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Issues Involved:
1. Legislative competence of the State Government under Section 15 of the Mines and Minerals (Regulation and Development) Act, 1957. 2. Validity of Rule 8C of the Tamil Nadu Minor Mineral Concession Rules, 1959. 3. Application of Rule 8C to the renewal of leases. 4. Applicability of Rule 8C to applications made before its enactment. 5. Impact of Rule 8C on leases for quarrying black granite in Patta lands. Issue-wise Detailed Analysis: 1. Legislative Competence of the State Government under Section 15 of the Mines and Minerals (Regulation and Development) Act, 1957: The Supreme Court examined whether the State Government had the authority to enact Rule 8C under Section 15 of the Mines and Minerals (Regulation and Development) Act, 1957. Section 15 empowers the State Government to make rules for regulating the grant of quarry leases, mining leases, and other mineral concessions in respect of minor minerals. The Court held that regulation under Section 15 includes the power to prohibit the grant of leases in certain cases as part of the regulation process. The Court emphasized that the conservation and prudent exploitation of minerals are paramount considerations, and the State Government's decision to ban private leases for black granite was within its regulatory powers. 2. Validity of Rule 8C of the Tamil Nadu Minor Mineral Concession Rules, 1959: Rule 8C, which bans the grant of leases for quarrying black granite to private persons and reserves such leases for the State Government or its wholly-owned corporations, was challenged for exceeding the rule-making power under Section 15. The Court upheld the validity of Rule 8C, stating that the rule was made in bona fide exercise of the State Government's regulatory powers. The Court found that the rule was aimed at conserving mineral resources and preventing their wasteful exploitation by private entities. The Court also rejected the argument that the rule created a monopoly in favor of the State Government, noting that the regulation of mineral resources in the public interest is a legitimate exercise of legislative power. 3. Application of Rule 8C to the Renewal of Leases: The Court addressed whether Rule 8C applied to the renewal of existing leases. It held that the criteria for granting a renewal of a lease include satisfying the conditions applicable at the time of the initial grant, suitably adapted for renewal. The Court reasoned that applying Rule 8C to renewals was necessary to prevent the frustration of the rule's objective of conserving mineral resources. The Court emphasized that an application for renewal is essentially an application for a fresh lease period and must be considered under the current regulatory framework. 4. Applicability of Rule 8C to Applications Made Before Its Enactment: The Court considered whether applications for leases or renewals made before the enactment of Rule 8C should be decided based on the rules in force at the time of application. The Court held that there is no vested right to have an application dealt with under the rules in force at the time of application. Applications must be decided based on the rules in force at the time of disposal. The Court rejected the argument that the delay in disposing of applications should allow them to be considered under the old rules. 5. Impact of Rule 8C on Leases for Quarrying Black Granite in Patta Lands: The Court clarified that Rule 8C, which bans leases for quarrying black granite to private persons, applies only to government lands where the minerals belong to the government. The rule does not apply to Patta lands where the right to minerals belongs to private owners. Applications for permission to quarry black granite in Patta lands must be dealt with under the relevant rules in Section III of the Tamil Nadu Minor Mineral Concession Rules, 1959. The Court noted that Rule 8C does not impose a general ban on quarrying black granite but only restricts the grant of leases by the government. Conclusion: The Supreme Court allowed the appeals arising from applications for the grant or renewal of leases for quarrying black granite in government lands and dismissed the writ petitions filed in the High Court. However, appeals related to applications for quarrying black granite in Patta lands were dismissed. The Court upheld the validity of Rule 8C and confirmed its applicability to both new leases and renewals, emphasizing the importance of conserving mineral resources.
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