The Supreme Court, on May 22, 2025, ruled that the Zudpi Jungle lands in Maharashtra fall under the category of forest lands. This landmark decision brings them within the scope of the Forest Conservation Act, 1980, making any non-forest use of these lands subject to prior approval from the Central Government.
The bench, comprising Chief Justice B.R. Gavai and Justice A.G. Masih, held:
“Zudpi Jungle lands shall be considered as Forest lands in line with the order of this Court dated 12th December 1996.”
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The Court made a clear distinction between allotments made before and after 12 December 1996, the date of the T.N. Godavarman judgment, which expanded the Forest Act’s reach. Allotments made before this date will be regularized without the need for compensatory afforestation or Net Present Value (NPV) payments.
“Zudpi Jungle lands allotted by the competent authority up to 12th December 1996 shall be regularized, and the State of Maharashtra shall seek approval under Section 2 of the Forest (Conservation) Act, 1980.”
However, post-1996 allotments will face strict scrutiny. The State must justify such allotments and provide names of officials involved in any violation.
“Such proposals will only be processed after ensuring punitive action is taken under Sections 3A and 3B of the Forest (Conservation) Act, 1980.”
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The Court emphasized administrative accountability and sustainable development. It directed that the remaining 7.76 lakh hectares of Zudpi Jungle land still held by the Revenue Department must be handed over to the Forest Department within one year.
“This land shall be utilized only for compensatory afforestation.”
Also, fragmented land parcels of less than three hectares must be declared as Protected Forests under Section 29 of the Indian Forest Act, 1927. Sub-Divisional Magistrates (SDMs) must ensure these lands are not encroached upon in the future.
“If any such encroachment takes place after the date of this judgment, the concerned SDM shall be made responsible.”
Encroachments made for commercial purposes after October 25, 1980, are to be treated as illegal. The Court directed the creation of Special Task Forces in each district to remove such encroachments within two years.
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“The Special Task Force will consist of SDMs, Deputy Superintendents of Police, Assistant Conservators of Forests, and Taluka Inspectors of Land Revenue.”
The Court strictly prohibited the diversion of Zudpi Jungle land to any non-governmental entity for any non-forestry purpose.
“In no case shall any such land be diverted to any non-governmental entity for any purpose whatsoever.”
Additionally, the land can only be used for afforestation if non-forest land is unavailable. In such cases, double the area of Zudpi Jungle land must be used for afforestation, as per existing guidelines.
The Central Empowered Committee (CEC) was instructed to monitor the land transfer process. The Supreme Court also reiterated its earlier direction from the judgment dated 15 May 2025 to all State Chief Secretaries and Union Territory Administrators to set up Special Investigation Teams (SITs) to verify if forest lands had been wrongly allotted for non-forest purposes.
“If returning such land is not in public interest, its cost must be recovered and used for forest development.”
The Court also recognized the contribution of the legal team:
“The State of Maharashtra shall pay Rs. 5,00,000/- to Shri K. Parameshwar, Amicus Curiae, and Rs. 2,50,000/- each to Ms. Kanti, Mr. M.V. Mukunda, Ms. Raji Gururaj, and Mr. Shreenivas Patil for their valuable services.”
Case Title: IN RE: ZUDPI JUNGLE LANDS
Appearances:
Shri K. Parameshwar, Amicus Curiae
Shri Siddharth Dharmadhikari, for the State
Smt. Madhavi Divan, Senior Counsel for the intervenor
