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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:

Aonly forests notified by the Central Government in writing (cf. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267) (cf. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267)
Bonly forests above 1000 meters altitude in any State (cf. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267) (cf. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267)
Cany area meeting the DICTIONARY MEANING of 'forest' — covering all statutorily recognised forests, all areas recorded as forest in government records, AND those areas which are FORESTS BY APPEARANCE
Donly forests within national parks or sanctuaries (cf. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267) (cf. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267)
Answer & Solution
Correct answer: C. any area meeting the DICTIONARY MEANING of 'forest' — covering all statutorily recognised forests, all areas recorded as forest in government records, AND those areas which are FORESTS BY APPEARANCE
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_
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