1. Heard Mr. Shaikh, learned Senior Advocate for Petitioner and Ms. Bhide, learned Government Pleader for Respondents – State.

2. Writ Petition assails impugned Order dated 10.12.2025 passed by Respondent No.1 – District Collector, Palghar, inter alia, rejecting Application filed by Petitioner seeking updation of Mutation entry in the Revenue Record as directed by concurrent orders passed by the Sub-Divisional Officer (for short “SDO”) and Maharashtra Revenue Tribunal (for short “MRT”) in proceedings under the Maharashtra Private Forest (Acquisition) Act, 1975 (for short “MPF Act”) and Maharashtra Land Revenue Code, 1966 (for short “MLR Code”). By virtue of concurrent orders the SDO and MRT held that Petitioner’s lands were “agricultural lands” and not “private forest lands” and accordingly directed removal of the entry “forest” and updation by way of Mutation in the Revenue Record. The District Collector did not implement the said orders and directions resultantly leading to filing of the present Petition.

3. Briefly stated, lands described in paragraph No.4 of the Petition belong to Petitioner (for short “subject lands”). The subject lands were “inam” lands which were granted to the owners i.e. predecessors-in-title of Petitioner under the provisions of Maharashtra Land Revenue Code, 1966 (for short “MLRC”) read with the The Bombay Personal Inams Abolition Act, 1952 (for short “BPIA Act”). The subject lands are “agricultural lands” which are subject to the provisions of the Maharashtra Agricultural Lands (Ceiling on Holding) Act, 1961 (for short “MAL Act”). By detailed order dated 05.06.2015, the SDO recorded a finding that the subject lands are “agricultural lands” and not “private forest lands”, under the provisions of Section 6 of the MPF Act and this was because on the enactment of MPF Act without issuing notice to Petitioner or owners of the subject lands merely to bring the subject lands under the purview of the said Act, the said lands were designated as “private forest lands” in the Revenue Record.

4. Admittedly all along and even thereafter, Petitioner and his predecessors-in-title continued paying the assessment as determined and cultivated the subject lands. However because the subject lands being designated as “private forest lands”, Appeal under Section 6 was filed by Petitioner before the SDO. By a detailed order dated 05.06.2015 SDO held that the subject lands are “agricultural lands” and not “private forest lands”, however he directed that the said order would come into effect only after obtaining permission from the Central Government. Both, the State and Petitioner filed 2 separate Appeals before the MRT. Petitioner filed Appeal to the limited extent of challenging the direction issued by SDO that permission from the Central Government should be obtained and only thereafter the order would come into effect.

5. By common order dated 19.04.2023, MRT dismissed the Appeal filed by the State and upheld the SDO’s order, however while doing so the MRT deleted the directions contained in the SDO’s order about the order coming into effect after obtaining permission from the Central Government as per the Indian Forest (Conservation) Act, 1980. In effect MRT granted full relief to the Petitioner. Petitioner therefore applied for implementation of MRT’s order seeking appropriate mutation in the Revenue Record qua the subject lands. The Collector by virtue of the impugned order dated 10.12.2025 rejected Petitioner’s Application on the premise that the same will require prior approval of the Central Government in accordance with provisions of the Section 2 of the Indian Forest (Conservation) Act, 1980.

6. Hence, the present Petition.

7. Mr. Shaikh, learned Senior Advocate along with Mr. Nargolkar appearing for the Petitioner would submit that by virtue of statutory order in Appeal dated 05.06.2015 passed under Section 6 of MPF Act the subject lands have been declared as “agricultural lands”. They would draw my attention