The Director-General: Department of Forestry, Fisheries and the Environment
FAO: Ms Magdel Boshoff
Private Bag X447
Pretoria 0001

Delivered by email to: revisedlionprohibition@dffe.gov.za 

19 November 2024

Comments on the Draft Notice Prohibiting Certain Activities Involving African Lion (Panthera leo)

Dear Ms Boshoff,

Thank you for the opportunity to comment on the Draft Notice prohibiting certain activities involving African lion (Panthera leo), gazetted under notice 51581.

We are in full support of the Minister’s decision to implement appropriate and necessary measures to avoid the establishment of new captive lion facilities whilst the voluntary exit process is underway and legislation under consideration to phase out the commercial captive lion industry in South Africa. 

Blood Lions is in full support of the following issues: 

1. With regards to captive lions, we fully support the initiative to prohibit the establishment and registration of any new breeding, exhibition or rehabilitation facility or any other type of captive lion facility. This initiative is a positive step towards preventing any further growth of the captive lion industry. 
2. We support the inclusion of ecological reasons to stop the domestication of lions and move towards a future in which South Africa holds no lions in captivity. As outlined in the prohibition notice, apex predators have complex needs, including social organisation, diverse diet, hunting behaviour, and territorial nature, that are central to their overall welfare and well-being. These complex needs are best provided for in natural environments and functioning, self-sustaining ecosystems. 

The recognition that controlled environments cannot adequately account for the complex needs of these apex predators is an important and necessary step towards phasing out the commercial captive lion industry. It demonstrates the Minister’s progressive recognition of in-situ biodiversity conservation, animal well-being and the need to restore South Africa’s reputation as a leader in the conservation of wildlife and as a responsible tourism destination with iconic wild lions.

Blood Lions have concerns with regards to the following issues: 

1. The exclusion to establish and register a new sanctuary. Even though the proviso has been made that the Minister should determine that such a new sanctuary is necessary to accommodate sterilised captive lions arising from the voluntary exit process, we feel that this exclusion can be used as a loophole.

Any commercial captive lion facility could potentially register their commercial captive lion facility as a sanctuary, especially since permits are issued on a provincial rather than national basis and the TOPS definition of sanctuary is too ambiguous:

A sanctuary means “a facility that provides permanent care to a specimen of a listed threatened or protected species that would be unable to sustain itself if released in an environment other than a controlled environment, irrespective of the reason for such inability”. This definition specifies neither conditions to guarantee the welfare and well-being of the wild captive animals in such a controlled environment, nor in terms of breeding and/or trading practices. 

If the Minister wants to leave the opportunity open for the establishment of sanctuaries that can accommodate some of the surrendered lions coming out of the voluntary exit process and/or the future prohibition, such facilities should be identified solely as being run under internationally recognised best practices that allow for the welfare and well-being of these apex predators to be guaranteed, as outlined in the various protocols developed by the Ministerial Task Team. 

Currently, numerous commercial captive lion facilities in South Africa have already included the word ‘sanctuary’ within their business name to create the impression that their facility/predator park rescues and/or rehabilitates wildlife, rather than having vested interests in commercial activities. We are concerned that such a loophole may encourage this practice to expand, which would not only deceive the public but also allow commercial activities to continue under the guise of a sanctuary label, and thus leaving the system wide open for abuse. 

2. Our second concern relates to the omission of prohibiting captive breeding of lions at existing commercial facilities. The continuation of captive breeding perpetuates the growth of the captive lion population and the associated animal welfare and well-being implications. This will in turn hamper the phase out process by increasing the number of captive lions that may require veterinary care, sterilisation, potential euthanasia, and/or lion safe haven space. 

It is therefore critical that a moratorium on captive breeding of lions is implemented as soon as possible to expedite not only the voluntary exit but also the ultimate closure of the commercial captive lion industry.