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Issues Involved:
1. Whether the land in question was a "forest" or "private forest" under the Maharashtra Private Forests (Acquisition) Act, 1975 on the appointed day, i.e., August 30, 1975. 2. Whether the findings of the Sub-Divisional Officer and Maharashtra Revenue Tribunal regarding the nature of the land were correct. 3. Whether the Bombay High Court's judgment reversing the Tribunal's findings was justified. 4. Whether the principles of natural justice were violated. 5. Whether the doctrine of proportionality was applicable in the administrative action taken by the State. Detailed Analysis: 1. Nature of the Land: The primary issue was whether the land in question was a "forest" or "private forest" under the Maharashtra Private Forests (Acquisition) Act, 1975 on the appointed day, i.e., August 30, 1975. The Supreme Court noted that the definition of "forest" under Section 2(c-i) of the Act includes land that was part of a forest on the appointed day. The Court concluded that the land, which encompassed the disputed area, was a "forest" on the appointed day, supported by documentary evidence, including revenue records and conveyance deeds describing the land as forest land. 2. Findings of the Sub-Divisional Officer and Maharashtra Revenue Tribunal: The Sub-Divisional Officer initially held that the land was not a "private forest." However, the Maharashtra Revenue Tribunal reversed this finding, declaring the land as "forest" and "private forest" under the Act. The Tribunal's decision was upheld by the High Court, which found that the Tribunal had committed a jurisdictional error by not considering the earlier findings and evidence properly. 3. Bombay High Court's Judgment: The Bombay High Court allowed the petition filed by the State, quashing the Tribunal's order and holding that the land was "private forest" under the Act. The High Court emphasized that the Tribunal's approach was not in consonance with the law, as it failed to consider the legislative intent and the broader definition of "forest" under the Act. 4. Principles of Natural Justice: The appellant-Corporation contended that the orders were in violation of the principles of natural justice. However, the Supreme Court found that the State had two opportunities to produce evidence, and the appellant-Corporation had been given ample opportunity to present its case. The Court concluded that the principles of natural justice were not violated. 5. Doctrine of Proportionality: The appellant-Corporation argued that the State's decision to consider the land as automatically vested with the Government was irrational and disproportionate. The Supreme Court applied the doctrine of proportionality, which requires that administrative action should impinge on individual rights to the minimum extent necessary to preserve public interest. The Court found that the State's action was proportionate and in line with the principles of environmental protection and sustainable development. Conclusion: The Supreme Court dismissed both appeals, upholding the Bombay High Court's judgment that the land in question was "private forest" under the Maharashtra Private Forests (Acquisition) Act, 1975, and vested in the State Government. The Court emphasized the importance of interpreting the provisions of the Act in light of its purpose, which is to conserve forest resources and maintain ecological balance. The principles of natural justice were not violated, and the State's action was found to be proportionate and in public interest.
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