Facts
The petitioners operated the Dharampani Eco Tourism Resort under a Tripartite Memorandum of Understanding (MOU) dated 03.09.2025.
Source reference: para. 2By order dated 24.09.2026, the Divisional Forest Officer (DFO) directed them to vacate the resort within one month and hand over its management to the Joint Forest Management Committee, citing alleged violations of the MOU.
Source reference: para. 2The petitioners challenged the order, arguing that only the concerned Ranger could act on an alleged breach.
Source reference: para. 3The State maintained that the DFO, as the Ranger’s superior, could intervene and that the petitioners had received an opportunity to respond before the order was made.
Source reference: para. 4Issues
1. Whether the DFO could pass the order terminating the petitioners’ management and directing them to vacate the resort, despite their contention that the concerned Ranger was the competent authority under the MOU.
Source reference: paras. 3, 62. Whether the order could be challenged on the ground that the petitioners were not afforded an opportunity to be heard.
Source reference: paras. 4, 6Law Applied
The Court identified no statute or precedent as the basis for its decision.
Source reference: no citationIt considered Clause 6 of the MOU, which, as described by the State, provided for termination on one month’s notice and for immediate termination in the event of violation of applicable rules.
Source reference: para. 4The Court held that the order could not be faulted solely because it was made by the DFO rather than the concerned Ranger, since the DFO was the Ranger’s superior authority.
Source reference: para. 6Reasoning
The Court reviewed Clause 6 of the MOU, the notice issued to the petitioners, and their reply.
Source reference: para. 6It found that the petitioners had been afforded an opportunity of hearing.
Source reference: para. 6On the authority question, it accepted that the DFO was superior to the concerned Ranger and rejected the argument that the order was invalid merely because it was not made by the Ranger.
Source reference: para. 6The Court did not determine whether the alleged violations were established or otherwise assess the merits of the termination.
Source reference: no citationHolding
The Court rejected the petitioners’ challenge to the DFO’s authority on the ground advanced and dismissed the writ petition.
It expressly stated that it had not expressed any opinion on the merits of the case.
Source reference: para. 8Original Court PDF
VINOD SAHUvsSTATE OF CHHATTISGARH
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