STATE OF BIHAR vs BANSHI RAM MODI & ORS.

The Supreme Court held that under Section 2 of the Forest (Conservation) Act, 1980, no fresh breaking up or clearing of forest land can occur without prior approval from the Central Government. However, if mining operations were already ongoing prior to the Act's enforcement, the lessee is permitted to extract additional minerals found during mining without violating the Act. The Court upheld the High Court's decision, stating that allowing the lessee to mine felspar and quartz does not constitute fresh breaking of forest land, thus aligning with the Act's objectives.