High Court of Jharkhand at Ranchi (Double Bench: Sujit Narayan Prasad & Arun Kumar Rai, JJ.; Order No. 05 dated 08.08.2025, per Sujit Narayan Prasad, J.) — W.P.(C) Nos. 4944, 6684 & 6751 of 2019, a connected writ, and W.P.(C) No. 225 of 2020 — ALL DISMISSED. (i) Villager-petitioners of Hazaribagh district challenging the Gazette notification dated 01.08.2019 declaring an Eco-Sensitive Zone of 900 metres to 5 km around Hazaribagh Wildlife Sanctuary (which, per the notification, treated the 72 villages earmarked in the 1976 sanctuary notification as the green zone and added the red zone of 900 m to 5 km): dismissed because the identical issues — quashing that notification, modifying the Supreme Court's order dated 03.06.2022 fixing a minimum one-km ESZ for each National Park/Wildlife Sanctuary, and special-case treatment of Hazaribagh with a 100–500 m ESZ — were rejected by the Supreme Court on 26.05.2025 in I.A. Nos. 227104, 227108 & 237508 of 2023 in T.N. Godavarman Thirumulpad v. Union of India, W.P.(C) No. 202/1995 (whose reproduced order notes that any alteration of National Park/Wildlife Sanctuary or ESZ boundaries can be done only by the Standing Committee of the National Board for Wildlife); this Court therefore found the writ petitions merited no interference. (ii) Sanjay Kumar Singh v. State of Jharkhand (W.P.(C) No. 225 of 2020): Letter Nos. 1120 & 1131 dated 25.11.2019 of the District Mining Officer, Gumla stopping the petitioner's stone-crushing operations (4.10 and 5.00 acres, Mouza Fasia) and terminating the leases for the rest of the period upheld — (a) principles of natural justice have no straitjacket formula; non-issue of a show-cause notice is no error warranting interference where the decisive fact (the lease area falling within the Eco-Sensitive Zone notified by the Central Government's Gazette notification dated 09.08.2019) is undisputed and no reply could change the outcome, hearing in such a case being a futile exercise and empty formality (relying on Escorts Farms Ltd. v. Commissioner, Kumaon Division, (2004) 4 SCC 281, para 64, and Dharampal Satyapal Ltd. v. Dy. Commissioner of Central Excise, Gauhati, (2015) 8 SCC 519, para 39; the general principle acknowledged per Maneka Gandhi v. U.O.I., (1978) SCC 248); (b) the jurisdictional attack failed as the District Mining Officer acted on the Central Government's Gazette notification in the light of the Supreme Court's Godavarman judgment; (c) the petitioner himself admitted the land lay within the notified ESZ, so he could not claim to mine contrary to the notified decision.
