Chhattisgarh High Court
Administrative and Public LawContract Law

A DFO’s order cannot be invalidated solely because the MOU identifies the Ranger as competent.

VINOD SAHU vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 12, 20262 MIN READSOURCE JUDGMENT
A DFO’s order cannot be invalidated solely because the MOU identifies the Ranger as competent.. VINOD SAHU vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners operated the Dharampani Eco Tourism Resort under a Tripartite Memorandum of Understanding (MOU) dated 03.09.2025.

Source reference: para. 2

By 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. 2

The petitioners challenged the order, arguing that only the concerned Ranger could act on an alleged breach.

Source reference: para. 3

The 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. 4
02

Issues

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, 6

2. Whether the order could be challenged on the ground that the petitioners were not afforded an opportunity to be heard.

Source reference: paras. 4, 6
03

Law Applied

The Court identified no statute or precedent as the basis for its decision.

Source reference: no citation

It 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. 4

The 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. 6
04

Reasoning

The Court reviewed Clause 6 of the MOU, the notice issued to the petitioners, and their reply.

Source reference: para. 6

It found that the petitioners had been afforded an opportunity of hearing.

Source reference: para. 6

On 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. 6

The Court did not determine whether the alleged violations were established or otherwise assess the merits of the termination.

Source reference: no citation
05

Holding

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. 8
Chhattisgarh High Court

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VINOD SAHUvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 12, 2026

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