The court ruled that Zudpi Jungle lands are to be classified as forest lands for conservation purposes, yet allows for non-forestry uses considering socio-economic impacts and historical context.

Headnote:(A) Forest (Conservation) Act, 1980 - Zudpi Jungle lands - 86409 hectares categorized as unfit for Forestry Management - Issues concerning their status, classification, and use for non-forest purposes addressed. Court recognized historical usage for residential and agricultural purposes, validating non-forestry practices. CEC Reports recommend de-notification of certain lands and recognition of public utility uses, balancing environmental and socio-economic interests. (Paras 1-140)

(B) Public Interest and Socio-Economic Justice - The Supreme Court highlighted the need to uphold the rights of citizens engaged in farming and living on Zudpi lands and the provision of public amenities, establishing constitutional obligations to ensure housing and occupational rights. (Paras 72-107).

(C) Sustainability - Court emphasized the necessity of a balanced approach towards environmental conservation and development. (Paras 119-121).

(D) Conclusions - Recommendations from the CEC to regard Zudpi Jungle as forest lands unless otherwise specified post-12/12/1996 upheld, ensuring the allocation for public goods without imposing additional conditions for afforestation. (Paras 138). (E) Judgment concluded with directives for compliance, monitoring, and stakeholders' rights protection.

Table of Content
1. status of zudpi jungle lands in maharashtra. (Para 1 , 2 , 3)
2. arguments for and against recognition of zudpi lands. (Para 7 , 8 , 9)
3. historical background of zudpi jungle lands and legal definitions. (Para 10 , 11 , 12 , 13 , 14 , 15 , 16 , 18 , 19 , 20)
4. legal stance on forest conservation regarding zudpi lands. (Para 29 , 41)
5. final directives by the court concerning zudpi jungle lands. (Para 48 , 139)

1. I. INTRODUCTION
This batch of applications involves a peculiar issue concerning the situation prevailing in the six districts of Eastern Vidarbha Region namely Nagpur, Wardha, Bhandara, Gondia, Chandrapur and Gadchiroli. The issue pertains to the status of the parcels of lands known as Zudpi Jungle or Zudpi Forest in the aforesaid districts of State of Maharashtra.

2. The State of Maharashtra has approached this Court stating that though these lands have been recorded in the revenue records as Zudpi Forest lands, however, taking into consideration the historical perspective, it is clear that these lands are not forest lands and that for the past several decades these lands have been put to various non - forestry purpose like residential, agricultural, government offices, public schools, primary health centres etc. The Divisional Commissioner, Nagpur Division, State of Maharashtra accordingly has filed certain IAs being IA No.12465 of 2019 and IA No.98194 of 2019. The prayers in the first of the two IAs are thus:
"(a) Issue the directions that the 86409 ha. Zudpi land, unfit for Forestry Management does not come under the purview of Forest (Conservation) Act, 1980 and also does not attract the provisions of orders of 12/12/1996 issued by this Hon'ble Court in the present Writ Petition AND in light of the submissions made above, this Hon'ble Court may also be pleased to issue directions that the directions in order dated 13/11/2000 in Writ Petition No. 337/1995 are also not applicable in respect of 86409 ha. Zudpi land, unfit for Forestry Management in the State of Maharashtra;
(b) Pass such other or further orders as may be deemed fit and proper."

3. One Mr. Prasad Khale has filed IA No.127871 of 2020 seeking intervention. Further, IA No.127874 of 2020 has been filed by the said intervenor seeking the following reliefs:
"a. Direct the State of Maharashtra to initiate departmental enquiry against the errant officers of the Forest Department and Revenue Department who have violated the provisions of the Forest Conservation) Act, 1980 by permitting Zudpi lands to be diverted for non - forest use and for allowing encroachments in the said areas.
b. Direct the State of Maharashtra to undertake necessary measures to restore the zudpi lands to its original condition, in cases where such lands have been illegally diverted without following the procedure laid down as per law."

4. This Court, by its earlier orders, had directed the Central Empowered Committee (hereinafter, "CEC") constituted under the orders of this Court, to submit its report.

5. Pursuant to the directions passed by this Court, two reports have been submitted by the CEC being CEC Report No.29 of 2019 dated 22nd October 2019 (hereinafter referred to as "2019 CEC Report") and CEC Report No.8 of 2025 dated 17th February 2025 (hereinafter referred to as "2025 CEC Report"). We will refer to the orders passed by this Court and the aforesaid reports submitted by the CEC in the subsequent paragraphs of this judgment.

6. We have heard Shri K. Parameshwar, learned amicus curiae, Shri Siddharth Dharmadhikari, learned counsel appearing on behalf of the State and Smt. Madhavi Divan, learned Senior Counsel appearing on behalf of the intervenor.

7. II. SUBMISSIONS
Shri Parameshwar, learned amicus curiae has placed before us the entire factual scenario and the recommendations of the CEC as contained in both the reports. He submits that this Court after taking into consideration the entire factual scenario and the historical background should pass an appropriate order tha