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Issues:
1. Validity of the imposition and collection of coal cess by the Janapada Sabha, Chhindwara. 2. Interpretation and validity of the Madhya Pradesh Koyala Upkar (Manyatakaran) Adhiniyam Act 18 of 1964. 3. Effect of the Act on previous judgments and legal declarations regarding the coal cess levy. Analysis: 1. Validity of Coal Cess Imposition: The appeals were filed by the Janapada Sabha, Chhindwara against the High Court's judgment declaring the Madhya Pradesh Coal Cess (Validation) Act 18 of 1964 ineffective in legalizing the imposition of cess at varying rates per ton under notifications issued by the Independent Mining Local Board. Previous challenges to the levy were upheld by the Supreme Court, which found the increased levy without prior sanction illegal. The High Court also ruled against the validity of the enhanced levy, leading to the enactment of Act 18 of 1964 to rectify the defects. 2. Interpretation of Act 18 of 1964: The Madhya Pradesh Koyala Upkar (Manyatakaran) Adhiniyam Act 18 of 1964 aimed to validate the imposition and collection of coal cess by local authorities. However, the High Court judges differed in their interpretation of the Act's effectiveness. One judge found the Act ineffective in legalizing the cess imposed under previous notifications, while another judge held a contrary view. The Act was scrutinized for its drafting deficiencies and its failure to clearly amend the previous enactments under which the cess was imposed. 3. Effect on Previous Judgments: The Supreme Court reiterated that the Act could not overturn the previous judgment declaring the levy invalid due to lack of proper sanction. The Act's attempt to retroactively amend the law was deemed unconstitutional, as it sought to challenge a binding legal declaration by the Court. The Court emphasized that legislative amendments could not render a court judgment ineffective or alter the interpretation of the law as established by the Court. The judgment in the previous case was upheld as binding on all parties and courts within the territory of India. In conclusion, the appeals challenging the validity of the coal cess imposition and the interpretation of Act 18 of 1964 were dismissed by the Supreme Court. The Court affirmed the binding nature of its previous judgment and declared the Act's attempt to override it as unconstitutional. The legal principles of tax legislation and the limitations on legislative power to alter court judgments were underscored in this comprehensive analysis.
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