The Kerala High Court on August 17, 2026, disposed of a writ petition filed by director Tharun Moorthi and producer Ashiq U.E., the makers of the Mohanlal-starrer Malayalam film 'Athimanoharam', seeking a direction to the Forest Department officials to consider their request for permission to shoot the film in Pamba and Sannidhanam areas within the Periyar Tiger Reserve.
The Division Bench comprising Justice Raja Vijayaraghavan V. and Justice K.V. Jayakumar took note of the submission made by the Special Government Pleader for Forests that the Deputy Director of Periyar Tiger Reserve had rejected the filmmakers' request. The Bench observed that the rejection was based on the decision in Angels Nair v. The Principal Secretary and Ors., and further reinforced by the directions issued by a Division Bench in Writ Appeal No. 2179 of 2023 and the Government order dated August 26, 2025, which collectively prohibit the granting of permission for shooting commercial films and television serials within Wildlife Sanctuaries, National Parks, or Tiger Reserves.
The Court recorded that the Deputy Director had taken the stand that the areas mentioned in the representation—Pamba and Sannidhanam—form part and parcel of the Periyar Wildlife Sanctuary and the Periyar Tiger Reserve. Although these areas have been leased or diverted in favour of the Travancore Devaswom Board for facilitating the Sabarimala pilgrimage, the legal status of such leased or diverted forest land remains unchanged, and thus falls under the prohibitive regime applicable to protected areas.
The petitioners had obtained permission from the Devaswom Commissioner of the Travancore Devaswom Board, but such permission was conditional upon obtaining prior clearance from the Chief Conservator of Forests, the Deputy Director of Periyar Tiger Reserve, and the Division Forest Officer, Pathanamthitta. The filmmakers then made representations before the Division Forest Officer and the Deputy Director.
Regarding the representation before the Division Forest Officer, the Court noted that permission was granted after considering a report from the Range Forest Officer, Goodrical, which identified the proposed shooting locations as the 'Tea Shop opposite to the Pamba petrol bunk' and the 'Pamba KSRTC bus stand and surroundings'. The Division Forest Officer, after reviewing the report, decided that film shooting could be permitted in these locations from August 18 to August 28, 2026, subject to payment of prescribed fees and execution of the requisite agreement with the Forest and Wildlife Department.
However, the Deputy Director of Periyar Tiger Reserve had rejected the request, citing the aforementioned legal prohibitions. The Court had earlier passed an interim direction to the Deputy Director to consider the representations after hearing the parties, but upon reconsideration, the Deputy Director maintained the rejection.
Since decisions had already been made by the concerned officials—the Division Forest Officer granting permission for specific locations and the Deputy Director refusing it for the broader area—the Court observed that nothing survived in the plea for a direction to reconsider. The petitioners, however, sought to reserve their right to challenge the Deputy Director's decision independently.
Recording the petitioners' request to reserve their right to challenge the Deputy Director's order, the Court disposed of the writ petition. The case was listed as WP(C) No. 28032 of 2026, titled Tharun Moorthi and Anr. v. State of Kerala and Ors. Counsel for the petitioners included Lakshmi Narayan (Sr.), R. Rajanie, Vaishnavi Shaji, and Nevil Zacharia Mathew, while the respondents were represented by Syam Kumar C.R., Special Government Pleader for Forests, and G. Biju, representing the Travancore Devaswom Board.