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Issues:
1. Whether "brick-earth" qualifies as a "minor mineral" under the Mines and Minerals (Regulation and Development) Act, 1957. Analysis: The Supreme Court considered the definition of "minor mineral" under Section 3(e) of the Mines and Minerals (Regulation and Development) Act, 1957, which includes substances like building stones, gravel, ordinary clay, and ordinary sand, among others. The central issue was whether "brick-earth" could be classified as a mineral and, consequently, notified as a minor mineral by the Central Government. The appellant argued that for a substance to be considered a minor mineral, it must first qualify as a mineral. The Court agreed with this contention, emphasizing that the term "mineral" is not a fixed concept but can have varied meanings based on context. The Court cited examples where substances like sand and gravel, even when found on the surface, were considered minerals. This broad interpretation of the term "mineral" was crucial in determining the eligibility of "brick-earth" as a minor mineral. Furthermore, the Court referred to various judgments, including international precedents, to illustrate the contextual nature of the term "mineral." The Court highlighted that the word "mineral" does not have a singular definition but rather a contextual connotation that can vary based on the specific circumstances of its use. The Court also analyzed English cases where substances like clay, gravel, sand, and stone were classified as minerals, demonstrating the flexible nature of the term. In light of these considerations, the Court concluded that "brick-earth" could indeed be encompassed within the definition of "minor mineral" under the Act, especially since it was used for making bricks, aligning with the broader understanding of what constitutes a mineral. The Court dismissed the appeal, upholding the view that "brick-earth" qualifies as a minor mineral under the Mines and Minerals (Regulation and Development) Act, 1957. The decision was supported by previous judgments such as Laddu Mal v. State of Bihar, Amar Singh Modilal v. State of Haryana, and Sharma & Co. v. State of U.P., which had taken a similar stance on the interpretation of the term "mineral." The Court disagreed with the Calcutta High Court's perspective that "ordinary earth" could not be considered a minor mineral, emphasizing the expansive scope of the term "mineral" within the legislative framework. Ultimately, the Court's ruling affirmed the classification of "brick-earth" as a minor mineral, thereby settling the issue raised in the appeal.
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