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    <title>2022 (6) TMI 1478 - ORISSA HIGH COURT</title>
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    <description>A proposal notification under Section 4 of the Orissa Forest Act, 1972 does not by itself create a reserved forest; the statutory process must be completed through proclamation by the Forest Settlement Officer, inquiry and settlement of claims, and the final reservation notification under Section 21. Because those subsequent steps had not been completed, the quarry land could not be treated as reserved forest merely on the basis of the proposal notification or internal correspondence. The rejection of environmental clearance on that footing was therefore unsustainable and was quashed, with directions to proceed in accordance with law.</description>
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      <description>A proposal notification under Section 4 of the Orissa Forest Act, 1972 does not by itself create a reserved forest; the statutory process must be completed through proclamation by the Forest Settlement Officer, inquiry and settlement of claims, and the final reservation notification under Section 21. Because those subsequent steps had not been completed, the quarry land could not be treated as reserved forest merely on the basis of the proposal notification or internal correspondence. The rejection of environmental clearance on that footing was therefore unsustainable and was quashed, with directions to proceed in accordance with law.</description>
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