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Issues: Whether bamboo mat is a "forest-produce" within the meaning of section 2(4) of the Indian Forest Act, 1927.
Analysis: The definition of "forest-produce" in section 2(4) was construed along with the definitions of "timber" and "tree". The expression was held not to extend to a commercially new and distinct product manufactured by human labour merely because bamboo itself is included in the definition of tree. The Court declined to enlarge the statutory definition by reading into it an article that is commercially different from the original forest material. It was further held that where the legislature has defined an expression, the court must apply that definition and not the general understanding of the word.
Conclusion: Bamboo mat is not forest-produce under section 2(4) of the Indian Forest Act, 1927, and the confiscation order could not stand.