Ocl Iron & Steels Limited vs Union Of India on 28 July, 2026

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    Orissa High Court

    Ocl Iron & Steels Limited vs Union Of India on 28 July, 2026

                   ORISSA HIGH COURT : CUTTACK
    
                         W.P.(C) No.743 of 2017
    
                  In the matter of an Application under
         Articles 226 and 227 of the Constitution of India, 1950
    
                                 ***
    

    1. OCL Iron & Steels Limited
    (A company under the Companies Act, 1956)
    Having its Registered Office
    At: Lamloi, P.O.: Garvana, Rajgangpur
    District: Sundergarh
    Odisha – 770 017.

    2. Mr. Dilip Das
    Aged about 51 years
    Son of Bidyadar Das
    Having address
    At: Mallapada, Talagadia, Jajpur
    Odisha – 755 043
    (being the Executive Director of
    the Petitioner-Company. … Petitioners

    SPONSORED

    -VERSUS-

    1. Union of India
    Represented by
    The Secretary (Mines)
    Ministry of Mines, 3rd Floor,
    Shashtri Bhavan, Rajender Prasad Road
    New Delhi – 110 001.

    2. Union of India
    Represented by

    W.P.(C) No.743 of 2017 Page 1 of 85
    The Secretary
    The Ministry of Environment Forest
    & Climate Change, Jorbagh
    CGO Complex, Indira Paryavaran Bhawan
    New Delhi – 110 003.

    3. State of Odisha
    Represented by
    The Principal Secretary
    Department of Steel & Mines
    State Secretariat, Bhubaneswar
    Odisha … Opposite parties.

    Counsel appeared for the parties:

    For the Petitioner         : Sri Pinaki Misra,
                                 Senior Advocate
                                 Assisted by
                                 M/s. Saswat Kumar Acharya,
                                 Abhisek Agarwal and
                                 Abhijeet Agarwal,
                                 Advocates.
    
    

    For the Opposite parties : Mr. Saswat Das,
    Additional Government Advocate
    Mr. Himanshu Sekhar Panda,
    Central Government Counsel.

    P R E S E N T:

    HONOURABLE CHIEF JUSTICE
    MR. HARISH TANDON

    AND

    HONOURABLE JUSTICE
    MR. MURAHARI SRI RAMAN

    Date of Hearing : 07.05.2026 :: Date of Judgment : 28.07.2026
    W.P.(C) No.743 of 2017 Page 2 of 85
    J UDGMENT

    MURAHARI SRI RAMAN, J.–

    The petitioners, alleging inaction on the part of the
    opposite parties, particularly the opposite party No.3, in
    depriving it of the property by not executing mining lease
    before the cut-off date, i.e., 11.01.2017, in terms of
    Section 10A(2)(c) of the Mines and Minerals
    (Development and Regulation) Act, 1957 (be referred to
    as “MMDR Act“) read with Rule 8(4) of the Minerals
    (Other than Atomic and Hydro Carbons Energy Mineral)
    Concessions Rules, 2016 (abbreviated as “MC Rules”)
    and thereby discriminating it vis-à-vis sixteen others in
    whose favour lease deeds were executed and registered
    on 11.01.2017, crave for exercise of extraordinary
    jurisdiction under Articles 226 and 227 of the
    Constitution of India to issue writ of mandamus to the
    opposite parties and beseeches grant of following
    relief(s):

    “In the circumstances, it is therefore most humbly prayed
    that this Hon‟ble Court may kindly be graciously pleased
    to:

    (a) Pass appropriate writ, order or direction to the effect
    that the State Government shall execute and register
    the mining lease deed with the petitioner promptly
    as the petitioner has complied all the conditions vide
    its Letter dated 23.12.2008 as required under
    Section 10A(2)(c) of the MMDR Act and/or;

    W.P.(C) No.743 of 2017 Page 3 of 85

    (b) Pass appropriate writ, order or direction or
    declaration to the effect that the grant of mining
    lease shall not lapse or forfeited in the event the
    mining lease deed is not-executed and/or registered
    on or before 11.01.2017, and/or

    (c) Pass appropriate writ, order or direction to the effect
    that the mining lease can be executed even after
    11.01.2017, and/or;

    (d) Pass appropriate writ, order or direction or
    declaration to the effect that the provisions of Rule
    8(4) of the Mineral Concession Rules, 2016 to the
    extent it seeks to forfeit the right of the petitioner on
    after 11.01.2017 is declared ultra-vires, illegal being
    contrary to the provisions of the MMDR Act and the
    Constitution of India;

    (e) Pass appropriate writ, order or direction in the
    nature of declaration that the provisions Clause (c) of
    sub-section (2) Section 10A of the MMDR Act to the
    extent it seeks to curtail, abridge or restrict the right
    of the petitioner after a period of two years (i.e. after
    11.01.2017) is unconstitutional, ultra-vires and
    violative of the Article 14 and 19 and other
    provisions of Constitution of India;

    (f) Pass appropriate writ, order or direction in the
    nature of declaration that the conditions No. 2(i) of
    the Guidelines dated 30.11.2016 is declared ultra
    vires illegal and not binding;

    (g) Pass any other or further order as may be deemed
    fit and proper by this Hon‟ble Court.

