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Issues Involved:
1. Nationalisation of Coke Oven Plants 2. Interpretation of the term "Material Resources of the Community" 3. Applicability of Article 31C of the Constitution 4. Alleged Discrimination and Violation of Article 14 5. Identity of the Coke Oven Plant Detailed Analysis: 1. Nationalisation of Coke Oven Plants: The primary issue revolves around the nationalisation of the Coke Oven Plants owned by the petitioners under the Coking Coal Mines (Nationalisation) Act, 1972. The Act aimed to acquire and transfer the right, title, and interest of the owners of coking coal mines and coke oven plants to the Central Government. The legislation was intended to reorganize and reconstruct such mines and plants for protecting, conserving, and promoting the scientific development of coking coal resources needed for the iron and steel industry. The Court clarified that the management of all coking coal mines and coke oven plants vested in the Central Government from the appointed day under the Coking Coal Mines (Emergency Provisions) Act, 1971. The Act defined 'mine' broadly enough to include 'coke oven plants' within its scope. The Coking Coal Mines (Nationalisation) Act, 1972 further specified that the right, title, and interest of the owners in relation to the coking coal mines and certain identified coke oven plants vested in the Central Government. 2. Interpretation of the term "Material Resources of the Community": The Court addressed the interpretation of the term "material resources of the community" under Article 39(b) of the Constitution. It was argued that private-owned resources could not be considered "material resources of the community" until they were acquired by the State. The Court rejected this narrow interpretation, stating that the term includes all resources, whether public or private-owned, capable of producing wealth for the community. The Court emphasized that the goal of socialism and the Directive Principles of State Policy support this broader interpretation. 3. Applicability of Article 31C of the Constitution: The Court examined whether the Coking Coal Mines (Nationalisation) Act, 1972 was entitled to the protection of Article 31C of the Constitution, which immunizes laws giving effect to the policy of the State towards securing the principles specified in Article 39(b) or (c) from being challenged on the grounds of inconsistency with Articles 14, 19, or 31. The Court upheld the constitutionality of Article 31C as introduced by the Constitution Twenty-fifth Amendment Act, 1971, and stated that the nationalisation of coking coal mines and coke oven plants was directed towards securing the principle of distributing material resources to best subserve the common good. 4. Alleged Discrimination and Violation of Article 14: The petitioners argued that the nationalisation of their coke oven plants was discriminatory, as other similar plants were left out. The Court found no merit in this argument, stating that the nationalisation process could be achieved in stages and that the exclusion of some units in the earlier stages did not constitute a violation of Article 14. The Court also noted that the inclusion of the petitioners' plants in the Second Schedule was justified based on their proximity to nationalised coking coal mines and the need to reorganize and reconstruct the industry. 5. Identity of the Coke Oven Plant: A specific issue was raised regarding the identity of the coke oven plant listed in Item 9 of the Second Schedule to the Coking Coal Mines (Nationalisation) Act. The petitioners claimed that the plant did not belong to them and that there was a mix-up in the names. The Court found no doubt about the identity of the plant, as the petitioners themselves had acknowledged its inclusion in the Second Schedule in their affidavits. Conclusion: The Court dismissed the writ petitions, holding that the Coking Coal Mines (Nationalisation) Act, 1972 was a valid legislation aimed at securing the distribution of material resources for the common good and was protected under Article 31C of the Constitution. The Court also found no merit in the allegations of discrimination and confirmed the identity of the coke oven plant in question. The petitions were dismissed with costs quantified at Rs. 10,000 in each case.
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