No Perpetuation of Illegality: Supreme Court Bars Renewal of Agricultural Leases on Forest Land and Mandates Ecological Restoration
Commentary on State of Karnataka & Ors. v. Gandhi Jeevan Collective Farming Co-operative Society Ltd., 2025 INSC 1461 (Supreme Court of India, 18 December 2025)

I. Introduction

The decision in State of Karnataka & Ors. v. Gandhi Jeevan Collective Farming Co-operative Society Ltd., 2025 INSC 1461, is a significant reaffirmation of India’s forest conservation regime under the Forest (Conservation) Act, 1980 (“FCA, 1980”), and of the binding force of the continuing orders passed in the T.N. Godavarman line of cases.

The Supreme Court was faced with a seemingly sympathetic claimant: a cooperative farming society that had been cultivating forest land for over a decade under a state-granted lease, and that had managed to secure a High Court direction permitting it to make a representation for continuation of the lease. Against this stood the statutory and judicially reinforced mandate that forest land cannot be diverted for non-forest purposes—especially agriculture—without strict compliance with Section 2 of the FCA, 1980, and the overarching directions in nationwide forest litigation.

The Supreme Court, speaking through Mehta, J. (with Nath, J. concurring), unambiguously chose environmental legality over equitable indulgence. Holding that agriculture on forest land is a “non-forest purpose,” the Court ruled that:

• the original lease for agricultural use of forest land was “uncalled for”,
• no extension or continuation of such a lease is legally permissible under Section 2 of the FCA, 1980, and
• the High Court could not direct consideration of a representation that would, in substance, perpetuate an illegality.

Crucially, the Court did not merely resolve the inter se dispute between the parties. It also imposed a positive obligation on the State to restore the forest on the 134 acres in question by planting indigenous species, and it retained seisin of the matter by listing it for a compliance report in 2026. The judgment therefore fits squarely within the Supreme Court’s broader environmental jurisprudence, including public trust, ecological restoration, and continuing mandamus.

II. Factual and Procedural Background

1. Grant of lease over forest land

The facts, though concise in the judgment, are critical to understanding the Court’s reasoning:

• By orders dated 17 March 1973 and 30 June 1976, the Government of Karnataka granted the respondent, Gandhi Jeevan Collective Farming Co-operative Society Ltd. (“respondent-Cooperative Society”), a lease of 134 acres and 6 guntas of land situated in Benachi and Tumarikoppa villages, Kalaghatagi Taluk, Dharwad District.
• The lease period was ten years, commencing from 30 June 1976, and the stated purpose was agricultural.
• The land was, by the State’s own subsequent admission in the Supreme Court, forest land under the ownership and control of the Forest Department.

Following the grant, members of the cooperative cleared trees from the leased forest area and began cultivation.

2. Termination of lease and early writ petitions

• At the end of the lease period, the Government refused to extend the lease and formally terminated it by an order dated 13 March 1985.
• The cooperative challenged the termination in two writ petitions before the Karnataka High Court (W.P. Nos. 6608 of 1985 and 12780 of 1987), both of which were dismissed on 15 April 1985 and 12 July 1988 respectively.

Thus, the cooperative lost its first round of challenge to the State’s decision not to continue the lease.

3. Civil suit and appeals – protection limited to due process of eviction

• The cooperative then filed Original Suit No. 255 of 1988 (later renumbered O.S. No. 160 of 1992) before the Munsif and JMFC, Kalaghatagi, Dharwad District.
• The trial court partly decreed the suit, restraining the Forest Department from disturbing the cooperative’s possession until eviction was carried out in accordance with law.
• The State’s first appeal (R.A. No. 54 of 1994) was dismissed by the III Additional Civil Judge (Senior Division) and CJM, Dharwad, on 11 October 1999.
• The State’s Regular Second Appeal (R.S.A. No. 686 of 2002) was also dismissed on 8 September 2003. The High Court, importantly, observed that the State ought to have initiated legal steps for eviction rather than pursuing further appeals.

The net effect of these civil proceedings was not recognition of any substantive right in the cooperative to continue in perpetuity, but merely a requirement that eviction be conducted through lawful process.