    And for this act of kindness, the petitioners shall as in
    duty bound ever pray.”

    W.P.(C) No.743 of 2017 Page 4 of 85

    The facts:

    2. The necessary background facts as adumbrated by the
    petitioners giving rise to filing of this the writ petition is
    narrated hereunder.

    2.1. The Government of India in Ministry of Mines vide Letter
    bearing No.5/111/2008-M.IV, dated 29.09.2008
    accorded approval under Section 5(1) of the MMDR Act
    by invoking the provisions of Section 11(5) and by
    relaxing provisions under sub-rules (1) and (2) of Rule
    59 of the Mineral Concession Rules, 1960 for grant of
    mining lease for iron ore over an area of 45.131 hectares
    in the village Kundaposi in the district of Keonjhar in
    favour of the OCL India Ltd.1 for a period of twenty five

    1 Vide Order dated 27.11.2007 in the company petition being COPET No.27 of
    2007 the company judge of this Court sanctioned “Scheme of Arrangement” and
    allowed demerger of the Steel Undertaking (Sponge Iron Works) of OCL India
    Limited vis-a-vis M/s.OCL India Ltd., OCL Iron and Steel Ltd., Konark Minerals
    Ltd. and Dalmia Cement Ltd. and, thereby allowed transfer and vesting of all
    assets and liabilities of said undertaking, which was duly registered by the
    Registrar of the Companies on 20.12.2007 and acknowledged by the
    Government of Odisha vide Steel and Mines Department Letter No.VSL-

    71/03/4084/SM, dated 27.05.2008. Interlocutory Application bearing
    No.15936 of 2025 during pendency of the writ application was filed by the
    company named “OCL Iron and Steel Limited” for amendment of cause title as
    the new company was admitted to corporate insolvency resolution process in
    terms of Insolvency and Bankruptcy Code, 2016 pursuant to an Order dated
    20.09.2021 by the learned National Company Law Tribunal, Cuttack Bench.
    Said petition of the petitioner-company being not opposed to by none of the
    opposite parties, has been allowed by this Court vide Order dated 15.10.2025
    and accordingly original cause titled stands replaced by the amended cause title
    depicting the name of the company as “OCL Iron & Steels Limited” in place of
    “OCL Iron and Steel Limited”.

    Intimation was made to proper quarters as per Rule 62 of the Mineral
    Concession Rules, 1960, which stood as follows:

    “62. Change of name, nationality, etc. to be intimated.–

    (1) An applicant for, or the holder of a reconnaissance permit, a prospecting
    licence or a mining lease shall intimate to the State Government within
    W.P.(C) No.743 of 2017 Page 5 of 85
    years in response to the recommendation of the State
    Government in Department of Steel and Mines,
    Bhubaneswar vide Letter No.5198/ III(A)SM-

    46/2002/SM, dated 08.07.2008 issued in consideration
    of application dated 20.06.2002 in this regard by the
    company. By Letter Ref. No.RG:MN:01, dated
    24.12.2008, the petitioner-company conveyed
    acceptance of the terms and conditions embodied in
    Steel and Mines Department Letter No.8556-III(A)SM-
    46/2002/SM, dated 23.12.2008 granting lease for
    twenty years2.

    2.2. The Government of India in Ministry of Mines, Indian
    Bureau of Mines, Office of the Regional Controller of
    Mines, vide Letter No.MP/OTF. MECH/10-ORI/BHU/

    sixty days any change that may take place in his name, nationality or
    other particulars mentioned in the relevant Forms.
    (2) If the holder of a reconnaissance permit or a prospecting licence or a
    mining lease fails, without sufficient cause, to furnish the information
    referred to in sub-rule (1), the State Government may determine the
    reconnaissance permit or prospecting licence or mining lease, as the case
    may be:

    Provided that no such order shall be made without giving the permit
    holder or the licensee or the lessee, as the case may be, a reasonable
    opportunity of stating his case.”

    2 By Steel and Mines Department Proceeding No.III(A)SM-46/2002/SM
    communicated in Memo No.897/SM, dated 04.02.209, it has been
    acknowledged as follows:

    “Whereas M/s. OCL India Ltd. has filed mineral concession applications in the
    State of Odisha as read above;

    ***
    Whereas the Scheme of Arrangement came into effect from the appointed date,
    i.e., 01.01.2007 and it is already acknowledged by this Department and
    communicated vide this Department Letter No.4084, dated 27.05.2008;
    ***
    Now, therefore, the State Government are hereby pleased to order that the mining
    lease for iron ore over an area of 45.131 hectares in village Kundaposi of
    Keonjhar District for grant in favour of M/s. OCL India Ltd. will now be treated as
    decided to be grant in favour of M/s. OCL Iron & Steel Ltd.”

