In a packed courtroom on Thursday, the Supreme Court brought a long-running land dispute from Telangana’s forest belt to a decisive halt. The case revolved around 102 acres in the Gurramguda Forest Block, land that had travelled through jagir abolition, forest notifications, and multiple courts over nearly seven decades. At the end of the hearing, the Bench made it clear: summary forest proceedings cannot be used to decide complex ownership claims.
Background
The dispute traces back to Survey No. 201/1 in Saheb Nagar Kalan village, now part of Ranga Reddy district. After the abolition of jagirs in the erstwhile Hyderabad State, the land vested in the government. In 1953, a large portion of Survey No. 201 was transferred to the Forest Department, and by the early 1970s, 102 acres were notified for inclusion in the Gurramguda Forest Block under the Telangana Forest Act.
Decades later, legal heirs of Mir Jaffar Ali Khan, claiming succession to Salar Jung III, approached the Forest Settlement Officer (FSO). They argued that the land was “Arazi-Makta”, meaning privately purchased land, and not jagir or government property. In 2014, the FSO accepted this claim and ordered the land’s exclusion from the forest block. That view was upheld by the District Judge and later by the Telangana High Court.
The State of Telangana challenged these findings, bringing the matter to the Supreme Court.
Court’s Observations
The Bench closely examined the powers of the Forest Settlement Officer and the nature of the claim. It noted that proceedings under Section 10 of the Telangana Forest Act are summary in nature. “The Forest Settlement Officer can consider claims to existing rights, but cannot assume the role of a civil court to finally decide title,” the Bench observed.
The Court was particularly critical of how earlier judgments were brushed aside. It recalled that in an earlier round of litigation, the High Court and the Supreme Court had already held that similar claims over Survey No. 201 failed, and that the State had perfected its title over time. Merely because the present claimants were not parties then, the issue of ownership could not be reopened through forest proceedings.
On the claim of Arazi-Makta status, the Court was unconvinced. It pointed out that after jagir abolition, land vested in the State unless lawfully released. Documents relied upon by the claimants, including old letters and revenue entries, could not override statutory vesting or earlier binding findings.
The Bench also flagged procedural lapses, noting that the State was improperly represented before the FSO. Even so, it clarified that the case would not turn only on technicalities. The core problem, it said, was jurisdictional. As the Bench put it, “complex and disputed questions of ownership cannot be settled in a summary enquiry meant for forest settlement.”
Decision
Allowing the State’s appeal, the Supreme Court set aside the orders of the Forest Settlement Officer, the District Judge, and the Telangana High Court. The Court held that the 102 acres in Survey No. 201/1 could not be excluded from the Gurramguda Forest Block through forest settlement proceedings and restored the land’s status in favour of the State.
Case Title: The State of Telangana v. Mir Jaffar Ali Khan (Dead) through LRs & Others
Case No.: Civil Appeal No. 9996 of 2025
Case Type: Civil Appeal (Forest Land / Title Dispute)
Decision Date: 2025