4. Eviction proceedings under forest law and recovery of possession

Acting on the High Court’s observation, the forest authorities proceeded as follows:

• The Assistant Conservator of Forests, Kalaghatagi Sub-Division, initiated eviction proceedings under the Karnataka Forest Act and the Karnataka Forest Manual against the cooperative and its members, treating their occupation as unauthorized occupation of forest land.
• By a formal order dated 22 June 2004, the Assistant Conservator directed the eviction of the cooperative and its members.
• The cooperative’s appeal to the Conservator of Forests, Dharwad Circle, was rejected on 12 December 2006.
• The forest department took physical possession of the land on 23 January 2007, drawing mahazars (panchnamas) and erecting departmental boards warning against unauthorized entry.

By early 2007, therefore, the State had both the legal orders and factual possession of the land as forest land.

5. Writ proceedings leading to the impugned High Court judgment

The cooperative then approached the Karnataka High Court again:

• In W.P. No. 3467 of 2007, a Single Judge disposed of the writ petition on 27 February 2008 by:
  • granting liberty to the cooperative to file a representation to the Deputy Conservator of Forests under “relevant rules” within eight weeks; and
  • directing the State to forward such representation to the Ministry of Environment and Forests (now MoEF&CC), Government of India, which was to pass appropriate orders within six weeks thereafter.
• The State’s Writ Appeal No. 1079 of 2008 was dismissed by a Division Bench on 6 January 2009, thereby affirming the Single Judge’s order.

It was against this Division Bench judgment that the State of Karnataka approached the Supreme Court in Civil Appeal No. 3661 of 2011.

III. Summary of the Supreme Court’s Judgment

The Supreme Court allowed the appeal and set aside the High Court’s judgment. The key holdings can be summarised as follows:

1. The lease for agricultural use of forest land was fundamentally improper.
   The Court held that “the very grant of lease” to the cooperative for agricultural purposes was “uncalled for” as it resulted in “devastation and deforestation” of about 134 acres of forest land.
2. Forest land cannot be used for agriculture without complying with Section 2 of the FCA, 1980.
   The Court underscored that under the “extant statutes,” forest land cannot be diverted to non-forestry purposes, and that such non-forestry purposes “would include agriculture.” Any clearance of forest for cultivation would be in the teeth of Section 2 of the FCA, 1980.
3. No extension or continuation of an illegal lease is permissible.
   Having already enjoyed over ten years of cultivation on forest land, the cooperative was “not entitled for any further extension” of a lease that was itself illegally granted. The Court explicitly refused to allow “perpetuation of the illegality.”
4. The High Court’s direction to allow a representation for continuation of the lease was unsustainable.
   Given that the forest department had already taken possession in January 2007, and in light of the statutory and Supreme Court-imposed restrictions on diversion of forest land, the High Court could not legally grant the cooperative an opportunity to seek continuation of the lease.
5. Binding force of Godavarman series and forest conservation orders reiterated.
   The Court relied on:
   • the order in Centre For Environmental Law, WWF-I v. Union of India (WP (C) No. 337/1995), which directed that pending further orders, no de-reservation of forest/sanctuaries/national parks should be effected; and
   • the landmark directions in T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267, mandating cessation of all non-forest activities in forest areas without Central Government approval under Section 2 of the FCA.
6. Positive direction for ecological restoration.
   The Court directed the Forest Department, State of Karnataka, to restore the forest on the 134 acres by planting indigenous plants and trees, in consultation with experts, within 12 months.
7. Continuing oversight by the Supreme Court.
   The matter was directed to be listed on 17 December 2026 “only for receiving the compliance report,” indicating a form of continuing supervision consistent with the Court’s environmental jurisprudence.

IV. Detailed Analysis

A. Statutory Framework: Section 2 of the Forest (Conservation) Act, 1980

The FCA, 1980 is the central statutory basis for the Court’s reasoning. Section 2—reproduced in full in the judgment—is the cornerstone of India’s forest conservation regime.

1. Overriding effect and prohibition of unilateral State action

Section 2 opens with a strong non obstante clause:

“Notwithstanding anything contained in any other law for the time being in force in a State, no State Government or other authority shall make, except with the prior approval of the Central Government, any order directing—”

It then lists four kinds of prohibited state actions without Central approval:

1. that any reserved forest (or any portion thereof) shall cease to be reserved;
2. that any forest land (or any portion thereof) may be used for any non-forest purpose;
3. that any forest land may be assigned by way of lease or otherwise to any private person or other organisation; and
4. that any forest land may be cleared of naturally grown trees for the purpose of using it for reafforestation.