    W.P.(C) No.743 of 2017 Page 6 of 85

    2009-10, dated 24.08.2009 approved the mining plan
    with certain conditions stipulated therein. A Certificate
    dated 24.11.2010 has come to be issued by the
    Collector, Keonjhar, the Chairperson of DLC, after
    undertaking process for diversion and settlement of
    rights under the Scheduled Tribes and Other Traditional
    Forest Dwellers (Recognition of Forest Rights) Act, 2006

    which inter alia certified that:

    “It is certified on the basis of joint verification report dated
    01.07.2010 and Gram Sabha Resolution that no such
    facilities managed by Government requiring diversion of
    forest land under Section 3(2) of the Forest Rights Act,
    2006 exist over the forest land proposed for diversion.”

    In furtherance thereto, Form II (for Projects other than
    Linear Projects) dated 06.09.2013 was issued from the
    Office of the District Collector, Keonjhar inter alia
    asserting that “The rights of primitive tribal groups and
    pre-agricultural communities where applicable have been
    specifically safeguarded as per Section 3(1) of the Forest
    Rights Act.”

    2.3. This apart, by Letter No.432/SE/AA, dated 14.01.2013
    the State Environment Impact Assessment Authority
    (SEIAA), Odisha (constituted vide Order No.S.O. 1899(E),
    dated 17.08.2012 of Ministry of Environment and
    Forests, Government of India) informed that the SEAC,
    Odisha has recommended for grant of Environmental

    W.P.(C) No.743 of 2017 Page 7 of 85
    Clearance subject to submission of authentic copy of
    Stage-I Forest Clearance.

    2.4. On 01.04.2015 “Guidelines for diversion of forest land
    for non-forest purposes under the Forest (Conservation)
    Act, 1980
    ” was issued vide F.No.11-599/2014-FC by the
    Government of India, Ministry of Environment, Forest
    and Climate Change (Forest Conservation Division) with
    one of the conditions envisaged therein as follows:

    “Henceforth, in case of mining leases, including those of
    Government Authorities, having forest land in part or in
    full, approval of Central Government under Section 2(iii) of
    the Forest Act, for the entire forest land located within a
    mining lease shall be obtained before execution (including
    by way of renewal) of a mining lease in accordance with
    the provisions of the Mines and Minerals (Development
    and Regulation) Act, 1957
    (MMDR Act) and the Rules
    framed thereunder.”

    Though an application was filed for grant of general
    approval under Section 2(iii) of the Forest (Conservation)
    Act, 1980 for entire forest area including the safety zone
    area, in view of Operational Guidelines dated 16.11.2016
    issued by the Ministry of Environment, Forest and
    Climate Change (Forest Conservation Division) vide
    F.No.9-31/2016-FC, dated 16.11.2016 instructing to file
    such application by online process “for seeking
    permission for getting forest land on lease under Section
    2(iii)
    of Forest Conservation Act, 1980″ and vide F.No.8-

    W.P.(C) No.743 of 2017 Page 8 of 85
    31/2016-FC, dated 17.11.2016 instructing to “apply
    online on the prescribed form” as made available on
    webportal of the Ministry, the petitioner stated to have
    filed “online application” on 20.12.2016, which was
    forwarded by the State Government for consideration of
    proposal under Section 2(iii) of the Forest Conservation
    Act, 1980 to the Ministry of Environment, Forest and
    Climate Change.

    Government of India in Ministry of Environment Forest
    and Climate Change (Forest Conservation Division)
    issued Guidelines for diversion of forest land for non-
    forest purposes under the Forest (Conservation) Act,
    1980
    with the following clarification vide Letter bearing
    F.No.11-599/2014-FC, dated 19.10.2015:

    “I am directed to refer to this Ministry‟s letter of even
    number dated 1st April 2015 on the above-mentioned
    subject, and to say that some of the States have
    sought clarification from this Ministry on
    applicability of para 2(v)3 of the said letter to the

    3 Clause (v) of Paragraph 2 of the Guidelines in Letter dated 01.04.2015 stood as
    follows:

    “In case of existing mining leases having forest land in part or in full, where
    approval under Section 2 of the FC Act for a part of the forest land has only been
    obtained, Central Government hereby accords general approval under Section
    2(iii)
    of the FC Act for the remaining area of the forest land falling within such
    mining leases, subject to following conditions:

    (a) State Government shall, within a .period of one year from the date of issue
    of this letter, realize from the user agency, NPV of the entire forest land
    falling in the mining lease, in case NPV of such forest land has not already
    been realised;

