A PIL challenging forest-land leases fails when beneficiaries are not impleaded and statutory violations remain unspecified.

The petitioners, including the Sarpanch of Gram Panchayat Semarwar and a social worker, filed a writ petition styled as a Public Interest Litigation challenging the grant of rights, title and interest over 40.711 hectares of Reserved Forest Land in Compartment No. RF-279, Village Anjani, District Anuppur, to 51 beneficiaries under the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 and the applicable Rules.

An earlier PIL on the same subject, W.P. No. 39300 of 2025, had been withdrawn with liberty to approach the competent authority. The petitioners thereafter submitted a representation dated 15 May 2026, which they alleged remained undecided.

The State opposed the petition, contending that the Sarpanch lacked locus and that the PIL was motivated by personal interest.

Whether the PIL was maintainable in the absence of the 51 allottees, whose leases and proprietary or possessory interests were directly sought to be affected?

Whether the Court could examine and cancel the allotments when the petitioners had not identified the specific provisions of the Forest Rights Act, 2006 or the Rules allegedly violated?

Whether the petitioners had established sufficient bona fides and a legally substantiated public injury warranting exercise of PIL jurisdiction?

The Court considered the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 and the Rules of 2008, as the statutory framework governing the grant of forest rights, along with the Indian Forest Act, 1927, relied upon by the petitioners.

It applied the natural justice principle that persons whose leases or legal interests are directly challenged must be impleaded and given an opportunity of hearing before adverse orders are passed.

On PIL maintainability, the Court relied on State of Uttaranchal v. Balwant Singh Chaufal, (2010) 3 SCC 402, which requires courts to scrutinise the petitioner’s bona fides and prevent PILs filed for personal, private or oblique motives; Guruvayur Devaswom Managing Committee v. C.K. Rajan, (2003) 7 SCC 546, which excludes proceedings seeking enforcement of individual rights or personal grievances from PIL jurisdiction; and S.P. Gupta v. Union of India, 1981 Supp SCC 87, which recognises liberal standing for public-spirited persons but denies standing to persons acting out of personal interest, private grudge or gain.

The Court found that the central relief sought was cancellation of leases granted to 51 identified beneficiaries. Since those beneficiaries had not been impleaded, the validity of their leases could not be examined or determined without violating principles of natural justice.

The petition also failed to specify which provisions of the 2006 Act or the 2008 Rules had been breached. The allegations concerning prior possession of alternative land, plantation, tree cutting and encroachment were treated as vague and insufficiently connected to a demonstrable statutory illegality.

Further, the petitioners did not file the six annexures allegedly attached to their representation, and there was no acknowledgement establishing receipt of that representation by the competent authority.

In light of the PIL safeguards laid down in the cited Supreme Court decisions, and given the inadequately substantiated allegations and procedural defects, the Court held that the petition did not warrant exercise of its writ or PIL jurisdiction.

The petition was also found deficient because the allegations were vague and unsupported by the relevant documents, and the petitioners had not established a proper basis for PIL intervention.

Accordingly, Writ Petition No. 32721 of 2026 was dismissed as devoid of merit, with no relief granted.