Odisha has formally recognised 10 habitat rights claims covering eight Particularly Vulnerable Tribal Groups, marking a significant advance under the Forest Rights Act, 2006.
The first title went to the Paudi Bhuyan community in Deogarh district in March 2024, covering 32 settlements and protecting the Maa Rambha Devi sacred grove.
Habitat rights recognise community landscapes that often span multiple settlements, sacred sites, forests, grazing areas and livelihood zones, rather than individual plots or single villages.
The author argues that legal recognition must now be followed by bio-cultural landscape management plans, so these titles become living governance systems rather than paperwork.
On March 7, 2024, the Paudi Bhuyan community in Deogarh district, Odisha, received an entitlement that 18 years of law had promised but never delivered anywhere in the state: a formally recognised habitat right.
The title covered 32 settlements under Barkote block and included legal protection for the community’s Maa Rambha Devi sacred grove. It was the first habitat rights title granted to any of Odisha’s 13 Particularly Vulnerable Tribal Groups, or PVTGs. Seven more communities followed within the year.
This account traces how that outcome came about and argues that recognition is only the first of two steps. The second is a structured bio-cultural landscape management plan. Without it, these hard-won titles risk becoming paperwork rather than practice.
India’s Forest Rights Act, 2006, recognises several tenure categories for forest-dwelling communities. But Section 3(1)(e), which grants “community tenures of habitat and habitation” for primitive tribal groups and pre-agricultural communities, has proved the hardest to implement.
Unlike Individual Forest Rights or Community Forest Resource rights, which attach to a village, habitat rights attach to an entire community, often spanning multiple settlements and districts.
Odisha has the largest stake in this provision. It is home to 13 PVTGs, the highest number of any Indian state. They are spread across 1,683 villages in 285 gram panchayats, 42 blocks and 14 districts, with a population of about 7.7 lakh.
India’s first habitat rights title went to the Baiga community in Madhya Pradesh in 2015, followed by the Bharia and Kamar. But for 13 years, no PVTG in Odisha received one. A major reason was the lack of clarity around the concept of “habitat”.
In some states, the Hindi text translated “habitat” as “aawas”, or house, leading officials to treat housing schemes as a substitute for what the law intended. The Ministry of Tribal Affairs clarified the distinction in April 2015, but implementation remained slow.
Before Odisha’s statewide effort, important groundwork had already been laid through pilot initiatives between 2013 and 2016.
Vasundhara, a non-government organisation, helped facilitate these efforts with District Level Committees, Integrated Tribal Development Agencies and PVTG traditional institutions. The process followed a 2014 national study by the Union Ministry of Tribal Affairs and the United Nations Development Programme, which proposed a broad approach for determining habitat rights while identifying recurring obstacles: absence of guidelines, confusion over non-forest land within habitats and limited awareness among officials.
One such effort began in 2014 with the Kutia Kondh of Kandhamal. It found that the community’s habitat did not rest on a single boundary, but on a nested structure of clan territories built from smaller padars — hill-centred landscapes unified by reverence for the sacred grove of Sapangada. With more than 100 clan territories across about 168 hamlets, claims were pursued clan by clan before consolidation.
A parallel process with the semi-nomadic Mankirdia, or Birhor, of Mayurbhanj covered nine villages on the fringes of Similipal forest. It documented their dependence on siali fibre collection, newly secured as minor forest produce under the Act, and ended with all nine villages agreeing to a single shared claim.
These pilots shaped the methodology later applied statewide: reliance on traditional institutions, layered clan-level mapping, and recognition of habitat as cultural and genealogical as much as geographic.
This background led the Scheduled Castes and Scheduled Tribes Research and Training Institute, Bhubaneswar, under Odisha’s ST & SC Development Department, with the Ministry of Tribal Affairs and Vasundhara, to undertake a statewide study in 2021 to map potential habitat rights for all 13 PVTGs.
Across 20 Micro Project Areas, the study combined Census and 2015 baseline data, hand-drawn community maps and GIS overlays. It used geographic, livelihood and socio-cultural markers to delineate each habitat.
Potential habitat maps were prepared for 11 of the 13 PVTGs across 17 Micro Projects, totalling about 2.27 million hectares. The Mankirdia habitat alone accounted for more than 812,000 hectares, followed by the Juang at 440,924 hectares across three districts and the Paudi Bhuyan at 386,468 hectares. The Kutia Kondh and Bonda habitats were the smallest, at 63,374 hectares and 65,861 hectares respectively.
Two communities, the Lodha of Mayurbhanj and the Lanjia Saora of Gajapati and Rayagada, opted instead for Individual Forest Rights and Community Forest Rights village by village.
