LexIN RE: ZUDPI JUNGLE LANDS versus
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[2025] 5 S.C.R. 1480 : 2025 INSC 754 In Re: Zudpi Jungle Lands [(I.A. No. 12465 of 2019 with I.A. No. 98194 of 2019, I.A. No. 127871 of 2020, I.A. No. 127874 of 2020, I.A. No. 44062 of 2025, I.A. No. 66986 and 74569 of 2025) In (Writ Petition (C) No. 202 of 1995)] In Re: T.N. Godavarman Thirumulpad v. Union of India and Others In the Matter of: State of Maharashtra .... Applicant Prasad Khale ... Intervenor/Applicant 22 May 2025 [B.R. Gavai,* CJI and Augustine George Masih, J.] Issue for Consideration Issue pertains to the status of Zudpi Jungle or Zudpi Forest in the six districts of State of Maharashtra; and whether the recommendations made by the CEC in its 2025 Report should be accepted or not. Headnotes† Forest Act, 1927 – Forest (Conservation) Act, 1980 – Reserved forest – Zudpi Jungle – Status of Zudpi Jungle/Zudpi Forest in the districts of Eastern Vidarbha Region-Nagpur, Wardha, Bhandara, Gondia, Chandrapur and Gadchiroli of State of Maharashtra – State of Maharashtra’s case that though these lands recorded in the revenue records as Zudpi Forest lands, however, these lands are not forest lands and for the past several decades have been put to various non-forestry purpose like residential, agricultural, government offices, public schools, primary health centres – In the present writ petition this Court vide order dated 12.12.1996 stated that the Zudpi Lands would also be treated as Forest Lands for the purpose of the 1980 Act – Thereafter, recommendations by the High Powered Committee that 92,115 Ha. of Zudpi Jungle, found to be suitable for forestry management, development * Author [2025] 5 S.C.R. 1481 In Re: Zudpi Jungle Lands and conservation, to be notified as reserved forest, and 86,409 Ha. Zudpi Jungle land, not suitable for forest management, to be denotified and be allowed for any non-forestry purpose – Subsequently, upon recommendation of Forest Advisory Committee, MoEF&CC granted approval for diversion of certain area – Thereafter, recommendation by FAC that Net Present Value-NPV not to be collected from State for diversion where Zudpi Jungle land has been put to non-forestry use before 12.12.1996 – State then filed IA for clarification that the directions of Supreme Court dated 12.12.1996 not applicable in respect of certain area of Zudpi lands being unfit for Forestry Management – Pursuant thereto, the Court sought report by the Central Empowered Committee-CEC – Recommendations in the 2025 CEC Report, to be accepted or not: Held: Recommendations made by the CEC to be accepted, else would have a devastating effect – Lakhs of people residing on the said lands for a number of decades would be dishoused and huge government buildings, offices existing on the said lands for decades will also have to be demolished as also the facilities in use by the Defence Ministry, Air Force, and the Agricultural Universities – Thus, the Zudpi Jungle lands to be considered as Forest lands in line with the order of Supreme Court – Zudpi Jungle lands allotted by the competent authority up to 12.12.1996 where land classification has not been changed, the State to seek approval for their deletion from the “List of Forest Areas” – State to submit a consolidated proposal for each district, and Union of India to approve the same without imposing any condition for compensatory afforestation or depositing NPV levies – Union Government and the State to devise a format for the proposal of diversion of Zudpi Jungle land for non-forestry activities within the stipulated period – For proposal regarding the allotments of Zudpi Jungle lands made post 12.12.1996, the State to give reasons for making such allotments with the list of officers who had made allotments in violation of the order of this Court, and ensure that punitive action is taken against such officers – State to declare all the unallotted “fragmented land parcels” as “Protected Forests”, and when required for non-forestry purposes by the State Government, the proposal to be submitted and said land not to be diverted to any non-governmental entity for any purpose – State to issue directions to Sub-Divisional Magistrates to ensure that no land parcel is encroached upon – Special Task Force to be constituted 1482 [2025] 5 S.C.R. Supreme Court Reports in each district to remove encroachments within the stipulated period – Allotments for commercial purpose post 25.10.1980 to be treated at par with enc
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