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Issues Involved:
1. Premature termination of mining leases under Section 4A of the Mines & Minerals (Regulation & Development) Act, 1957. 2. Violation of principles of natural justice. 3. Applicability of Section 4A to minor minerals in light of Section 14 of the Act. 4. Adequacy of consultation between the Central Government and the State Government. Issue-wise Detailed Analysis: 1. Premature Termination of Mining Leases: The State of Haryana prematurely terminated mining leases for silica sand and ordinary sand, invoking Section 4A of the Mines & Minerals (Regulation & Development) Act, 1957. The State justified this action by claiming that Haryana Minerals Limited, a public sector undertaking, was fully equipped to undertake the mining operations and had obtained necessary permissions from the Central Government. The High Court found that the essential conditions for exercising powers under Section 4A were not satisfied. 2. Violation of Principles of Natural Justice: The lessees contended that the decision to terminate the leases violated the principles of natural justice as they were not given prior notice or an opportunity to present their case. The High Court agreed, noting that the lessees should have been given a chance to prove that the proposed action would not advance the interest of mines and mineral development. The Supreme Court upheld this view, stating that the affected parties must be heard before a decision to terminate their leases is finalized. 3. Applicability of Section 4A to Minor Minerals: The lessees argued that Section 4A does not apply to leases for ordinary sand, a minor mineral, due to the provisions of Section 14. However, the Supreme Court clarified that Section 4A(2) specifically allows for the premature termination of leases for minor minerals, making it applicable in this case. Despite this, the lessees succeeded on other grounds. 4. Adequacy of Consultation Between Governments: The appellants claimed that there was full and necessary consultation between the Central Government and the State Government, fulfilling the conditions of Section 4A. However, the Supreme Court found that there was no effective consultation as required by the Act. The Central Government had not formed any opinion on the matter, and the State Government's decision lacked the necessary procedural compliance. The Supreme Court emphasized that the consultation should involve a thorough consideration of all relevant factors and the interests of the affected parties. Conclusion: The Supreme Court dismissed the appeals, holding that the premature termination of the mining leases was not justified due to the lack of effective consultation and the violation of principles of natural justice. The lessees were entitled to be heard before any decision to terminate their leases was taken. The Court also clarified that Section 4A applies to both major and minor minerals, but the procedural requirements must be strictly followed.
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