Two points are directly material to this case:

• State Governments cannot lease forest land to private entities for non-forest use without prior Central approval (clause (iii)); and
• forest land cannot be used for non-forest purposes (which includes most forms of agriculture) without such approval (clause (ii) read with the Explanation).

2. “Non-forest purpose” – the heart of the case

The Explanation to Section 2 defines “non-forest purpose” as:

“…the breaking up or clearing of any forest land or portion thereof for—
(a) the cultivation of tea, coffee, spices, rubber, palms, oil-bearing plants, horticulture crops or medicinal plants;
(b) any purpose other than reafforestation…”

Hence, “non-forest purpose” has two components:

• Specific listed agricultural and plantation crops (tea, coffee, spices, etc.), and
• A broad, residual category: any purpose other than reafforestation.

Although generic “agriculture” is not named explicitly, any clearing of forest land for cultivation that is not reafforestation clearly falls within the residual part of clause (b). The Supreme Court in the present case makes this explicit by stating that non-forestry purposes “would include agriculture.”

By tying agricultural use of forest land squarely to “non-forest purpose,” the Court closes any remaining interpretive window that might have allowed State authorities or litigants to argue that certain cooperative or subsistence agricultural uses of forest might be treated as benign or permissible.

B. Precedents and Prior Supreme Court Orders

1. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267

The Court quotes from the order in T.N. Godavarman Thirumulpad v. Union of India, where sweeping directions were issued:

“In view of the meaning of the word ‘forest’ in the Act, it is obvious that prior approval of the Central Government is required for any non-forest activity within the area of any ‘forest’… all on-going activity within any forest in any State throughout the country, without the prior approval of the Central Government, must cease forthwith.”

The Godavarman bench further clarified that:

• running saw mills, veneer and plywood mills, and mining are non-forest purposes and cannot continue without Central approval; and
• any such activity is prima facie a violation of the FCA, 1980.

Though Godavarman speaks directly of industrial and extractive activities, the underlying principle is that any non-forest activity in an area legally or factually recognised as forest must cease unless it has received the Central Government’s clearance under Section 2.

In the present case, the Court imports this logic to agricultural use of forest land: if commercial saw mills cannot operate, a fortiori, clearing forest to cultivate crops cannot be given a special status merely because it is agricultural and done through a cooperative.

2. Centre For Environmental Law, WWF-I v. Union of India, 2000 SCC OnLine SC 119

The Court also relies on the order dated 13 November 2000 in Writ Petition (C) No. 337 of 1995, Centre For Environmental Law, WWF-I v. Union of India, which is part of the broader Godavarman series. The Court quotes:

“Pending further orders, no de-reservation of forest/sanctuaries/national parks shall be effected.”

Two important implications flow from this:

1. Hard freeze on de-reservation and diversion.
   Until modified by the Supreme Court, no authority anywhere in India can de-reserve forest, sanctuary, or national park areas. De facto, this centralizes all significant decisions on forest diversion into the Supreme Court’s supervisory jurisdiction via Godavarman-type proceedings.
2. Renewal or continuation is as problematic as fresh diversion.
   Even if a lease was granted long ago, continuing or renewing an arrangement that effectively amounts to non-forest use is indistinguishable, in environmental terms, from de-reservation or fresh diversion. Hence, any such continuation—especially after the FCA, 1980 and Godavarman—must be treated as presumptively impermissible.

By invoking this order, the Court emphasises that the High Court’s direction to permit a representation for continuation of the lease was inconsistent not only with Section 2 of the FCA, 1980 but also with binding Supreme Court mandates in a nationwide environmental proceeding.

C. The Court’s Legal Reasoning

1. Illegality and impropriety of the original lease

The Court uses unusually strong language to characterize the original lease:

“the very grant of lease to the respondent-Cooperative Society for agricultural purposes was uncalled for because it led to devastation and deforestation of huge forest area admeasuring nearly 134 acres.”

Two strands are visible:

• Normative condemnation: Even if the initial lease orders (1973 and 1976) preceded the coming into force of the FCA, 1980, the Court emphasises that, in hindsight and in terms of current statutory and constitutional values, such a lease should not have been granted at all.
• Legal incompatibility under “extant statutes”: The Court then states:

  “As per the extant statutes, forest lands could not be allowed to be used for non-forestry purposes which would include agriculture.”

