Even if there is no notification of wildlife sanctuaries and buffer zones, the Supreme Court can say that you (state government) are obliged under Article 21 (right to life) of the Constitution to protect life including the environment and that you can’t exploit within this area.
” These were stern observations of the Supreme Court, while hearing the lessees who were arguing why and how it was legal for them to be mining within one kilometre of wildlife sanctuaries, on the eighth day of hearing of the Goa mining case.