By Raj Kumar Srivastava, IFS (Retd.)
India has long aspired to transform agroforestry into an engine of prosperity—doubling farmers’ incomes, expanding tree cover, and delivering on climate commitments.
The recently notified Model Rules for Tree Felling on Agricultural Land were announced with great fanfare, promising to simplify processes and encourage farmers to plant trees.
Yet behind the polished portals and optimistic press releases lies a sobering truth: this is not genuine deregulation. It is the same old control mindset—merely digitised.
🌱 Digitisation Without Deregulation
At the heart of the new rules is the National Timber Management System (NTMS). This online platform requires farmers to:
Register every plantation in detail—species, planting date, ownership documents, geolocated photos.
✅ File applications before felling.
✅ Upload “stump images” after harvest.
✅ Wait for inspections and a transit permit.
On paper, this may appear modern. In practice, it simply moves the burden from files and signatures in forest offices to online compliance—without reducing the burden itself.
“Planting trees continues to carry hidden transaction costs, delays, and the fear of harassment.”
For the average smallholder, little has changed.
🌱 A Persistent Presumption of Guilt
The new rules are still driven by an old mindset: that farmers cannot be trusted to manage trees on their land without supervision.
We do not ask a farmer to register every paddy field or seek permission to harvest sugarcane. But the moment a tree is involved, the State insists on oversight.
This presumption of guilt is exactly why many farmers hesitate to invest in long-cycle timber crops. A single paperwork error can lead to seizure of produce and penalties.
The new rules miss the opportunity to build trust and remove this historical baggage.
🌱 Confusion Over Species
One of the biggest deterrents to agroforestry has been the uncertainty over which species require permissions. Different states maintain different lists, creating confusion and inhibiting investment.
Instead of providing clarity—a simple national “negative list” of protected species—the Model Rules leave it to each state committee to decide.
“This preserves the same patchwork of restrictions farmers have grappled with for decades.”
For smallholders, the risk of entanglement in red tape remains high, especially for commercially valuable species like teak or sandalwood.
🌱 Markets Ignored
While the rules focus heavily on regulating felling and transport, they say almost nothing about enabling markets.
A truly progressive policy would have:
✅ Recognised standing trees as collateral for credit.
✅ Enabled tripartite agreements between farmers, wood processors, and banks.
✅ Promoted insurance products for timber crops.
✅ Created transparent e-marketplaces for price discovery.
Instead, the policy concentrates narrowly on compliance, leaving market development unaddressed.
🌱 Discretion Without Accountability
The rules also grant broad powers to state-level committees—who can decide verification processes, empanel agencies, and define species lists.
While flexibility is important, in practice this can lead to inconsistent interpretations, arbitrary delays, and bureaucratic opacity.
The promise of “ease of doing business” risks becoming just another slogan.
🌱 Superficial Transparency
Much has been made of how the NTMS will create traceable supply chains aligned with international regulations.
But rather than making traceability optional—so that farmers targeting export markets can opt in—the system forces all farmers to comply.
“This one-size-fits-all approach imposes compliance costs on the smallest farmers while doing little to incentivise genuine market differentiation.”
🌱 The Road Not Taken
India’s agroforestry aspirations require a different approach: one that trusts farmers as partners, not suspects.
A truly transformative policy would have included:
✅ Presumption of freedom—harvest and sell any tree unless it belongs to a short, notified list.
✅ Time-bound approvals with deemed consent after a fixed window.
✅ Optional certification for those who want premium market traceability.
✅ Enabling credit and insurance support.
✅ Developing transparent markets and price information systems.
🌱 Conclusion: A Historic Opportunity at Risk
India has pledged to increase tree cover outside forests, create green jobs, and diversify rural incomes. But aspirations must be matched by policies that genuinely empower.
Replacing old paperwork with new portals, while retaining the same permissions architecture, will not build trust or unlock investment.
“Until we abandon the presumption that private timber must be policed, agroforestry will remain underperforming—strangled by outdated instincts of control.”
The Model Rules are a retrograde step, masquerading as reform. We must do better if farm forestry is to become the transformational force it can—and should—be.
(The author is a former Principal Chief Conservator of Forests and presently heads NbS and Strategy at IORA Ecological Solutions. Views are personal.)