The National Wildlife Action Plan was adopted in 2004. It entailed identifying ecologically fragile areas and wildlife corridors within 10 km of protected areas, and getting states to notify them as eco-fragile zones under the Environment (Protection) Act, 1986. But there was no progress in some states. In 2005, Goa Foundation, a Goa-based environment monitoring group, filed a petition in the Supreme Court stating that Maharashtra and Goa had not declared eco-sensitive areas.

Meanwhile, Rajasthan, Goa and Himachal Pradesh filed interlocutory petitions before the Supreme Court's Central Empowered Committee stating the eco-sensitive area policy would affect development projects and people's livelihoods. The Union Ministry of Shipping, Road Transport and Highways also raised concerns over the 10-km range stating that highway development would be affected.