Forest Officer Cannot Decide Land Ownership: Supreme Court Cancels Claim Over 102 Acres in Telangana's Gurramguda Forest Block

“Summary proceedings under Forest Law cannot displace settled title under Jagir Abolition or bypass civil court jurisdiction,”  In a powerful reiteration of the limits of statutory authority and the sanctity of public land, the Supreme Court of India on December 18, 2025, in the case titled The State of Telangana v. Mir Jaffar Ali Khan (Dead) through LRs & Ors., struck down the decision of the Forest Settlement Officer (FSO) to exclude 102 acres of land in Survey No. 201/1 of Gurramguda Forest Block, Ranga Reddy District, Telangana, from the reserve forest process. The Court delivered a decisive verdict that the land belongs to the Government and directed the State to complete final forest notification within 8 weeks.

“Forest Settlement Officer Cannot Adjudicate Ownership or Title to Land – That Power Lies Only With Civil Courts,” declares Supreme Court

The case involved a disputed claim by the legal heirs of Salar Jung III, who approached the FSO in 2005 asserting that the 102-acre parcel was their private Arazi-Makta land, originally purchased in 1833 by their ancestor, and should not be part of the Gurramguda Reserve Forest. While the claim was accepted by the FSO in 2014, and upheld by the Principal District Judge and the Telangana High Court in 2023, the Supreme Court reversed every layer of these findings, calling them jurisdictionally flawed, factually unsustainable, and legally perverse.

The bench comprising Justice Pankaj Mithal and Justice S.V.N. Bhatti ruled that the FSO, under Section 10 of the Telangana Forest Act, 1967, cannot determine land ownership or title.

“The jurisdiction of the FSO is limited to summary inquiry. It cannot decide ownership or settle complex title disputes,” the Court observed while voiding the entire claim.

“Title to Government Land Cannot Be Unseated By Dubious Claims or Faulty Revenue Entries,” says Top Court While Restoring Government Possession Since 1953

The Court made it clear that the land had already vested in the State after the Hyderabad (Abolition of Jagirs) Regulation, 1358 Fasli (1949 AD), and that possession with the Forest Department since 1953 had ripened into title by adverse possession. The Court noted that the claim petition was filed after a delay of 53 years, and observed:

“Even if delay in filing under forest law is condonable, limitation under the Limitation Act for claiming title cannot be diluted. Rights lost by prescription cannot be revived by summary claims.”

The respondents’ reliance on an 1833 sale deed, a 1954 letter from the Jagir Administrator, and certain entries in revenue records was found to be tenuous and uncorroborated. The Court went further to say that revenue entries were tampered with in the 1980s, and even the FSO had earlier rejected the claim in 2010, only to reverse itself later without valid justification.

“Forest Conservation Act Bars Exclusion of Notified Land Without Central Government Approval” – Supreme Court Denounces Flawed Approach by Lower Courts

Crucially, the Court held that the Forest Conservation Act, 1980, requires prior approval from the Central Government for any change in the status of notified forest land. The FSO and the High Court had wrongly assumed that since the land was private Arazi-Makta, no such permission was needed. Rejecting this view, the Supreme Court stated:

“A forest officer cannot, on a mere assumption of private title, exclude land from forest notifications. The legal process demands rigorous scrutiny, not historical conjecture.”

“Judgments Binding on Land Disputes Cannot Be Sidestepped Due to Technicalities” – Apex Court Slams High Court For Ignoring Prior Rulings

One of the most critical errors noted by the Supreme Court was the complete disregard by the High Court of its own earlier judgment in CCCA No. 84 of 1982, and the Supreme Court’s affirmation of that decision in Civil Appeal No. 3354 of 1988, where the same land had been declared Government land, and Salar Jung III’s rights were held to be non-transferable and restricted to life interest only.

The present claimants had argued that they were not parties to that earlier litigation. But the Court was categorical:

“Final judgments on title bind successors-in-interest. A new face does not give rise to a new cause of action where the underlying claim is identical.”

“Forest Department Cannot Represent the State Alone in Title Disputes” – Supreme Court Flags Serious Procedural Lapses

In a scathing observation, the Court pointed out that the original claim petition was filed only against the Divisional Forest Officer, without impleading the State of Telangana through its Secretary or District Collector, who are the only competent authorities to represent the Government in land title cases.

“Misdescription of the State is not a technicality—it is a jurisdictional defect. The Forest Department alone cannot defend Government land in proceedings that affect title,” the Court warned.

“Vesting Under Jagir Abolition Cannot Be Reversed by Administrative Letters or Revenue Tweaks,” Supreme Court Affirms

The Court also examined the 1954 letter from the Jagir Administrator, which the claimants heavily relied on, and rejected its evidentiary value. The letter was not a title deed and did not refer to any specific survey number. Similarly, the Gazette Notification from 1956 listing the land as "purchased land" (Arazi-Makta) was held not to override the legal consequences of the Jagir Abolition Regulation.

“Public lands, once vested in the State under a valid legal process, cannot be divested through letters, revenue notings, or unverified ancestral claims. Title is a matter for courts—not for administration,” the Court declared.

Government Reclaims Land, State Told to Finalise Forest Notification

The Supreme Court allowed the appeal filed by the State of Telangana, set aside the FSO’s 2014 order, quashed the District Judge’s judgment, and overruled the High Court’s 2023 order in CRP No. 417 of 2017. It dismissed the Claim Petition No. 1 of 2005, and restored full Government ownership over the 102-acre parcel.

The Court also directed:

“The Chief Secretary of Telangana shall ensure that the final notification under Section 15 of the Telangana Forest Act is issued within 8 weeks, declaring the land as reserved forest.”

It also dismissed a connected appeal (C.A. No. 9997/2025) filed by another third-party claiming rights to the same land.

This Judgment is a Watershed Moment for Public Land Protection

The Supreme Court’s detailed and authoritative ruling reinforces critical principles of Indian land law:

• Statutory officers like FSOs cannot adjudicate title.
• Title once adjudicated by civil courts is final and binding.
• Claims to Government land after decades cannot bypass limitation laws.
• Public interest in forest conservation must prevail over individual claims lacking clear legal basis.

In the words of the Court:

“No individual, however illustrious their ancestry, can lay claim to public land unless the law clearly permits it. History must yield to legality, and private interest must bow before public interest.”

Date of Decision: December 18, 2025