In Re: Zudpi Jungle Lands (T.N. Godavarman Thirumulpad v. Union of India)
Background
Across six districts of Maharashtra's Eastern Vidarbha region, roughly 86,409 hectares of land recorded in revenue records as "Zudpi Jungle" or "Zudpi Forest" had, for decades, actually been used for homes, schools, hospitals, government offices and farming, yet remained frozen under strict forest-conservation restrictions arising from this Court's earlier orders in the Godavarman case. The State of Maharashtra asked the Court to rule that these lands are not truly forest land and should be freed from those restrictions, while an intervenor argued that Zudpi lands are ecologically valuable scrub forest that must remain protected. The Court had earlier tasked its Central Empowered Committee (CEC) with examining the issue, which submitted reports in 2019 and 2025.
Decision Breakdown
The Court held that Zudpi lands must, in principle, continue to be treated as forest land consistent with its 1996 order, but crafted a carefully calibrated, non-precedent-setting scheme to balance conservation with the reality of settled communities. Land already allotted for non-forestry use up to 12 December 1996 can be de-notified through a formal approval process under the Forest (Conservation) Act, 1980, without compensatory afforestation levies, provided the land use is never changed again. Allotments made after that date, however, require the State to justify them and identify the responsible officers, who face punitive action before any regularisation is processed. The Court also ordered removal of encroachments through dedicated Special Task Forces within two years, unallotted fragmented parcels to be declared Protected Forests, and detailed monitoring and compliance timelines for the State and Union Governments, with the CEC continuing to supervise.
Lesson Learnt
Even long-standing, court-protected forest classifications can be recalibrated to reflect decades of genuine, on-the-ground non-forest use by settled communities, but only through a structured, accountable process. The Court will not simply erase forest protections wholesale, and officials responsible for unlawful land diversions remain answerable.