In Re : T.N. Godavarman Thirumulpad vs Union Of India And Ors.

The Supreme Court addressed the criteria for identifying 'forests' under the Forest (Conservation) Act, 1980, in the context of appeals arising from the National Green Tribunal's order. The Court emphasized that the identification criteria must align with the principles established in the TN Godavarman Thirumulpad case, ensuring comprehensive application of the Act to all lands. The Court held that the criteria set forth by the State of Goa must be modified to ensure they are consistent with the overarching legal framework, thereby allowing the appellant to seek appropriate remedies under the NGT Act, 2010.