    (b) In case State Government fails to realize from the user agency, NPV of the
    entire forest land falling in a mining lease within a period of one year from
    the date of issue of this letter, this general approval in respect of such
    mining lease, shall be kept in abeyance, and shall be deemed to have
    W.P.(C) No.743 of 2017 Page 9 of 85
    existing mining leases (as on the date of the issue of
    the said letter) having Forest land in part where
    approval under Section 2 of the Forest (Conservation)
    Act, 1980 for even a part of the forest land falling in
    such leases has not been obtained, and to say that
    to facilitate this Ministry to take decision on the
    matter, details of existing mining leases having
    forest land in part or in full for which though the
    mining lease has already been executed at least
    once before 1st April 2015 but approval under die
    Forest (Conservation) Act, 1980 for even a part of
    forest land falling in such mining lease has not been
    obtained, may be provided to this Ministry at the
    earliest, and in any case before the expiry of a
    period of one year from the date of issue of the said
    letter dated 1st April 2015.

    2. I am further directed to say that till decision on the
    said matter is taken by this Ministry after the receipt
    of the afore-mentioned information from all the

    been kept in abeyance, and all mining activities in such mining lease shall
    be stopped, till such time, the NPV of such forest land is realised by the
    State Government;

    (c) The general approval shall be valid for a period co-terminus with the
    period of mining lease in accordance with the provisions of the Mines and
    Minerals (Development and Regulation) Act, 1957
    , as amended, and the
    Rules framed thereunder;

    (d) This general approval does not, in any manager, exempt a user agency
    from obtaining prior approval under Section 2(ii) of the FC Act in regard to
    such area of forest land which is to be used for non-forest purpose;

    (e) Grant of this general approval under Section 2(iii) does not, in any
    manner, create any right or equity in favour of the user agency for grant of
    approval under Section 2(ii) of the FC Act and decision on proposals under
    Section 2(ii) will be taken purely on the merit of each case;

    (f) This general approval will not be applicable to the forest land for which
    Central Government before the issue of this letter has already declined
    approval under Section 2 of the FC Act; and

    (g) Grant of this general approval does not in any manner, exonerate the
    concerned Authorities in the State Government or in any other Authority,
    from the proceedings under Sections 3A and 3B of the FC Act, liable to be
    initiated for violation, if any, of the FC Act committed by them by
    assigning such, forest land on mining lease without obtaining prior
    approval of Central Government under Section 2 of tlie FC Act.”

    W.P.(C) No.743 of 2017 Page 10 of 85

    States and Union territories, the States and Union
    territories if so desires, may seek general
    approval under Section 2(iii) of the Forest
    (Conservation) Act, 1980 for the forest land
    falling in such mining leases, on case to case
    basis, by giving details (viz. date of execution of
    mining lease deed and area of forest and non-forest
    land falling in such mining leases) of one or more of
    such mining leases to this Ministry in letter form.”

    On 09.01.2017 the said Ministry granted general
    approval under Section 2(iii) of the Forest Conservation
    Act, 1980, just two days prior to the last date fixed for
    execution of mining lease deed in terms of Section
    10A(2)(c)
    of the MMDR Act read with Rule 8(4) of the MC
    Rules, 2016.

    2.5. Pursuant thereto, the Divisional Forest Officer raised a
    demand to the tune of Rs.4,22,82,331/- as Net Present
    Value over the forest land admeasuring 45.029 hectares,
    which stood deposited vide NEFT/RTGS Challan dated
    10.01.2017 (Annexure-13) in favour of Odisha State
    Compensatory Afforestation Fund Management and
    Planning Authority (“CAMPA, Odisha”, for short). The
    petitioner made a fervent request for issue of lease
    execution of order in its favour vide Letter dated
    10.01.2017 (Annexure-14) addressed to Principal
    Secretary to the Government of Odisha, Department of
    Steel and Mines by enclosing evidence showing
    compliance of terms and conditions. Besides such step,
    W.P.(C) No.743 of 2017 Page 11 of 85
    another Letter was submitted in the Office of the
    Divisional Forest Officer, Keonjhar Division, on
    11.01.2017 demonstrating compliance of conditions
    including Clearance by the Ministry of Environment,
    Forest and Climate Change.

    2.6. Though the petitioner has taken all possible steps, due
    to delay in the process on the part of the opposite parties
    and the circumstances not within the control of the
    petitioner, the mining lease deed was not executed in its
    favour on or before 17.11.2017 as specified under Rule
    8(4) of the MC Rules, 2016 read with Section 10A(2)(c) of
    the MMDR Act, while the State Government in similarly
    situated companies/entities executed such lease deed on
    or about said cut-off date.

    At the stage of fresh admission:

    3. This Court at the stage of entertainment of the writ
    petition passed the following Order on 16.01.2017:

    “Connect with W.P.(C) Nos.2814 and 283 of 20175.

    4 Visiting webportal it is found that on 07.03.2017 the following order was passed
    in W.P.(C) No.281 of 2017 [Rudra Sen Sindhu Vrs. Union of India and Others]:

    “07.03.2017
    Learned counsel for the petitioner states that the petitioner does not wish to press
    this writ petition. Misc. Case No. 3381 of 2017 has also been filed with a prayer
    to permit the petitioner to withdraw the writ petition as the lease deed has
    already been executed between the State and the petitioner.
    Prayer is allowed.

