Forest lease renewal requires Central approval where quarrying would continue non-forest use under conservation law.

Renewal of quarry leases over forest land after the Forest (Conservation) Act, 1980 is subject to prior approval of the Central Government because continued quarrying amounts to use of forest land for a non-forest purpose and may further deforestation. The renewal provisions in the Gujarat Minor Mineral Rules, 1966 do not create an absolute right to renewal where later central conservation legislation imposes a mandatory approval regime. The earlier precedent on mining in already broken-up land was distinguished, as these matters concerned renewal of quarry leases rather than mere continuation of pre-existing mining operations. Refusal to renew was therefore upheld.

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Issues: Whether renewal of existing quarry leases in forest land after the commencement of the Forest (Conservation) Act, 1980 could be granted without prior approval of the Central Government and whether the lessees had an enforceable right to such renewal.

Analysis: Section 2 of the Forest (Conservation) Act, 1980 prohibits any order for dereservation of reserved forest or use of forest land for non-forest purpose except with the prior approval of the Central Government. The renewal of quarry leases after the Act would have the effect of permitting continued use of forest land and could promote further deforestation, which is contrary to the object of the Act. The renewal provisions in the Gujarat Minor Mineral Rules, 1966 could not be read as conferring an absolute right to renewal when the later central legislation imposed a mandatory conservation regime. The earlier decision concerning existing mining operations on already broken-up land was distinguished because the present cases involved requests for renewal of quarry leases, not merely continued use of land already opened up for mining before the Act.

Conclusion: Renewal of the quarry leases could not be claimed as a matter of right without prior approval of the Central Government, and the refusal to renew was upheld.

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