Telangana High Court Clarifies Jurisdiction of Forest Officials in Criminal Cases
The Telangana High Court has delivered a significant judgment that clearly delineates the investigative powers of forest department officials, ruling that they lack authority to investigate or file charges for offences under the Indian Penal Code (IPC) such as assault or criminal intimidation.
Court Quashes IPC Proceedings in 2022 Amrabad Forest Assault Case
In a judgment delivered on January 6, 2026, Justice J Sreenivasa Rao partially allowed a writ petition and quashed criminal proceedings under IPC sections against six individuals accused of obstructing and assaulting forest officers in March 2022. The court ruled that continuation of such proceedings would amount to "an abuse of the process of law" and violate principles established by the Supreme Court.
The case originated from an incident in the Mannanur range of Amrabad forest division in Nagarkurnool district, where forest officials had registered a Preliminary Offence Report (POR) against the petitioners. The individuals faced charges under:
- Sections 27 and 56 of the Wildlife Protection Act
- Sections 332 and 333 of IPC (criminal intimidation and voluntarily causing hurt to deter public servants)
"Forest Officials Are Not Police Officers"
The court's judgment made a crucial distinction, stating that "forest officials are not police officers within the meaning of the Code of Criminal Procedure" and therefore lack jurisdiction to investigate penal offences under IPC. This conclusion was reached after considering similar judgments from High Courts of Madhya Pradesh, Chhattisgarh, and Karnataka.
Justice Rao observed: "It is relevant to mention that even if the allegations pertaining to offences under IPC are taken at their face value, they do not disclose the commission of any offence in law, due to the inherent lack of jurisdiction of the investigating authority."
Wildlife Protection Act Powers Upheld, IPC Jurisdiction Denied
While limiting forest officials' authority regarding IPC offences, the court upheld their statutory powers under the Wildlife Protection Act. The judgment clarified that forest officials are entitled to initiate proceedings and conduct investigations into offences specifically under the WLP Act, which confers statutory powers on them for this purpose.
The court was not inclined to quash proceedings regarding offences under sections 27 and 56 of the Wildlife Protection Act, maintaining the forest department's authority within its designated legal framework.
Alternative Legal Remedies Available
The judgment provided guidance for forest officials seeking redress for assaults against them, stating that the order "will not preclude the forest officials from working out their remedies in accordance with law" regarding IPC offences. The court specified that such matters should be pursued through appropriate police channels rather than internal forest department reports.
This clarification ensures that while forest officials cannot independently investigate IPC offences, they retain the right to seek justice through proper legal channels when assaulted or intimidated during duty.
Legal Implications and Precedents
The Telangana High Court's decision establishes important legal boundaries between:
- The specialized jurisdiction of forest officials under wildlife protection laws
- The general criminal jurisdiction of police under the Indian Penal Code
This judgment reinforces the principle that statutory authorities must operate within their designated legal frameworks and cannot assume powers beyond what their enabling legislation provides. The court specifically quashed proceedings related to IPC sections 351, read with 332 and 333, while preserving the Wildlife Protection Act charges.
The ruling provides much-needed clarity for forest departments across India regarding their investigative limitations and proper procedures for addressing assaults against their personnel while performing official duties.