    The writ petition is accordingly disposed of as withdrawn.”

    5 Visiting webportal it could be ascertained that W.P.(C) No.283 of 2017
    (Parmeswari Devi Vrs. State of Odisha and Others) is pending as on date.

    W.P.(C) No.743 of 2017 Page 12 of 85

    The submission of Mr. Ashok Parija, learned Senior
    Counsel for the petitioners is that the petitioners had
    applied for grant of mining lease, which was duly
    approved by the Central Government under Section
    5(1)
    of the Mines and Minerals (Development and
    Regulation) Act, 1957 on 29.09.2008. The
    application however kept pending and in the
    meantime, the Act was amended and certain
    provisions have been inserted by Act 10 of 2015
    with effect from 12.01.2015. Under the new
    provision of Section 10A, lease deed is to be granted
    within a period of two years from the date of the
    amendment of the Act i.e. with effect from
    12.01.2015. Besides, several prayers which have
    been made, the grievance of the petitioners at this
    stage is with regard to the provision of Rule 8(4) of
    Mineral (Other Than Atomic and Hydro Carbons
    Energy Minerals) Concession Rules, 2016, which
    provides that in case the mining lease is not
    executed on or before 11.01.2017, the rights of the
    applicant shall be forfeited.

    2. The submission of the learned counsel for the
    petitioners is that because of the lapses on the part
    of the opposite parties, the mining lease has not
    been granted for which the petitioners cannot be
    made to suffer. The petitioners further contends
    that the provision of sub-rule (4) of Rule 8 is
    contrary to the provisions of Section 10A(2)(c)
    of MMDR Act, 1957 and as such, the same
    cannot be sustained in the eye of law.

    3. In our view, the matter requires consideration.

    4. Mr. A.K. Bose, learned Assistant Solicitor General
    accepts notice on behalf of opposite parties No. 1
    W.P.(C) No.743 of 2017 Page 13 of 85
    and 2 and Mr. B.P. Pradhan, learned Additional
    Government Advocate accepts notice on behalf of
    opposite party No.3. They pray for and are granted
    four weeks time to file counter affidavit and the
    petitioners shall have two weeks thereafter to file
    rejoinder affidavit.

    5. List this matter immediately after six weeks.

    6. Considering the facts and circumstances of the case
    and keeping in view the submissions made by the
    learned counsel for the parties, as an interim
    measure, it is directed that the provisions of
    Rule 8(4) of Mineral (Other Than Atomic and
    Hydro Carbons Energy Minerals) Concession
    Rules, 2016, shall not be made applicable in
    the case of the petitioners till the next date of
    listing.”

    Response of the opposite party No.3:

    4. A counter affidavit being sworn to by the Deputy
    Secretary to the Government of Odisha in Steel and
    Mines Department has come to be filed on 01.09.2017
    inter alia with the following replies:

    (i) Having admitted that the petitioner being accorded
    with prior approval by the Central Government
    under Section 5 of the MMDR Act, a Letter of Intent
    with certain terms and conditions to govern grant
    of lease in favour of the petitioner was issued by
    the State Government and that the mining plan
    was approved by the Indian Bureau of Mines. Yet

    W.P.(C) No.743 of 2017 Page 14 of 85
    when certain terms and conditions which formed
    part of Letter No.8556/SM, dated 23.12.2008
    remained unfulfilled even after six years, the
    petitioner was issued with notice vide Letter
    No.III(A)SM-46/2002/2994/SM, dated 09.04.2015
    calling upon it to explain as to why such terms and
    conditions would not be revoked and the
    application for mining lease dated 20.06.2002
    would not be rejected.

    (ii) Since the petitioner submitted compliance of terms
    indicated in Letter of Intent on 10.01.2017 (late
    afternoon) in view of Rule 8(1) of the MC Rules for
    consideration of grant of mining lease under Rule
    8(2) of the said Rules, such partial compliance
    could not be processed due to paucity of time. The
    petitioner could/did not furnish full compliance of
    terms and conditions on or before 11.01.2017, as a
    result of which grant order of mining lease was not
    considered.

    (iii) Due to non-compliance of the terms and conditions
    mentioned in the Letter of Intent within the period
    specified in Rule 8(4) of the MC Rules read with
    Section 10A(2)(c) of the MMDR Act, the right of the
    petitioner for grant of mining lease got forfeited
    with effect from 12.01.2017.

    W.P.(C) No.743 of 2017 Page 15 of 85

    (iv) In order to eliminate discretion and improve
    transparency in the allocation of mineral resources
    as evident from the Statement of Objects and
    Reasons for bringing into force auction regime
    necessary amendments were made in the MMDR
    Act
    inter alia introducing Section 10A in said Act in
    the year 2015 and framing relevant Rules in the
    year 2016. The twin conditions stipulated in
    Section 10A(2)(c) of the MMDR Act being not
    satisfied, the petitioner became ineligible for grant
    of mining lease in terms of Section 10A(1) thereof.

