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Sunday , 26 April 2020

Ms Kusuma M

DD, Horticultural Department

Cubbon Park

Bangalore 560001

Dear Madam: 

Sub: Conservation and appropriate use of Heritage structure at Cubbon Park given to Karuna Animal Welfare

This has reference to our earlier discussion on the issue of the heritage SPCA structure now called Karuna Animal Shelter opposite the Queen Victoria statue. Records show SPCA was set up in 1888 but registered as a charity in May 1916. Originally in the early 1900s,  this was used for upkeep and treatment of the horses of the  Mounted police or British horse riders in the park , as well as taking care of any accident or cruelty cases to other animals like dogs and cats via SPCA. Post-independence, it was re allotted to  Bangalore SPCA. 

This office has been largely unused for the last 10 years after Bangalore SPCA was formally shut down in Bangalore and the former NGO now re structured as Karuna Animal shelter in the late 1980s, continued from its new name as of 2001. Both Heritage supporters and Animal Welfare people have been surprised that this office has been completely non-functional, hardly occupied, and very rarely responsive on issues of Animal Welfare. Calls to the number largely go unanswered and most trauma or accident cases that happen close by anyway are sent to CUPA or CARE instead. This is an underuse of central location to address cases of animal cruelty. Since there is little clarity on why and how it is there, and perhaps because no one has questioned it, it has continued in this odd limbo. This needs to be addressed and better late than never.

While the transfer to a private NGO like Karuna  may have happened by default and perhaps with a good intention to continue the good work of Animal Welfare, we are concerned that both from an ownership perspective and a functional perspective of delivering on Animal Welfare there is no upside or positive impact at all. Even accident or trauma cases in Cubbon Park with the Park dogs are not treated here, as there is no one in the office most of the week. We understand that this tiny structure comes under the purview of the Horticulture department and since this is largely unused we would request that this be used a living museum highlighting Cubbon Park heritage, showcase the historical animal care focus, animal trauma coordination, and the back area be reserved for any animal trauma at Cubbon park itself. As you are aware many  from The CJ Memorial Trust and Cubbon Park Canines group look after the hundred or so dogs in the park. This would be very beneficial for us to ensure the few dogs that get hurt or need treatment can be temporarily housed until we transfer them to a shelter or hospital for treatment . To this extent, a couple of rusted cages already there that can be repaired and used .

We have been meaning to discuss this for the last few years but with one thing or the other it has been passed over for bringing it to your attention. However considering the tremendous concerns around heritage and preservation as well as lack of functionality of the animal shelter that we would request that the suggestions that we have given, as well as an oversight for helping on this from the Animal Welfare aspect can be considered, so as to provide continuity towards its original  purpose as well as maintain this beautiful though small heritage structure.

We look forward to hearing from you and to your kind and immediate action on this matter. 


Thanking you ,

Your sincerely



Priya Chetty-Rajagopal 

Founder, #HeritageBeku 

cc BBMP Commissioner

cc: Chief Secretary

cc Heritage Conservation Committee, Bangalore (ACS , UDD) 



(picture courtesy Indian Express)

Ms. Kusuma

DD Cubbon Park

Bangalore 560001

Dear Madam:

Subject: Request for Removal of LED Signboards at Cubbon Park

Citizens of Bangalore, and particularly aficionados of Cubbon park watched with great concern the emergence of 50 LED signboards spaced across Cubbon Park roads. None of us in the public have had any information or notice it was coming up last year - or any idea of why it was constructed in the first place, what purpose it serves, or what basis it was decided to insert the signage at all. Several of us had emailed our objections.

We understand that BESCOM set this up only on a pilot or test project under its Smart Light Campaign for a period of a year in June 2019 , so we are happy to share our views on its continuance. We do not want this. In addition, given the BBMP ruling on signage and outdoor hoardings, even though these LED boards are for a purely informative and internal point of view , we do feel that that should have gone through the proper procedure before setting it up in the first place.

What is important to note is this signage is poorly designed and set up, hurtful to the eye, visually anesthetic and unappealing, pose a serious traffic hazard as it distracts vehicle drivers with its LED flash and distracting moving visuals. From the flora and fauna point of view it is extremely negative in impact. Lastly Parks worldwide have disallowed or even banned such outdoor signage and particularly LED and wireless, so this is a vast departure from Horticulture park global standards.

The annexure below has initial inputs from experts on the subject, including planners, scientists from IISc, biologists and heritage experts.  We would earnestly request you to heed their considered view and do use this lock down period to have them immediately removed, and beauty and ecology restored in the park.

As we understand, these signboards have been done by kind courtesy Bescom as a pilot project for the period of one year in June 2019, and since the general public opinion has been quite negative about this, may we request you to please have this removed at the earliest, before the testing period elapses.

Try as we might, we have seen no upside at all about having these boards at the park, and neither has the signage messaging been either positively observed or actioned. We know your respect and regard for citizen views, scientifically backed claims and are happy to also connect a delegation of experts and share this point of view in person at the earliest. Once again, our deepest thanks for all the wonderful work done at Cubbon Park and we hope to continue to partner and support you in any way we can.

