On 19 April 2024, a two-judge bench restated the narrow scope of the Order XLVII review jurisdiction, protected reserved forest land against a private title claim, and imposed ₹5 lakh costs recoverable from the officers who filed collusive affidavits.
On 1 March 2025, a Full Bench of the Madhya Pradesh High Court annulled the 2015 notification exempting 62 forest species from the Transit Rules as ultra vires the Indian Forest Act and violative of Articles 14, 21 and 48-A.