Nine PVTGs across 14 Micro Projects carried claims to the Sub-Divisional Level Committee. The Mankirdia claim alone reached the District Level Committee by 2022. The rest followed in 2024, when all 10 claims were approved and titles distributed.
Odisha’s district administrations then converted a substantial share of these claims into formal recognition at a pace without precedent among Indian states.
Of 14 claims on record, 10, covering eight PVTGs, have been formally recognised. Together, they account for 625 constituent communities and hamlet clusters, 18,811 households, and nearly 1.65 million hectares of forest and revenue land.
The largest recognised habitat is that of the Mankirdia, at 812,932 hectares across just nine communities. The smallest is that of the Bonda, at 11,860 hectares across 78 communities. The Juang of Keonjhar alone account for 134 communities and more than 207,000 hectares.
The Paudi Bhuyan of Deogarh received the first title on March 15, 2024, covering 32 villages in Barkote block. The remaining nine recognitions — the Juang of Jajpur and Keonjhar, Chuktia Bhunjia of Nuapada, Saora of Gajapati, Mankirdia of Mayurbhanj, Paudi Bhuyan of Angul, Hill Kharia of Mayurbhanj, Kutia Kondh of Kandhamal, and Bonda of Malkangiri — were distributed on November 15, 2024.
Two qualifications matter.
First, recognition has been uneven even within a single community’s landscape. The Bonda’s recognised habitat covers 11,860 hectares of forest and revenue land, while the 2022 Atlas had estimated their full customary landscape, including non-forest hills, grazing grounds and unclassified slopes, at closer to 65,000 hectares.
Land records categorise “forest” and “revenue” land, but do not capture most non-forest customary use. This means parts of what communities consider habitat may fall outside the recognised boundary unless separately claimed.
Second, four claims remain filed but unrecognised: the Paudi Bhuyan of Sundargarh, Saora of Ganjam, Juang of Dhenkanal and Didayi of Malkangiri. Two more, including the Dongaria Kondh of Rayagada and the Kutia Kondh of Lanjigarh in Kalahandi, remain mapped only in outline.
Sensitivity around the Niyamgiri landscape, after years of contestation over bauxite mining, has made it difficult to convene the gram sabha meetings required for formal recognition.
Section 5 of the Forest Rights Act already empowers rights holders “to protect, regenerate, conserve or manage” the resources over which their rights are recognised. FRA Rule 4(1)(e) requires a conservation and management plan wherever Community Forest Resource rights are vested.
No equivalent framework yet exists for habitat rights areas, even though these are larger, more ecologically varied and culturally denser than standard Community Forest Resource areas.
Eight Odisha PVTGs across 10 Micro Projects now hold legal titles, but there is no plan to translate these into governance. This is the most significant unfinished part of the story, and the immediate policy priority.
Such a plan should integrate ecological management with the spiritual, social and livelihood dimensions that distinguish habitat rights from ordinary tenure.
It should include Habitat Rights Management Committees rooted in each community’s traditional institutions and federated across villages within a habitat; formal sacred-site protocols, building on the precedent set by the Paudi Bhuyan’s protected Maa Rambha Devi grove, endorsed through gram sabha resolutions; community-authored calendars for sustainable harvesting and rotational cultivation; and convergence with schemes such as Van Dhan Vikas Kendras, the Pradhan Mantri Janjatiya Vikas Mission and DAJGUA.
It should also explore registration as Indigenous and Community Conserved Areas or Other Effective Area-based Conservation Measures, alongside funding from CAMPA and the Green India Mission. Capacity building of traditional leaders, women and youth as community para-ecologists, and a five-year review cycle using the original Habitat Rights Atlas as a monitoring baseline, would be equally important.
Odisha’s 10 habitat rights recognitions represent the most significant advance anywhere in India on one of the Forest Rights Act’s most demanding provisions.
But a title secures a boundary in law. It does not, by itself, create practice on the ground.
The communities that waited 18 years for recognition now need what Section 5 already anticipates: the tools, institutions and financing to manage what is theirs.
Whether Odisha turns its lead in recognition into an equal lead in bio-cultural landscape management will decide whether these titles become living governance arrangements, or paperwork alongside the four claims still waiting.
The author was part of the research team, on behalf of Vasundhara, for the “Mapping of Potential Habitat Rights of PVTGs under FRA in Odisha” study, 2022, conducted by SCSTRTI, Bhubaneswar, under the ST & SC Development Department, Government of Odisha, with support from the Union Ministry of Tribal Affairs, in partnership with Vasundhara. Figures on habitat rights recognition are drawn from district-wise records compiled as of 2024, supplemented by publicly reported recognition dates from state government and news sources.
Aurobindo Rout is programme director, forest rights and governance, Vasundhara. Views expressed are the author’s own and don’t necessarily reflect those of Down To Earth