Forest authorities must expeditiously investigate missing or illegally felled trees, fix responsibility, and enforce statutory protections.

The petitioner filed a Public Interest Litigation under Article 226 concerning 32.36 hectares of forest land in Reserved Forest Compartment No. 608, Village Kachhe, District Uttar Bastar Kanker, diverted in favour of M/s Godawari Power & Ispat Limited for expansion of its Ari-Dongri Iron Ore Mines.

The petitioner alleged that 11,765 trees having a circumference exceeding 20 centimetres were recorded in 2015; 5,695 trees were subsequently reported as remaining in 2018, but a joint inspection in May 2023 found only 712 trees, leaving 4,983 trees unaccounted for.

The State submitted that 11,765 trees had been marked for felling, of which 6,070 had been felled and 5,695 were initially reported as remaining.

A subsequent report dated 19 November 2025 was considered inconsistent with the earlier report dated 2 June 2023, leading to a further inquiry being directed on 20 November 2025.

Whether the alleged disappearance or illegal felling of 4,983 trees from the diverted forest land required judicial directions for inquiry, fixation of responsibility, and action in accordance with law.

Whether the Court should quash the forest-diversion approval granted under Section 2 of the Forest (Conservation) Act, 1980, or otherwise interfere with the mining-related proceedings, including the public-hearing notice.

Whether directions were necessary to ensure protection of the remaining forest land and undertake compensatory or restorative plantation.

The Court exercised jurisdiction under Article 226 of the Constitution of India to address alleged inaction concerning protection of forest land and enforcement of environmental obligations.

It considered the statutory framework under Section 2 of the Forest (Conservation) Act, 1980, the Indian Forest Act, 1927, and the conditions attached to approval for diversion of forest land, which require regulated use of forest land and compliance with statutory safeguards.

The Court also referred to the constitutional obligations under Articles 48-A and 51-A(g) to protect and improve the environment and to safeguard forests and wildlife.

Reliance was placed on T.N. Godavarman Thirumulpad v. Union of India, (2006) 1 SCC 1, reflecting the principle that forests and ecological resources must receive effective judicial and administrative protection.

Where the competent authority has already initiated an inquiry into disputed factual matters, the Court may direct its expeditious completion and require action in accordance with law rather than determine disputed facts in the writ proceedings.

The Court found that the departmental records disclosed a substantial discrepancy between the number of trees initially recorded as remaining and the number found during the later inspection: 5,695 trees were reported as remaining, but only 712 were standing, leaving 4,983 trees unaccounted for.

This discrepancy was sufficient to warrant administrative investigation, but the Court noted that the Forest Department had already initiated an inquiry to ascertain the factual position and fix responsibility.

Since the later inquiry report dated 19 November 2025 was considered inconsistent with the earlier report, the competent authority had directed a fresh inquiry on 20 November 2025.

The Court therefore considered it inappropriate to conclusively determine the alleged illegal felling or quash the diversion approval while the factual inquiry remained pending.

Instead, applying the statutory and constitutional duty to protect forests, it directed the authorities to complete the inquiry, determine responsibility, take lawful action, and ensure that no activity violated the forest-diversion approval or applicable statutory provisions.

The Court further emphasized compensatory and restorative plantation to address the ecological loss.

The Court disposed of the PIL with directions to the concerned authorities to conclude the pending inquiry expeditiously, ascertain the exact factual position, fix responsibility for trees illegally felled or found missing, if any, and take appropriate action strictly in accordance with law.

The authorities were also directed to protect the subject forest land and ensure compliance with statutory provisions and the conditions of diversion approval.

The Court further expected the State to undertake compensatory and restorative plantation, preferably planting more trees than those cut, felled, or otherwise lost, particularly in and around the affected area.

All pending interlocutory applications were disposed of, and the PIL was accordingly closed.