Guide
Private Land Conservation in Costa Rica: Reserves, Easements and Landowners
How Costa Rican landowners protect private forest: payments for environmental services, ecological easements, private reserve networks and visits.
Forests · Gandoca-Manzanillo, Talamanca, Limón
On Feb. 5, 2026, Costa Rica's Ombudsman's Office asked the Constitutional Chamber to have the Judicial Investigation Agency's forensic biologists independently check a MINAE report that found 107.92 hectares of forest in a strip cut out of the Gandoca-Manzanillo refuge in 2014. MINAE rejected the objections. It's a request, not a finding: as of late August 2026 the court hadn't ruled, and its freeze on permits in the area remained in place.
On Costa Rica's southern Caribbean coast, the question of exactly where the forest is, and who gets to decide, has been in court for more than a decade. In February 2026, the country's Ombudsman's Office asked the Constitutional Chamber not to accept the Environment Ministry's latest forest map of the Gandoca-Manzanillo refuge until independent forensic experts check it. The court hasn't decided yet.
As The Tico Times reported on Feb. 5, the Ombudsman's Office (Defensoría de los Habitantes), which takes part in the case as an intervening party, asked the Constitutional Chamber, known as the Sala IV, to order an outside review of a report from the Ministry of Environment and Energy (MINAE). It proposed the Forensic Biology section of the Judicial Investigation Agency (OIJ), citing its certified methods and independence from the ministry. The office set out its position in a press release the same day.
The office accepted that MINAE had largely done what the court ordered, but said reasonable doubts remained about its methods, according to Semanario Universidad. It raised three main concerns:
MINAE rejected the objections the same day. In a statement reported by Delfino.cr, the ministry said the Ombudsman's Office has no experience or technical capacity to judge forestry questions. It said FONAFIFO brought broad forest-management expertise, played no part in producing the maps, and carried out an independent check. MINAE added that the final word belongs to the court and said it wouldn't comment further until then.
The report, signed by Environment Minister Franz Tattenbach and acting SINAC director David Chavarría, went to the court on Sept. 11, 2025. It covered the 186.66-hectare coastal strip, between Cocles and Manzanillo, that a 2014 law (Law 9223) had removed from the refuge. Its main findings:
The Gandoca-Manzanillo National Wildlife Refuge was created in 1986 next to the Panama border. It protects beaches where sea turtles nest, coral reefs, seagrass, mangroves and swamp forests, and it's been a Ramsar wetland of international importance since 1995. In 2013 it was renamed for Jairo Mora Sandoval, a young turtle conservationist murdered on a Limón beach.
In 2014, Law 9223 cut the coastal strip out of the refuge. In July 2019, the Sala IV struck down part of that law (ruling 2019-12745) and ordered SINAC to map which land was forest so it could return to protection. Progress was slow. In March 2025, the court froze new and existing municipal permits and concessions on the affected forest land, halted MINAE logging permits in seven forest sections, and kept those measures in place until it receives a full compliance report. In June 2025, it widened the freeze to filings seeking to register property in the area.
The Ombudsman isn't alone. Delfino.cr reported in August that the Attorney General's Office (PGR) had asked the court back on March 9, 2026, to order a forensic study by the OIJ's biology and engineering sections, after forensic biologists found differences between SINAC's measurements and earlier studies. On Aug. 20, Marco Levy Virgo of the Asociación de Desarrollo para la Ecología asked the PGR to go to the OIJ directly. The PGR replied that only a court or prosecutor can order that work.
As of Aug. 29, 2026, the court's press office said the magistrates hadn't yet taken up the request. Attorney General Iván Vincenti Rojas said the freeze on permits stays in force until the court decides. We found no ruling after that date.
The case is about land use and permits, not public access, so it doesn't close the refuge to visitors. Stick to marked trails and public beaches, and hire local guides for the forest. For anyone eyeing land along the Cocles to Manzanillo coast, the message is caution: building and logging permits on the disputed forest land remain suspended while the case is open. Our guide to private land conservation covers the legal tools owners can use to protect forest on their own property. Read about leatherbacks arriving early on Caribbean nesting beaches and the campaign to help Costa Rica's coral reefs, or browse refuges on our nature reserves map.
It's a protected area on Costa Rica's southern Caribbean coast, in Talamanca near the Panama border, created in 1986. It protects turtle-nesting beaches, coral reefs, mangroves and swamp forests and is a Ramsar wetland site.
Not as of late August 2026. The Ombudsman requested it in February 2026 and the Attorney General's Office in March, but the court's press office said the magistrates hadn't taken it up yet.
107.92 hectares, about 58% of the 186.66-hectare strip removed from the refuge in 2014.
On the forest land covered by the court's measures, new and existing municipal permits and concessions have been suspended since March 2025, and they stay suspended until the court rules.
We wrote this story from the published reports and official sources above. We didn't interview the people named unless the story says so.
Guide
How Costa Rican landowners protect private forest: payments for environmental services, ecological easements, private reserve networks and visits.
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