Environmental Foundation (Guarantee) Ltd and Another vs. Director General of Wildlife Conservation and Others – sllr 2020 volume 1 page 366

In Environmental Foundation (Guarantee) Ltd and Another v. Director General of Wildlife Conservation and Others, the court considered whether the Fauna and Flora Protection Ordinance required parliamentary approval for the initial declaration of a National Reserve or National Park and examined the validity of a supporting affidavit executed by a Commissioner for Oaths employed by the 1st Petitioner. The primary holding determined that the affidavit was invalid due to contravention of statutory requirements, resulting in no proper application before the court. The principle reaffirmed is that a petition is fundamentally defective without a valid supporting affidavit where statutory prohibitions are explicit. Statutory interpretation and case law were relied upon, with emphasis placed on the