In Brief
The Supreme Court held that lands covered by special orders issued under Section 4 of the Punjab Land Preservation Act, 1900 (PLPA) constitute 'forest lands' within the meaning of the Forest (Conservation) Act, 1980. As such, the State Government cannot permit non-forest use of these lands without prior Central Government approval. Once land is deemed forest land under the 1980 Act, its status persists regardless of whether the PLPA order expires. The Court directed authorities to remove illegal non-forest structures on such lands, but only after granting affected persons a hearing within three months. The decision clarifies that broad PLPA notifications alone do not make land 'forest', but specific Section 4 orders restricting activities like tree-cutting and quarrying do.
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