    (v) The petitioner having got approval under Section
    2(iii)
    of the Forest (Conservation) Act, 1980 on
    09.01.2017 submitted the full compliance letter on
    10.01.2017 in the late afternoon, just the day
    before 11.01.2017, i.e., the last date for grant and
    execution of the lease saved under Section 10(2)(c)
    of the MMDR Act, due to paucity of time the lease
    deed could not be executed and registered.

    Response of the opposite party No.2:

    5. Citing Section 2 of the Forest (Conservation) Act, 1980
    as amended by virtue of the Forest (Conservation)
    Amendment Act, 1988
    , a counter affidavit has been filed
    by the opposite party No.2 by stating that:

    W.P.(C) No.743 of 2017 Page 16 of 85

    “That with regard to the approval under Section 2(iii) of
    the Forest (Conservation) Act, it is submitted that the
    proposal received from the State Government has been
    granted approval by the Ministry of Environment, Forest
    and Climate Change, New Delhi vide its Letter No.8-73/
    2016-FC, dated 09.01.2017.”

    Rejoinder affidavit of the petitioner:

    6. Strongly opposing the blame put upon it by the opposite
    parties in delaying the process to obtain necessary
    clearances to comply with the terms and conditions
    envisaged in the Letter of Intent dated 23.12.2008, the
    petitioner submitted that one of the conditions contained
    in Letter dated 29.02.2008 granting prior approval under
    Section 5(1) of the MMDR Act was that the applicant was
    required to obtain statutory clearance under the
    provisions of the Forest (Conservation) Act, 1980 and
    Environmental Notification dated 27.01.1994. It is
    explained that the petitioner submitted a Forest
    Diversion Proposal under Section 2(ii) of the Forest
    (Conservation) Act for an area of 41.011 hectares. The
    process of such grant took considerable length of period
    at the behest of the Ministry of Environment, Forest and
    Climate Change. It is only on 09.01.2017 the petitioner
    was issued with clearance in terms of Section 2(iii) of
    said Act. The delay cannot be attributed to the
    petitioner.

    Hearing:

    W.P.(C) No.743 of 2017 Page 17 of 85

    7. As the pleadings are complete and this Court as an
    interim measure vide Order dated 16.01.2017 directed
    not to make provisions of Rule 8(4) of the MC Rules,
    2016 applicable qua the petitioner(s), respective counsel
    representing the parties agreed for final hearing of the
    matter.

    7.1. Though on 01.12.2025 the matter was heard, written
    note of submissions were sought to be filed on
    15.12.2025. Having allowed, such notes so filed were
    directed to be taken on record. For clarification of certain
    aspects, the case was instructed to be posted on
    07.05.2026, on which date final hearing was conducted
    by the counsel for the parties.

    7.2. Sri Pinaki Misra, learned Senior Advocate assisted by Sri
    Abhisek Agarwal, learned Advocate representing the
    petitioner and Sri Saswat Das, learned Additional
    Standing Counsel were heard in the matter.

    7.3. Upon conclusion of hearing, the matter stood reserved
    for preparation and pronouncement of judgment/order.

    Consideration of arguments advanced and submissions
    made by the counsel for respective parties:

    8. At the outset it needs to be stated that in the writ
    application the petitioner has raised many issues
    including validity and rationality in putting cut-off date,
    i.e., 11.01.2017 for execution of lease deed vide Rule 8(4)
    W.P.(C) No.743 of 2017 Page 18 of 85
    of the MC Rules, 2016, nonetheless, at the stage of
    arguments Sri Pinaki Misra, learned Senior Advocate
    confined his arguments to the extent of discriminatory
    treatment meted to the petitioner in not executing
    mining lease deed on 11.01.2017 despite fulfilment of all
    the statutory requirements.

    9. For convenience relevant statutory provisions which are
    necessary for the present purpose are reproduced
    hereunder:

    The Mines and Minerals (Development and
    Regulation) Act, 1957
    :

    “5. Restrictions on the grant of prospecting licences or
    mining leases.―

    (1) A State Government shall not grant a
    reconnaissance permit, prospecting licence or mining
    lease to any person unless such person―

    (a) is an Indian national, or company as defined in
    Clause (20) of Section 2 of the Companies Act,
    2013 (18 of 2013); and

    (b) satisfies such conditions as may be prescribed:

    Provided that in respect of any mineral specified in
    Part A and Part B of the First Schedule, no
    reconnaissance permit, prospecting licence or mining
    lease shall be granted except with the previous
    approval of the Central Government.

