Forest land, without evidence to show that forest land had been cleared and prepared or earmarked for agricultural purposes, it must be treated as prima facie non-agricultural land, Controller of Estate Duty v. V. Venugopala Varma Rajah, AIR 1977 SC 121: (1976) 4 SCC 3: (1977) 1 SCR 346.
The term 'forest land', occurring in s. 2, will not only include 'forest' as understood in the dictionary sense, but also any area recorded as forest in the Government record irrespective of the ownership, T.N. Godavarman v. Union of India, AIR 1997 SC 1228 (1230). [Forest (Conservation) Act, 1980, s. 2]
See also W.L. Wadhera v. Union of India, (2002) 9 SCC 108: AIR 2002 SC 1913.
The expression 'forest land' should be given an extended meaning to cover a track of land covered with trees, shrubs, vegetation and undergrowth under mingled with trees with pastures, be it of natural growth or man made forestation. Samatha v. State of Andhra Pradesh, AIR 1997 SC 3297 (3380). [Forest (Conservation) Act, 1980, s. 2]
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