FOREST RANGE OFFICER AND ORS. vs P.MOHAMMED ALI AND ORS.

The Supreme Court held that sandalwood oil qualifies as wood oil under Section 2(f)(i) of the Kerala Forest Act, 1961, thus categorizing it as forest produce. The Court overruled the previous decision in Mohammed Ali v. Forest Range Officer, which had held otherwise, and approved the ruling in Khushboo Enterprises v. Forest Range Officer. The Court emphasized the need for purposive interpretation of the term 'wood oil' to align with legislative intent for conservation and regulation of forest resources.