    Explanation.―

    W.P.(C) No.743 of 2017 Page 19 of 85
    For the purposes of this sub-section, a person shall
    be deemed to be an Indian national,―

    (a) in the case of a firm or other association of
    individuals, only if all the members of the firm
    or members of the association are citizens of
    India; and

    (b) in the case of an individual, only if he is a
    citizen of India.

    (2) No mining lease shall be granted by the State
    Government unless it is satisfied that―

    (a) there is evidence to show the existence of
    mineral contents in the area for which the
    application for a mining lease has been made
    in accordance with such parameters as may be
    prescribed for this purpose by the Central
    Government;

    (b) there is a mining plan duly approved by the
    Central Government, or by the State
    Government, in respect of such category of
    mines as may be specified by the Central
    Government, for the development of mineral
    deposits in the area concerned:

    Provided that a mining lease may be granted upon
    the filing of a mining plan in accordance with a
    system established by the State Government for
    preparation, certification, and monitoring of such
    plan, with the approval of the Central Government.

    10A.Rights of existing concession holders and
    applicants.―

    W.P.(C) No.743 of 2017 Page 20 of 85
    (1) All applications received prior to the date of
    commencement of the Mines and Minerals
    (Development and Regulation) Amendment Act,
    20156, shall become ineligible.

    (2) Without prejudice to sub-section (1), the following
    shall remain eligible on and from the date of
    commencement of the Mines and Minerals
    (Development and Regulation) Amendment Act,
    2015:

    a. applications received under section 11A of this
    Act;

    b. where before the commencement of the Mines
    and Minerals (Development and Regulation)
    Amendment Act, 2015 a reconnaissance permit
    or prospecting licence has been granted in
    respect of any land for any mineral, the permit
    holder or the licensee shall have a right for
    obtaining a prospecting licence followed by a
    mining lease, or a mining lease, as the case
    may be, in respect of that mineral in that land,
    if the State Government is satisfied that the
    permit holder or the licensee, as the case may
    be,―

    (i) has undertaken reconnaissance
    operations or prospecting operations, as
    the case may be, to establish the
    existence of mineral contents in such land
    in accordance with such parameters as
    may be prescribed by the Central
    Government;

    6 Inserted by Section 10 of the Mines and Minerals (Development and Regulation)
    Amendment Act, 2015 [Act 10 of 2015], with effect from 12.01.2015.

    W.P.(C) No.743 of 2017                                          Page 21 of 85
                      (ii)    has not committed any breach of the
                             terms    and     conditions    of    the
    

    reconnaissance permit or the prospecting
    licence;

    (iii) has not become ineligible under the
    provisions of this Act; and

    (iv) has not failed to apply for grant of
    prospecting licence or mining lease, as the
    case may be, within a period of three
    months after the expiry of reconnaissance
    permit or prospecting licence, as the case
    may be, or within such further period not
    exceeding six months as may be extended
    by the State Government;

               c.    where the Central Government has
                     communicated      previous    approval     as
    

    required under sub-section (1) of Section 5
    for grant of a mining lease, or if a letter of
    intent (by whatever name called) has been
    issued by the State Government to grant a
    mining lease, before the commencement of
    the Mines and Minerals (Development and
    Regulation) Amendment Act, 2015, the
    mining lease shall be granted subject to
    fulfilment of the conditions of the previous
    approval or of the letter of intent within a
    period of two years from the date of
    commencement of the said Act:

    Provided that in respect of any mineral
    specified in the First Schedule, no prospecting
    licence or mining lease shall be granted under

    W.P.(C) No.743 of 2017 Page 22 of 85
    clause (b) of this subsection except with the
    previous approval of the Central Government.”

    The Minerals (Other Than Atomic and Hydro
    Carbons Energy Minerals) Concession Rules, 2016:

    “8. Rights under the provisions of clause (c) of sub-

    section (2) of Section 10A.–

    (1) The applicant in whose favour:

    (a) the State Government has issued a letter of
    intent (by whatever name called) in writing
    before January 12, 2015, for grant of a mining
    lease for minerals not specified in the First
    Schedule to the Act
    ; or

    (b) the Central Government has communicated the
    previous approval in writing before January
    12, 2015, under sub-section (1) of Section 5, for
    grant of a mining lease for minerals specified in
    Part C of the First Schedule to the Act, shall
    submit a letter of compliance to the State
    Government, of the conditions mentioned in the
    letter of intent or the conditions mentioned in
    the previous approval granted by the Central
    Government, as the case may be; and the State
    Government shall send an acknowledgement of
    receipt of the letter of compliance to the
    applicant in Schedule II within a period of three
    days of receipt thereof.

