The SAMATHA judgment was followed by Parliament enacting the:

1. The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 (also called the Forest Rights Act, FRA) was enacted to address tribal land tenure issues. 2. The FRA recognises FOREST RIGHTS of Scheduled Tribes and other traditional forest dwellers who have been residing in forests for generations. 3. Rights recognised include: (i) holding and living in forest land for self-cultivation; (ii) community forest rights (CFRs); (iii) entitlements to minor forest produce; (iv) usufructuary rights; (v) habitat and cultural rights of vulnerable groups. 4. Implementation has been controversial — slow recognition of CFRs, ongoing tension with forest protection laws. 5. Hence option B is correct. _Source: EPA 1986 / Constitution of India / Stockholm/Rio/Paris / Indian SC environmental jurisprudence — Forest Rights Act 2006 (Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act 2006)_