T.N. Godavarman Thirumulpad vs Union Of India & Ors

The Supreme Court addressed the issue of whether land leased to M/s. Maruti Clean Coal and Power Limited by the State of Chhattisgarh constitutes forest land under the Forest (Conservation) Act, 1980. The Court reaffirmed the principles established in T.N. Godavarman Thirumulkpad v. Union of India, emphasizing that the definition of 'forest' includes all areas recognized as such in government records, irrespective of ownership. The Court directed the establishment of Expert Committees by State Governments to identify forest areas, thereby holding that the land in question should be treated as forest land under the FC Act.