For four decades, Old Goa’s priceless heritage has stood without a management plan. Now, long-awaited bylaws promise protection, but experts warn crucial gaps could leave its fragile legacy vulnerable
After a 40-year gap without a management plan for the World Heritage Site of ‘Churches and Convents of Goa’, draft heritage bylaws have finally been prepared, but experts have flagged gaps in enforcement, mapping, height restrictions and heritage safeguards that could undermine their effectiveness.The National Monuments Authority (NMA), Delhi, framed the draft bylaws in consultation with the Indian Heritage Cities Network Foundation (IHCNF), Bengaluru. The regulations seek to “guide physical, social and economic interventions within 300m of all directions of the protected monuments”.The bylaws were notified in the central gazette on Dec 3, 2025, inviting suggestions and objections within a month. However, stakeholders in Goa alleged that the draft was neither published in the Goa official gazette nor adequately publicised through local newspapers, limiting public participation in the process.Experts said the bylaws, prepared 16 years after the Ancient Monuments and Archaeological Sites and Remains (AMASR) (Amendments and Validation) Act, 2010, was enacted, contain useful provisions but require greater clarity, corrections and consolidation before they can become an effective and enforceable framework.Old Goa’s lost landscape
SHANTIES & SQUALOR: Structures like these—hardly two existed at this spot—speak volumes about the lack of management at the world heritage site
Once known as the ‘Rome of the East’, Old Goa was a sprawling city enclosed by a majestic 21km-long wall extending around areas including Corlim and Carambolim. Since the 18th century, however, it has progressively shrunk into a fragmented cluster of monuments.In the absence of a comprehensive management plan, road expansion, construction and the mushrooming of kiosks within the regulated area have affected the visual integrity of the historic walled city, which reflects layers of Vijayanagar, Kadamba and Portuguese history, sources said.Conservation architect and ICOMOS national coordinator for Risk Preparedness Poonam Verma-Mascarenhas criticised the lack of transparency surrounding the process.
“I perused bylaws on the NMA website only after I saw a social media post. But in its current form, the document is not user-friendly for property owners, architects or promoters,” she said.Mapping and enforcement gaps
SUFFOCATED BY ILLEGALITIES: Arch of Conception, a historic monument, south of St Cajetan’s Church has been overrun by shanties near it, including this new one
While the draft addresses several heritage concerns, experts have pointed to the absence of corresponding survey numbers and ownership details for properties falling within the prohibited and regulated zones.“The survey numbers and footprint details should have been verified through ASI Goa Circle records, especially for prohibited zones and intersections with regulated zones for the purpose of effective enforcement,” Mascarenhas submitted to the NMA.She said the responsibility of maintaining the world heritage status rests with India as the state party and called for greater clarity on jurisdiction.“NMA must make the jurisdiction very clear and take responsibility, as part of its duty along with ASI, to prepare implementable bylaws,” she said.Illegal construction concerns
An illegal structure stands out in the Adil Shahi moat which runs deep at this stretch on the road to Dauji
Old Goa has witnessed repeated protests over alleged illegal constructions, including a bungalow near the Arch of the Viceroy in a protected area, as well as proposals for projects within heritage zones.“Considering these developments, adversely impacting the significance of Old Goa as a world heritage site comprising 7 of the 14 centrally protected monuments, NMA needs to set up a dedicated special officer within ASI Goa circle for effective management of heritage zones,” Mascarenhas said.Height limit under scrutiny
HOUSE OF BULL: Experts want height restrictions in the area based on the low stature of this compact building on Divar ferry road which is 8m-10m high and the Arch of Adil Shah palace
The proposed 11.5m height limit has also drawn objections, with heritage advocates suggesting that it be reduced to 8m.“Heritage norms acknowledge skylines as an important element in determining the outstanding universal value of world heritage sites,” architect and urban planner Tahir Noronha said.
Noronha also objected to the absence of a requirement for documentation before and after repairs or renovations.“This provides malicious actors the opportunity to show photos of a project elsewhere, build a new structure and claim to have repaired the structure,” he said.He also raised concerns over heritage impact assessments, restrictions on incompatible building materials, and other provisions of the draft.Commercial activity continues
Despite Old Goa’s heritage significance, the local panchayat appears to have prioritised commercial activity, with kiosks and shops being permitted at strategic locations, heritage activists said.“Approvals are also obtained for residential purposes, but premises are misused for commercial purposes,” heritage activist John Mascarenhas said.ASI officials declined to comment on the draft bylaws, saying the matter falls entirely within the NMA’s jurisdiction. NMA officials could not be contacted.The Bombay high court was recently informed that the bylaws would be approved by Parliament.