Thanking you

Yours Sincerely

Priya Chetty-Rajagopal

Cc: Mr. RK Kataria, Secretary, Horticulture

Cc: Dr Jagdish JD Horticulture Dept, Lalbagh

Cc: Mr. Rajesh Gowda, MD BESCOM

Cc: Ms. Revathy Ashok, MD, BPAC

Few Expert Views on LED Signboards at Cubbon Park :

Prof TV Ramachandra , Professor & Ecologist, IISc

This would impact the ecology evident from the nocturnal animals’ response to the lights. There are studies highlighting the pollinator's (bees, etc.) mortality due to light pollution so also birds, etc.

Decision makers need to understand the implications of mismanaging the nature..

Laxmi Nagaraj , Urban Planner, California

Strict regulations on not having LED signs in areas that are ‘heritage’ spaces. Cubbon Park is a heritage park with natural and scenic beauty in abundance and these signs are absolutely not compatible with the surroundings and is therefore an eye sore. Whatever the sign displays can be accommodated on the existing signage that is sensitive to the surroundings. Regulations PROHIBITING such signs should be immediately drafted and enforced. The LED signs are almost as large as billboards which are strictly prohibited in scenic surroundings.

Prof Yashaswini Sharma, Architect and Conservationist

Long time exposure to blue peaks and light emitted by LED can cause retinal damage. Why would the Government install LED sign displays in a green heritage precinct meant to benefit health? It is also a distraction for smaller wildlife that thrive in the park.

Sreedevi Changali , Architect & Conservationist , MasonInk

Yes, they are terrible and without doubt an eye sore. Could probably check what purpose they are serving and integrate it better with the existing signage (done by a company called sensing local).

Gopi Sundar, Scientist, Nature Conservation Foundation -

1. They are far too bright and damage sensitive corneas

2. Their wavelength is very limited so they don’t attract insects etc which a lot of animals can feed on

3. The “green” value of LED is only with respect to electricity usage and that too only if intensity and wattage is low so it does not damage eyes.

Global park standards:

Prohibited signs

· Neon signs, LED or similar accent lighting not permitted

· Signs which emit audible noise, door or visible matter not permitted

· A sign or illumination that causes glare not permitted

· A sign that emits flashing or intermittent lights not permitted

Billboard prohibition

· Excessive or Inadequately controlled signs endanger the unique character or scenic beauty

· The proliferation in number, increase in size, use of special effects in message presentation distracts

Therefore, all the above type of billboards and signs shall be prohibited

Some useful links


The zonal regulations amendment 2020 is an important step for heritage for the state overall . However for Bangalore the impact is different given point 2 which clearly establishes BDA as the LPA ie local planning authority via the defunct  arts commission to advise the heritage of the city as the appointed Heritage Conservation Committee .


Our Informal Zoom conversation with Shantala, director of Town planning and several others in the #HeritageBeku brought a fair amount of clarity and insights into both. Essentially until BDA sets up the  The arts commission as the de facto Bangalore heritage conservation committee, there is no advisory Heritage body and direction. . In addition the presence of BBMP as a further civic body controlling Heritage has to be noted. The new BBMP Act which has been put up to the council specifically has #Heritage related regulations as well. Please look at our blog post on this.


In whatever capacity, and however advisory a position, we are moving towards HCCs or heritage conservation committee‘s across Karnataka land planning authorities, and this will have a positive impact on conserving heritage, given that we have had no coverage on heritage protection since 2009.


So what does it mean for Bangalore’s heritage ? What is it that #HeritageBeku needs to do to forge forward and build on several conversations on the need for heritage regulations for the city? 

The first option is to sit tight and wait for something to evolve  in the fullness of time based on many recommendation made by an Intach or Heritage Beku and hoping to be right. The second is to work through from the political framework and share our concerns  with conversations with prominent influencers within the system. Creating a buy in to the cultural impact, heritage economy and creating a state heritage pride, maybe. Hopefully that point, the arts commission despite it’s advisory status can move forward. None of these perspectives are mutually exclusive and can be done in parallel too . The third option is I think the #HeritageBeku way.


One create an online petition as a placeholder for the concerns we have on the structure and future of heritage law in the city. Second set up a series of conversations with critical bureaucrats like the BBMP, BDA, heritage under tourism, Kannada and culture so as to get a concerted perspective on what the departmental drivers and concerns are, thereby arriving at some kind of common platform to build on going forward. Third to work on a collaborative online or physical  workshop with these stakeholders, bringing bringing them on to the same platform and create a common fabric and buy-in  for working together. Hopefully from here we can create a joint action plan. Next is to use the one month we have till the 15th May  to file a wish list and objections under the 13 E  of the Karnataka Town  and country planning rules so that the government records , and maybe internalises & implements citizens and civil societies view. Working with a pro-heritage media is important but we also know that , sometimes these things work better behind the scenes and low key , rather than the us vs them confrontational approach that tends to get  highlighted in media. I may be wrong and I’m happy to hear otherwise.


What we must remember is that overall this is a step in the right direction however late it might be. For some time I think that’s  #HeritageBeku Should take a supportive, collaborative and building block approach, working with govt  to create a buy in  and a collective vision. We have enough that we can build on in terms of granularity, but we must keep in mind that the need to JOINTLY move forward from the Bbmp and BDA in sync is critical. Otherwise this can move like the RMP 31 objections to the back drawer..


Your thoughts would be appreciated.

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