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Issues:
Challenge to the validity of the order rejecting the application for renewal of a Certificate of Approval under Mineral Concession Rules, 1949 by the Union of India (UOI) and the subsequent dismissal of the petition by the High Court Punjab. Detailed Analysis: 1. The appellants, a partnership firm engaged in mining, applied for the renewal of a Certificate of Approval in Madhya Pradesh, which was rejected by the State Government citing a change in the partners. The appellants then applied for a review under Rule 57 of the Mineral Concession Rules, 1949 to the Union Government, which was rejected on July 9, 1958. This rejection was challenged through Civil Appeal No. 115 of 1963, along with an appeal against the High Court's dismissal of the petition under Art. 226 of the Constitution. 2. The appellants contended that the Union Government, in rejecting the review application, acted as a quasi-judicial authority under Rule 59. They argued that the decision was void as it was made without disclosing the contents of the State Government's report and without providing the appellants with an opportunity to present their case, citing the principle of natural justice established in Shivji Nathubhai v. The Union of India. 3. The State Government's refusal to renew the Certificate was based on a perceived change in the firm's composition, which the appellants disputed, claiming that the partnership deed allowed for changes without affecting the firm's identity. The appellants insisted on being informed of any points against them in the State Government's report and having an opportunity to respond, as a matter of fairness. 4. The Union Government's decision to reject the review application without disclosing the State Government's report was deemed contrary to the principles of natural justice by the Supreme Court. The Court held that a reasonable opportunity to be heard is essential in quasi-judicial proceedings, overturning the High Court's view that the Central Government's actions were administrative in nature. 5. Consequently, the appeals were allowed, setting aside the orders of the Central Government and the High Court. The Central Government was directed to reconsider the review application in accordance with the law and the observations made in the judgment. The appellants were awarded costs for the appeal in the Supreme Court.
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