be examined in light of Article 21 of the Indian Constitution, which guarantees that no person shall be deprived of life or personal liberty except according to a procedure established by law. This procedure must always be fair, just and reasonable. It is also important to note that the right to life applies to every individual, including those accused of criminal activities.
Furthermore, the Indian judiciary has repeatedly condemned extra-judicial killings and stressed that law enforcement authorities cannot act as judge, jury or executioner. Even where a person is suspected of poaching, guilt must be determined through legal procedures rather than through the use of force.
This concern becomes deeply personal and real in cases like that of a young man named Goanbaruah, who was shot dead by forest guards in 2013. According to his family, he had severe learning disabilities and had entered the forest only to search for their missing cattle. He was allegedly shot for not responding to a warning. This incident highlights the tragic consequences of a policy that allows instant use of deadly force without assessing individual circumstances, especially when those affected may not even fully understand the situation.
A few of the issues are highlighted below:
Lack of Accountability: The issue is further aggravated by the lack of accountability mechanisms. Forest guards often enjoy significant legal protection, making it extremely difficult for victims’ families to seek justice. As Goanbaruah’s father expressed, poverty and systemic barriers prevent people like him from even approaching courts. This creates a system where state power operates without effective checks, increasing the risk of wrongful execution going unpunished.
Human Rights Concerns: The numbers tell a story that cannot be undermined. In the year 2015, more people (25) were shot dead by park guards than rhinos (17) were killed by poachers. Similarly, in 2014, 22 poachers were shot dead. ‘Kill the unwanted’ was the clear strategy guiding the forest guards, but it is deeply questionable and demands scrutiny. Such an approach risks crossing into human rights violations, especially when it targets vulnerable communities or bypasses due process.
Risk of Misuse of Power and Impact on Marginalised Communities: The policy opens the door to misuse of power and corruption. With such wide discretion, there is a possibility that force could be used for personal benefit or to conceal misconduct, including illegal activities. The absence of fair trial and due process means that individuals are punished instantly, without investigation or evidence, violating the very foundation of criminal justice. Marginalised communities, especially those dependent on forest resources, are disproportionately affected, as their daily survival often brings them close to such restricted areas. As a result, they are more vulnerable to being misidentified and subjected to violence.
Need for Rights-Based Conservation Approach: While the protection of endangered species like the Indian One-Horned Rhinoceros is crucial, it cannot justify a system where human life is taken without trial, accountability, or proportionality. Conservation must operate within the framework of constitutional rights, human dignity, and the rule of law, rather than at the cost of them.
CONCLUSION
Assam’s rhinos are more than wildlife; they are living symbols of identity, heritage, and ecological balance. While the government’s strong stance against poaching has contributed to conservation success, policies like zero tolerance and shoot-at-sight raise serious ethical and human rights concerns that cannot be ignored. Conservation must not come at the cost of justice. A sustainable future for Assam’s rhinos lies in balancing protection with accountability, community participation, and respect for human dignity. Only by aligning conservation goals with humane governance can Assam truly safeguard both its iconic species and the rights of its people.
Authors: Dishamoni Deka & Himonjyoti Parasar (University Law College, Gauhati University)
References:
- W.A Laurie et al, ‘Rhinoceros unicornis’, Mammalian Species (211), 1983 pp 1-6
- ‘Assam records 86% drop in rhino poaching since 2016: CM’ The Hindu (23 September 2024) <https://www.thehindu.com/news/national/assam/assam-records-86-drop-in-rhino-poaching-since-2016-cm/article68670734.ece> accessed 27 April, 2026
- Nootan Sharma, ‘Assam went to war on Kaziranga poachers. Rhinos are winning’ The Print (05 March 2026) <https://theprint.in/ground-reports/assam-went-to-war-on-kaziranga-poachers-rhinos-are-winning/2867701> accessed 28 April 2026
- Om Prakash v State of Jharkhand (2012) 12 SCC 72; Extra Judicial Execution Victim Families Association (EEVFAM) v. Union of India (2017) 14 SCC 536
- Justin Rowlatt, ‘Kaziranga: The park that shoots people to protect rhinos’ BBC (10 February 2017) <https://www.bbc.com/news/world-south-asia-38909512> accessed 27 April 2026
