Rational classification in forest regulation: discriminatory grazing charges and a 45-day transit limit were held unconstitutional.

A State may regulate grazing in protected forests, but a classification between resident and non-resident graziers must have a rational nexus to the regulatory object and cannot impose a discriminatory burden. Higher grazing charges for cattle owned by persons from outside Madhya Pradesh were held unconstitutional because the differentiation lacked rational basis and operated as a penal exaction inconsistent with equality and the freedom to move and pursue occupation. The route requirement for cattle transit was upheld as a reasonable forest-protection measure, but the 45-day limit was struck down as arbitrary because it had no reasonable basis and treated non-residents more harshly without justification.

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Issues: (i) whether higher grazing charges imposed on cattle belonging to persons residing outside Madhya Pradesh, as compared with cattle of residents of Madhya Pradesh, were constitutionally valid; (ii) whether the prescription of routes for transit of cattle and the requirement that such cattle leave the State within 45 days were constitutionally valid.

Issue (i): whether higher grazing charges imposed on cattle belonging to persons residing outside Madhya Pradesh, as compared with cattle of residents of Madhya Pradesh, were constitutionally valid.

Analysis: The differentia between resident and non-resident graziers had no rational basis. The forest wealth of the State could not justify a discriminatory levy when cattle of residents would cause the same kind of damage. The charge was treated as a penal exaction directed against persons from other States and was inconsistent with the constitutional guarantee of equality and the freedom of citizens to move throughout India and pursue their occupation, subject only to reasonable restrictions in the public interest.

Conclusion: The higher grazing charges for cattle belonging to persons of other States were unconstitutional and were struck down.

Issue (ii): whether the prescription of routes for transit of cattle and the requirement that such cattle leave the State within 45 days were constitutionally valid.

Analysis: The routing requirement was accepted as a reasonable measure to prevent cattle straying and to avoid indiscriminate damage to forests. The 45-day ceiling, however, had no reasonable basis because cattle of residents were allowed grazing for a year and the risk of overgrazing was already addressed by the other restrictions limiting stay in the same grazing unit. The shorter transit limit was therefore arbitrary.

Conclusion: The route prescription was upheld, but the 45-day limit was declared unconstitutional.

Final Conclusion: The challenge succeeded in part. The discriminatory enhancement of grazing charges and the 45-day transit restriction were invalidated, while the route regulation was sustained as a lawful forest-protection measure.

Ratio Decidendi: A State may regulate use of protected forests, but a classification between residents and non-residents must have a rational nexus to the object of the regulation and cannot justify a discriminatory or arbitrary burden unsupported by reasonable public-interest considerations.

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