Contractual forest lease disputes do not gain statutory status under Article 226; royalty revision challenge failed.

An agreement made under Rule 21 of the Assam Forest Regulation, 1891 for rights in a reserved forest remains contractual in law and does not become a statutory contract merely because the Government is a party. A dispute over interpretation or alleged breach of the lease terms, including royalty revision, therefore does not by itself justify invocation of Article 226. Hardship or delay in revising royalty cannot transform a contractual grievance into a writ claim. The petition was held not maintainable under Article 226, and the challenge to the royalty revision failed.

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Issues: Whether the royalty revision dispute arising out of a forest lease contract could be enforced under Article 226 of the Constitution of India, and whether the agreement made under Rule 21 of the Assam Forest Regulation, 1891 acquired statutory character.

Analysis: Rule 21 authorises the Government to grant rights in a reserved forest by contract in writing, but the agreement entered under that provision remains a contract in law and does not become a statutory contract merely because one party is the Government. A dispute about interpretation or alleged breach of such contractual terms does not, by itself, confer a right to invoke writ jurisdiction. The remedy sought was therefore outside the scope of Article 226, and considerations of hardship or delayed revision could not convert a contractual grievance into a writ claim.

Conclusion: The petition was not maintainable under Article 226 for enforcement of the lease terms, and the challenge to the royalty revision failed.

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