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In SAMATHA v. STATE OF A.P., AIR 1997 SC 3297, the Supreme Court protected:

Athe rights of tribal communities against the transfer of lands in SCHEDULED AREAS to non-tribals for mining and industrial activities (under the Fifth Schedule of the Constitution)
Bthe rights of large industries to develop in tribal areas (cf. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297) (cf. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297)
Cthe rights of the central government to expropriate tribal lands (cf. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297) (cf. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297)
Dthe rights of foreign investors in mining sector (cf. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297) (cf. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297)
Answer & Solution
Correct answer: A. the rights of tribal communities against the transfer of lands in SCHEDULED AREAS to non-tribals for mining and industrial activities (under the Fifth Schedule of the Constitution)
1. In Samatha v. State of Andhra Pradesh (1997), the Supreme Court (per K. Ramaswamy J.) held that: 2. The transfer of lands in SCHEDULED AREAS (under the FIFTH SCHEDULE of the Constitution) to non-tribals or to private companies for mining is UNCONSTITUTIONAL — even by the State Government. 3. The Court read the Andhra Pradesh Scheduled Areas Land Transfer Regulation, 1959 to PROHIBIT such transfer. 4. The judgment was a landmark for tribal rights and environmental governance — though Parliament responded with the Forest Rights Act 2006. 5. Hence option B is correct. _Source: EPA 1986 / Constitution of India / Stockholm/Rio/Paris / Indian SC environmental jurisprudence — Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297_
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