  This squarely refers to the FCA, 1980 and the Godavarman line of decisions. While the lease antedates the FCA, any attempt to extend or regularise it post-1980 would attract the statutory bar of Section 2.

The Court also notes that the cooperative had already “enjoyed cultivatory possession” over the forest area for more than ten years, confirming that there was no hardship in refusing any further extension.

2. No vested right to renewal and no equity to perpetuate illegality

The cooperative’s legal strategy, over several decades, effectively sought either:

• a continuation of its use of the forest land, or
• protection against eviction except on highly constrained terms.

The Supreme Court explicitly rejects the notion that long enjoyment of an illegal or environmentally harmful state concession can ripen into a legitimate expectation of renewal. It holds that:

“The respondent-Cooperative Society, having enjoyed cultivatory possession over the forest area for a period of more than 10 years, was not entitled for any further extension of the lease which was in the first place illegally granted.”

This reflects a broader constitutional and administrative law principle: courts will not use equity to perpetuate an illegality. This principle has appeared in multiple contexts (illegal appointments, unauthorized constructions, irregular allotments of public land); this judgment firmly applies it to forest leases and agricultural encroachments.

3. Agriculture as a “non-forest purpose” under Section 2 FCA, 1980

One of the judgment’s most important clarifications is its categorical treatment of agriculture as a non-forestry purpose:

“As per the extant statutes, forest lands could not be allowed to be used for non-forestry purposes which would include agriculture.”

This explicit statement removes any room for argument that agricultural use by cooperatives, farmers’ groups, or similar bodies might be considered a compatible or benign use of forest land. By linking agriculture to “non-forest purpose”:

• any fresh lease of forest land for agriculture without Central approval is directly barred by Section 2(iii) read with the Explanation; and
• any continuation, extension, or regularisation of such use post-1980 would itself be illegal and incapable of judicial support.

The legal implication is far-reaching: even if earlier State policies had encouraged agricultural settlement in forest areas, such policies are now structurally inconsistent with the FCA, 1980 and the Supreme Court’s environmental jurisprudence.

4. Illegality of the High Court’s “representation” route

The High Court had not directly extended the lease. Instead, it had:

• allowed the cooperative to file a representation to the Deputy Conservator of Forests; and
• directed the State to forward that representation to the Ministry of Environment and Forests for decision.

At first glance, this might appear innocuous: it merely permits a representation and requires consideration. However, the Supreme Court recognises this as a backdoor attempt to keep alive a claim that the law no longer permits. It holds:

“we are of the firm opinion that the impugned order whereby, the respondent-Cooperative Society was given an opportunity to make a representation to be considered by the Central Government for continuation of the lease on the forest land is not sustainable in the eyes of law.”

The logic is:

• once it is clear that the underlying activity (agricultural use of forest land) is impermissible without Central approval under Section 2, and
• once the Supreme Court in Godavarman/WWF orders has effectively frozen de-reservation/diversion,

then:

• a High Court cannot direct “consideration” of a proposal that would violate these controlling legal norms; and
• courts must refrain from issuing directions that create false hope of regularisation where the substantive law clearly forbids it.

In other words, judicial directions to “consider” cannot be used to circumvent clear statutory and constitutional prohibitions.

5. Relevance of recovery of possession by the Forest Department

The Court notes that the Forest Department had already taken possession on 23 January 2007 and erected departmental boards warning against unauthorized entry. This factual position strengthens the State’s case in two ways:

• It underscores that the cooperative’s rights, if any, had been effectively extinguished by lawful eviction proceedings; any further continuation would amount to a fresh grant, squarely hitting Section 2 FCA, 1980.
• It signals that the forest department had re-established actual control, enabling meaningful ecological restoration. Courts are generally cautious in ordering dispossession of parties in settled possession; here, that hurdle had already been crossed.

6. Positive direction to restore the forest and expert-based remediation

Rather than confining itself to declaring rights, the Supreme Court issues an affirmative environmental remedy:

“The Forest Department, State of Karnataka is directed to restore the forest on the 134 acres of released land by planting indigenous plants, tress in due consultation with the experts.”

This is notable for several reasons:

• Ecological restoration: The focus is not merely on ending illegal use, but on actively restoring the original ecological character of the land.
• Use of indigenous species: The direction to plant indigenous plants and trees shows sensitivity to ecological integrity, biodiversity, and local ecosystems, not just superficial “green cover.”
• Expert consultation: Recognising the technical complexity of restoration, the Court mandates consultation with experts, aligning with best practices in environmental adjudication.
• Time-bound compliance: A clear 12-month timeline is fixed for compliance, enhancing accountability.

