In T.N. GODAVARMAN THIRUMULPAD v. UNION OF INDIA, (1997) 2 SCC 267, the Supreme Court interpreted 'FOREST' under the Forest Conservation Act 1980 to mean:

1. T.N. Godavarman v. UoI (1997) is a sweeping PIL on forest conservation. 2. The Supreme Court held that the word 'forest' in the Forest Conservation Act 1980 must be understood in its DICTIONARY MEANING — covering all statutorily recognised forests, all areas recorded as forest in government records (irrespective of ownership), AND all areas which are FORESTS BY APPEARANCE. 3. The case became a 'continuing mandamus' with ongoing supervisory orders for decades. 4. The Court suspended all non-forest activity in forest areas without prior Central Government approval under Section 2 FCA 1980. 5. Hence option B is correct. _Source: EPA 1986 / Constitution of India / Stockholm/Rio/Paris / Indian SC environmental jurisprudence — T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267_