Purposive interpretation of "wood-oil" under forest law brings sandalwood oil within forest produce and supports jurisdiction.

Sandalwood oil was held to fall within "wood-oil" in the inclusive definition of "forest produce" under section 2(f)(1) of the Kerala Forest Act, 1961. The Court applied purposive interpretation, reading the term in statutory context and in light of the Act's object of conserving and protecting forest wealth. It rejected a narrow dictionary-based meaning and held that wood-oil is not confined to oleoresin from Dipterocarpus trees. Because sandalwood oil is extracted from sandalwood trees and roots removed from the forest, proceedings under section 51(1) could validly continue and the trial court had jurisdiction.

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Issues: Whether sandalwood oil is "wood-oil" within the meaning of section 2(f)(1) of the Kerala Forest Act, 1961 and therefore "forest produce", so that proceedings under section 51(1) of the Act could validly continue.

Analysis: The definition of "forest produce" in section 2(f) is inclusive and extends to wood-oil. The Court held that the meaning of the expression must be gathered from the statutory context and the object of the Act, which is the conservation and protection of forest wealth. Sandalwood oil is extracted from sandalwood trees and roots removed from the forest, and the manner of extraction or commercial use is not decisive. A narrow dictionary-based meaning would defeat the purpose of the enactment. The Court therefore applied purposive interpretation and rejected the contention that wood-oil is confined only to oleoresin derived from Dipterocarpus trees.

Conclusion: Sandalwood oil is wood-oil within section 2(f)(1) of the Kerala Forest Act, 1961 and is forest produce. The trial court has jurisdiction to proceed.

Ratio Decidendi: An inclusive statutory definition must be construed purposively in light of the object of the enactment, and a term used in such a definition may cover items falling within its ordinary and contextual sense even if they are not confined to a narrow technical meaning.

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