7. Continuing supervision and the “continuing mandamus” model

Finally, the Court orders:

“List on 17th December, 2026 only for receiving the compliance report.”

This is a classic feature of the continuing mandamus model adopted in environmental and social rights cases. It enables:

• monitoring of actual implementation rather than mere paper compliance; and
• the possibility of issuing further directions if the State fails to meet its obligations.

Thus, while this is formally a civil appeal, the Court’s remedial structure closely resembles its approach in public interest environmental litigation, especially in the Godavarman series.

D. Underlying Constitutional and Public Law Themes

Although the judgment is brief and statutory in focus, it is undergirded by several constitutional principles:

• Article 21 – Right to life and environment: The Supreme Court’s forest jurisprudence has repeatedly held that environmental protection is integral to the right to life. Preventing deforestation and restoring degraded forest land directly serves this constitutional right.
• Articles 48A and 51A(g): The State’s duty to protect and improve the environment (Article 48A) and the citizen’s duty to safeguard the natural environment (Article 51A(g)) form the normative backdrop to the Court’s condemnation of the initial lease and refusal to extend it.
• Public trust doctrine: Forests are treated as public trust resources that the State holds in trust for present and future generations. Leasing such land for private agricultural benefit, especially when it requires deforestation, is inconsistent with this doctrine.
• No equity against statute: The Court applies the classic principle that equitable considerations cannot override clear statutory prohibitions. The cooperative’s long use and possible reliance interests are subordinated to the mandatory environmental protections of Section 2 FCA, 1980.

V. Simplifying Key Legal Concepts

1. “Forest” and “reserved forest” – legal meaning

In common parlance, a “forest” means an area covered with trees and vegetation. Legally, however:

• “Reserved forest” refers to a category under state forest laws (such as the Indian Forest Act, 1927 or state-specific forest Acts) where land is formally notified as forest and enjoys the highest level of protection.
• In the Godavarman case, the Supreme Court held that “forest” in the FCA, 1980 must be understood in its dictionary sense too, covering any area that is forest by its characteristics, regardless of legal notification.

In this case, the State unequivocally asserted that the land falls under the category of “forest” and is in the ownership and possession of the Forest Department.

2. “Non-forest purpose”

This is a key term in Section 2 of the FCA, 1980:

• It includes specific types of cultivation (tea, coffee, spices, rubber, etc.).
• It also includes any use of forest land other than reafforestation (i.e., other than growing forests again).
• Thus, activities like agriculture, construction, industry, and mining are generally “non-forest purposes.”

Once an activity is categorised as “non-forest purpose,” it cannot be permitted on forest land without prior approval from the Central Government under Section 2.

3. “De-reservation”

“De-reservation” means changing the legal status of a reserved forest (or sanctuary or national park) so that it ceases to be protected as such. The Supreme Court’s order in Centre For Environmental Law, WWF-I effectively froze such de-reservations nationwide unless specifically permitted by the Court.

Even without formal de-reservation, allowing long-term non-forest activities on forest land is functionally similar to partial de-reservation, which is why the Court is so strict about agricultural use of forest land.

4. “Mahazar” / “Panchnama”

A “mahazar” or “panchnama” is an official record prepared by public authorities, usually in the presence of independent witnesses (panchas), documenting the state of affairs at a particular site—such as taking possession of land. It serves as important contemporaneous evidence of what transpired.

In this case, mahazars dated 23 January 2007 documented the Forest Department’s re-taking of possession of the land in question.

5. “Continuing mandamus”

A “continuing mandamus” is a form of judicial order where the court:

• issues directions that require ongoing compliance over time, and
• keeps the case pending to monitor implementation and issue further directions if needed.

The Godavarman series is the classic example; the present case borrows this technique by reserving the matter for a compliance report in 2026, ensuring that forest restoration is not merely promised but actually pursued.

VI. Impact and Future Implications

A. For State Governments and Forest Departments

This judgment sends a clear and binding message to State authorities:

• No fresh leases of forest land for agriculture are permissible without Central approval under Section 2 FCA, 1980.
• No renewal or extension of old leases for non-forest purposes can be justified on grounds of past practice or equitable claims.
• Forest Departments must treat such occupations, once the legal basis (like a time-bound lease) expires, as unauthorized occupation and proceed to evict in accordance with law.
• States are under a positive obligation to restore forest areas that have been illegally diverted or degraded, not simply to stop further illegality.

