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Issues Involved:
1. Legislative competence of Parliament to enact the Coal Mines (Nationalisation) Amendment Act, 1976. 2. Applicability of the Nationalisation Amendment Act to composite mines containing coal and fireclay. 3. Alleged discrimination and violation of fundamental rights under Articles 14, 19, and 31 of the Constitution. 4. Public purpose and payment of compensation under the Nationalisation Amendment Act. Issue-Wise Detailed Analysis: 1. Legislative Competence of Parliament: The petitioners challenged the legislative competence of Parliament to enact the Coal Mines (Nationalisation) Amendment Act, 1976, under Entry 54 of List I of the Seventh Schedule. They argued that the Act was not in public interest and merely terminated leases without ensuring regulation and development of mines. The Court found no substance in this argument, noting that the Act was designed to serve the purpose of Entry 54 by ensuring the rational, coordinated, and scientific development of coal resources. The Court emphasized that the Act was an extension of the Coal Mines (Nationalisation) Act, 1973, and was necessary for conserving and developing coal resources. 2. Applicability to Composite Mines: The petitioners contended that the Nationalisation Amendment Act did not apply to composite mines containing both coal and fireclay. The Court examined the definitions of 'coal mine' and 'coking coal mine' in the relevant Acts and concluded that composite mines were not intended to be acquired under the Nationalisation Acts. However, the Court held that the provisions of Sections 3(3)(a) and 30(2) of the Nationalisation Amendment Act would apply to composite leases, prohibiting coal mining operations by lessees of composite mines. Consequently, lessees could not mine fireclay if it involved mining coal. 3. Alleged Discrimination and Violation of Fundamental Rights: The petitioners argued that the Nationalisation Amendment Act violated Articles 14, 19, and 31 by discriminating against lessees whose leases were terminated without compensation, unlike lessees of other mines who were compensated. The Court rejected this argument, stating that the Act merely extinguished the rights of lessees without acquiring their mining businesses. The Court found that the Act was protected under Article 31A(1)(e), which exempts laws extinguishing or modifying rights in leases from being void under Articles 14, 19, and 31. 4. Public Purpose and Payment of Compensation: The petitioners contended that the Act lacked a public purpose and did not provide for compensation, thus violating Article 31. The Court held that the public purpose behind the Act was the same as that of the Coal Mines (Nationalisation) Act, 1973, which aimed at the rational and scientific development of coal resources. The Court emphasized that the Act did not acquire the lessees' businesses but merely terminated their leases, which was within the legislative competence of Parliament and served a legitimate public purpose. Conclusion: The Supreme Court upheld the validity of the Coal Mines (Nationalisation) Amendment Act, 1976, dismissing the writ petitions challenging the Act. The Court found that the Act was within the legislative competence of Parliament, served a public purpose, and did not violate the fundamental rights of the petitioners. The Act's provisions applied to composite mines, prohibiting coal mining operations by lessees of such mines. The Court also held that the Act was protected under Article 31A(1)(e) and did not require compensation for the termination of leases.
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