observed in the said judgment that for the purpose of regularization, there has to be a policy of the State to regularize pre- 25.10.1980 occupation/encroachment of forest land and thereupon, the regularization can only be permissible after obtaining the prior approval of the Central Government. It was further observed that after 25.10.1980, i.e., the date of enforcement of the Act of 1980, no State Government or other authority can pass an order or give a direction for de-reservation of the reserved forest or any part thereof, or permit use of any forest land or any portion thereof for any non-forest purpose, or grant any lease, etc., in respect of the forest land to any private person or any authority, corporation, agency, or organization which is not owned, managed, or controlled by the Government. It was further observed that if any forest land or any portion thereof have been used for non-forest purpose for a particular length of time prior to the enforcement of the Act of 1980, the tenure of such activity cannot be extended by way of a renewal of a lease or otherwise after 25.10.1980 without obtaining the prior approval of the Central Government.