In practical terms, this may require States to:

• audit existing uses of forest land for agriculture and other non-forest purposes;
• re-examine any policies providing for regularisation of encroachments on forest land in light of Section 2 and the Godavarman orders; and
• prioritize ecological restoration in reclaimed forest areas.

B. For Cooperatives and Private Users of Forest Land

For entities such as cooperative societies, this judgment is a stark warning:

• Even if an agricultural lease over forest land was legally granted decades ago, it does not generate a right to continue or to seek renewal contrary to current forest law.
• Long possession or capital investment on forest land does not create a vested right once the statutory framework changes or becomes stricter.
• Litigation strategies based on “equity” or “fairness” will not succeed where the statutory command and Supreme Court’s environmental orders are clear.

Cooperatives and other entities must therefore seek land for agricultural or similar activities in non-forest areas or explore legally-compliant agroforestry and community forestry models in partnership with the State, rather than relying on extensions of old, environmentally harmful arrangements.

C. For High Courts and Subordinate Courts

The Supreme Court’s correction of the Karnataka High Court’s “representation” order has wider institutional significance:

• Courts cannot direct authorities to “consider” representations that aim at outcomes clearly barred by statute and binding Supreme Court orders.
• High Courts and civil courts must read individual forest disputes in light of the overarching Godavarman framework and the FCA, 1980.
• Protective orders for possessory interests (like “do not evict except in accordance with law”) must not be interpreted or extended in a way that undermines national environmental mandates.

This judgment will likely be cited to resist similar “equitable” directions in future writ petitions where occupants of forest land seek regularisation or policy-based concessions contrary to Section 2 FCA, 1980.

D. For Environmental Jurisprudence: Restoration and Public Trust

The judgment reinforces several emerging trends in Indian environmental law:

• Restoration as standard remedy: Illegality in use of ecologically sensitive land is increasingly met, not only with cessation orders, but with directions for active ecological restoration.
• Integration of science and expertise: The requirement of expert consultation for planting indigenous species underscores the Court’s recognition that effective environmental remedies are technically complex and must be informed by ecological science.
• Supreme Court as environmental overseer: The listing for compliance in 2026 continues the pattern of the Court assuming an oversight role, especially in matters where long-term ecological outcomes are at stake.

E. “No Perpetuation of Illegality” – Extending a General Principle to Forest Leases

Finally, this decision firmly locates forest leases within the broader Indian jurisprudence that:

• denies regularisation of unauthorized constructions/concessions that violate planning or environmental laws;
• refuses to extend illegal public appointments; and
• insists that public resources (land, water, minerals) cannot be alienated contrary to constitutional and statutory norms.

The Supreme Court’s categorical refusal to allow continuation of the lease, despite decades of agricultural activity and multiple rounds of litigation, illustrates the firmness with which environmental illegality will be treated going forward.

VII. Conclusion

State of Karnataka v. Gandhi Jeevan Collective Farming Co-operative Society Ltd. cements and clarifies several critical propositions in Indian environmental and forest law:

• Forest land cannot be lawfully diverted to agriculture or other non-forest purposes without prior Central Government approval under Section 2 of the FCA, 1980.
• Even historically granted leases of forest land for agricultural use cannot be renewed or continued once they conflict with the statutory and judicially elaborated forest conservation regime.
• Longstanding use and equitable considerations cannot “wash clean” an illegal or environmentally harmful arrangement; the judiciary will not perpetuate such illegality.
• High Courts and other courts are bound to respect and apply the Supreme Court’s continuing orders in the Godavarman and related environmental cases, and cannot craft orders that undercut their effect.
• The State’s obligation does not end with eviction of unauthorized occupants; it extends to restoration of degraded forest land, using ecologically appropriate methods and under judicial supervision.

In the broader legal landscape, this judgment underscores that environmental law in India is not an optional policy preference but a hard-edged legal mandate, backed by constitutional norms, binding precedents, and enforceable court orders. For State authorities, cooperatives, and private actors alike, the message is unambiguous: forest land is not an expendable resource for agricultural expansion or private gain, and any past deviations from this principle cannot be legitimised by the mere passage of time.