Statutory Master Plan primacy prevents subsequent vegetation growth from reclassifying earmarked land as deemed forest.

The subject land, admeasuring approximately 12.40 hectares in Bijwasan, Delhi, was originally acquired as agricultural land in 1986 and handed over to the Delhi Development Authority (DDA)

In 2008, the DDA allotted the land to the Railway Authority on a perpetual lease for the development of an Integrated Metropolitan Passenger Terminal (IMPT)

The project was incorporated into the Master Plan of Delhi (MPD) 2015 and 2021 as a "Multi-Use" zone

In 2022, the Rail Land Development Authority (RLDA) issued a Request for Proposal (RFP) for mixed-use development, which was challenged by Respondent No. 5 before the National Green Tribunal (NGT) on the grounds that the land constituted "deemed forest" under the Forest (Conservation) Act, 1980 (the "1980 Act")

The NGT dismissed the application, finding no cogent evidence of the land being forest and noting that the 2023 Amendment to the 1980 Act excluded "deemed forests"

The Appellants, acting as public-spirited individuals, challenged the NGT’s order

1. Whether land that is not recorded as forest in revenue records or declared as such, and does not fulfill the requirements of a "deemed forest" at the time of being earmarked for a project under a statutory Master Plan, can be declared a "deemed forest" due to the subsequent natural growth of trees, thereby overriding the Master Plan?

2. Which date is relevant for determining the nature of land as a "deemed forest": the date the Master Plan came into force or the date project execution was initiated?

Section 2 of the Forest (Conservation) Act, 1980, which restricts the use of forest land for non-forest purposes without Central Government approval

The dictionary-based definition of "forest" established in T.N. Godavarman Thirumulkpad v. Union of India

The character of land cannot be altered merely by subsequent plantation if it was historically non-forest as held in Re: Construction of Park at NOIDA

The statutory finality and binding nature of an approved Master Plan as established in The Auroville Foundation v. Navroz Kersasp Mody

The principle of sustainable development, balancing economic needs with environmental protection as seen in Essar Oil Ltd. v. Halar Utkarsh Samiti

The Court reasoned that a statutory Master Plan is a long-term planning instrument that attains finality and provides certainty for urban development

If land is not recorded as forest when a Master Plan is notified, the subsequent proliferation of vegetation—often consisting of invasive alien species like Prosopis juliflora (Vilayati Kikar) which disrupt native ecosystems—cannot legally transform the land into a "deemed forest"

The Court emphasized that a mechanical application of tree-density tests to determine "deemed forest" status is improper if it ignores the historical character and planned use of the land

Since the subject land was agricultural at the time of acquisition and earmarked for a critical public infrastructure project (the IMPT) under the MPD 2021, the Master Plan must prevail over any ecological changes occurring by efflux of time

The Court also noted that the proliferation of invasive species does not signify a natural forest ecosystem worthy of protection under the 1980 Act

Land earmarked in an approved Master Plan cannot be subsequently declared a "deemed forest" due to later vegetation growth if it was not a forest at the Master Plan's inception

The relevant date for determining "deemed forest" status is the date the Master Plan came into force

The Court directed the respondents to maintain 20% green cover, transplant native/indigenous trees to the maximum extent possible, and undertake compensatory afforestation as per statutory rules