What is the core rule from Samatha?

In Scheduled Areas, government, tribal and forest lands cannot be leased to non-tribals or private companies for mining. The term 'person' includes the State.

Why did the Court ban such leases?

To protect tribal rights under the Fifth Schedule. The law must be read to stop exploitation and keep land with tribal communities.

Are all transfers covered?

Yes. Transfer includes sale, lease, mortgage, and similar dealings. Any such alienation to non-tribals is barred in Scheduled Areas.

Who may run mining in these areas?

Only the State Mineral Development Corporation or a cooperative of tribal persons. Profits should fund local services and infrastructure.

Were environmental laws violated here?

The Court found no conclusive proof of Forest Conservation Act violation and no breach of the Environment Protection Act on the record.

Samatha v. State of Andhra Pradesh

Supreme Court of India 1997 (8 SCC 191) Author: Gulzar Hashmi India Fifth Schedule ~7 min read

The Court safeguarded tribal land in Scheduled Areas. It said leases to non-tribals/private firms for mining are void. Laws must be read to protect tribal people—not to enable their dispossession.

Slug: samatha-v-state-of-andhra-pradesh Gulzar Hashmi India Constitutional / Tribal Rights

Quick Summary

The Supreme Court held that in Scheduled Areas, land belonging to government, tribals, or forest cannot be leased to non-tribals/private companies for mining. Such leases are null and void. Laws for tribal welfare must be read in a way that protects tribal communities.

Issues

Can Scheduled Area lands be leased to non-tribals/private firms for mining?
Are such leases void under the Fifth Schedule?
Do the leases break the Forest Conservation Act, 1980 or the Environment Protection Act, 1986?

Rules

“Person” is broad: Includes natural and artificial persons and the State when it serves tribal protection.
Pro-tribal reading: Laws must be read to prevent exploitation and safeguard tribal rights.
Transfer is wide: Covers sale, lease, mortgage, and similar alienations.
Purposive interpretation: Choose meanings that advance the protective aim of the law.

Facts — Timeline

Timeline illustration for Samatha case on Scheduled Areas

Leases: Andhra Pradesh granted mining leases over land in Scheduled Areas to non-tribals/private entities.

Challenge: Samatha, a tribal rights group, moved the High Court.

Grounds: Violation of the AP Scheduled Areas Land Transfer Regulation, 1959 and the Forest Conservation Act, 1980.

High Court: Petition dismissed. Samatha appealed to the Supreme Court.

Arguments

Appellant (Samatha)

Leases to non-tribals violate the 1959 Regulation and the Fifth Schedule.
“Person” should include the State; State cannot bypass protection by itself leasing out.
Transfers include leases; alienation to non-tribals is barred.

Respondent (State)

Leases were for development; State action is different from private transfers.
Environmental breaches not proven on record.
Reading “person” to include State is too wide.

Judgment

The Supreme Court allowed the appeal. It held that Section 3(1)(a) of the 1959 Regulation covers the State within “person”. Leases in Scheduled Areas to non-tribals/private companies for mining are prohibited.

All such leases are null and void; non-tribal mining must stop within six months.
Mining may be done only by the State Mineral Development Corporation or tribal cooperatives.
Profits must support infrastructure and social services in these areas.
No conclusive proof of FCA breach; no violation of EPA found on record.

Ratio Decidendi

Read protective laws with a purposive lens. “Person” includes the State if that reading advances tribal protection. Any transfer (including leases) of Scheduled Area land to non-tribals for mining is barred.

Why It Matters

Strong shield for tribal self-determination and land rights.
Stops back-door alienation via State leases.
Sets a model for welfare-oriented interpretation of protective laws.

Key Takeaways

“Person” ⟶ includes the State.
Transfer ⟶ sale + lease + mortgage.
Leases to non-tribals ⟶ void.

Mining only by State/tribal co-ops.
Profits fund local welfare.
Purposive reading favors tribal rights.

Mnemonic + 3-Step Hook

Mnemonic: “STAY WITH TRIBE”

Scope: “Person” includes State.
Transfer: Lease = transfer in Scheduled Areas.
Yardstick: Choose purposive reading that protects tribals.

IRAC Outline

Issue: Are mining leases to non-tribals over Scheduled Area land valid?

Rule: Fifth Schedule + AP 1959 Regulation; “person” includes State; transfer includes leases; purposive interpretation.

Application: State leases to non-tribals defeat protection; leases are void; mining limited to State/tribal bodies.

Conclusion: Leases to non-tribals are invalid; operations must align with tribal welfare and public interest.

Glossary

Scheduled Areas: Areas listed for special protection of tribal communities under the Constitution.
Fifth Schedule: Constitutional scheme to govern Scheduled Areas and protect tribal interests.
Purposive Interpretation: Reading a law to achieve its protective purpose rather than defeat it.
Transfer: Any alienation of rights in land, including lease and mortgage.

FAQs

No. “Person” includes the State, so such leases to non-tribals are barred and void.

Only the State Mineral Development Corporation or a cooperative of tribal persons, with profits used for local welfare.

No conclusive Forest Conservation Act breach was proven; no EPA violation was established on the record.

Purposive interpretation—choose meanings that protect tribal communities and prevent exploitation.

Case Card

CASE_TITLE: Samatha v. State of Andhra Pradesh
PRIMARY_KEYWORDS: Fifth Schedule; tribal land; mining leases
SECONDARY_KEYWORDS: Scheduled Areas; purposive interpretation; FCA 1980; EPA 1986
PUBLISH_DATE: 25 Oct 2025
AUTHOR_NAME: Gulzar Hashmi
LOCATION: India
Slug (auto): samatha-v-state-of-andhra-pradesh
Canonical: https://thelaweasy.com/samatha-v-state-of-andhra-pradesh/