    (2) After receipt of letter of compliance under sub-rule
    (1), the State Government shall issue an order for
    grant of the mining lease within a period of sixty
    days from the date of receipt of such letter subject to

    W.P.(C) No.743 of 2017 Page 23 of 85
    verification of fulfilment of the conditions mentioned
    in the letter of intent or previous approval of the
    Central Government, as the case may be:

    Provided that in case the conditions as mentioned in
    the

    (i) letter of intent issued by the State Government,
    or

    (ii) previous approval granted by the Central
    Government

    are not fulfilled, the State Government shall, after
    giving the applicant an opportunity of being heard
    and for reasons to be recorded in writing and
    communicated to the applicant within a period of
    sixty days from the date of receipt of letter of
    compliance, refuse to grant a mining lease for non-

    compliance of conditions mentioned in the letter of
    intent or the previous approval of the Central
    Government, as the case may be.

    (3) Upon issuance of an order of grant of mining lease
    under sub-rule (2), the applicant shall:

    (a) furnish a performance security to the State
    Government in the form of a bank guarantee in
    the format specified in Schedule IV or as a
    security deposit for an amount equivalent to
    0.50% of the value of estimated resources,
    which may be invoked by the State
    Government as per the terms and conditions of
    the Mine Development and Production
    Agreement, published by the Government of
    India in the Ministry of Mines, vide Part I,
    Section-I of the Gazette of India, dated the 2nd
    W.P.(C) No.743 of 2017 Page 24 of 85
    July, 2015, and the mining lease deed. The
    performance security shall be adjusted every
    five years to correspond to 0.50% of the
    reassessed value of estimated resources; and

    (b) sign a Mine Development and Production
    Agreement with the State Government in the
    format specified by the Central Government
    after compliance of conditions specified in this
    sub-rule.

    (4) Where an order for grant of mining lease has
    been issued under sub-rule (2), the mining lease
    shall be executed with the applicant in the
    format specified in Schedule VII and registered
    on or before 11th January, 2017, failing which
    the right of such an applicant under clause (c)
    of sub-section (2) of Section 10A for grant of a
    mining lease shall be forfeited and in such
    cases, it would not be mandatory for the State
    Government to issue any order in this regard.

    (5) The State Government may, for reasons to be
    recorded in writing and communicated to the
    applicant, reduce the area applied for at the time of
    grant of the mining lease.

    (6) The date of the commencement of the period for
    which a mining lease is granted shall be the date on
    which a duly executed mining lease deed is
    registered.”

    The Forest (Conservation) Act, 1980:

    “2. Restriction on the dereservation of forests or use of
    forest land for non-forest purpose.–

    W.P.(C) No.743 of 2017 Page 25 of 85

    Notwithstanding anything contained in any other
    law for the time being in force in a State, no State
    Government or other authority shall make, except
    with the prior approval of the Central Government,
    any order directing–

    (i) that any reserved forest (within the meaning of
    the expression “reserved forest” in any law for
    the time being in force in that State) or any
    portion thereof, shall cease to be reserved:

    (ii) that any forest land or any portion thereof may
    be used for any non-forest purpose.

    7[(iii) that any forest land or any portion thereof may
    be assigned by way of lease or otherwise to
    any private person or to any authority,
    corporation, agency or any other organisation
    not owned, managed or controlled by
    Government;

    (iv) that any forest land or any portion thereof may
    cleared of trees which have grown naturally in
    that land portion, for the purpose of using it for
    reafforestation.]
    8[Explanation.–

    For the purpose of this section “non-forest purpose”

    means the breaking up or clearing of any forest land
    or portion thereof for:

    7 Inserted by the Forest (Conservation) Amendment Act, 1988 [Act 69 of 1988]
    came into force with effect from 15.03.1989, being notified in the Gazette of
    India, Extraordinary, 1989 [Notification No.SO188 (E), 15.03.1989].
    8 Substituted ibid.

    W.P.(C) No.743 of 2017 Page 26 of 85

    (a) the cultivation of tea, coffee, spices, rubber,
    palms, oil-bearing plants, horticultural crops or
    medicinal plants;

    (b) any purpose other than reafforestation,

    but does not include any work relating or ancillary to
    conservation, development and management of
    forests and wild life, namely, the establishment of
    check-posts, fire lines, wireless communications and
    construction of fencing, bridges and culverts, dams,
    waterholes, trench marks, boundary marks,
    pipelines or other like purposes.]

    3. Constitution of Advisory Committee.–

    The Central Government may constitute a Committee
    consisting of such number of persons as it may
    deem fit to advise that Government with regard to–

    (i) the grant of approval under Section 2; and

    (ii) any other matter connected with the
    conservation of forests which may be referred
    to it by the Central Government.”

    10. Referring to Section 10A(2)(c) of the MMDR Act, Sri
    Saswat Das, learned Additional Government Advocate
    submitted that two categories of applicants9 who could
    be considered for grant of mining lease without auction,
    subject to specific conditions, namely:

    i. those who received a Letter of Intent for grant of the
    mining lease from the State Government; or

    9 Paragraph 2 of written note of submissions filed on behalf of the opposite party
    No.3.

    W.P.(C) No.743 of 2017 Page 27 of 85

    ii. those who had received prior approval from the
    Central Government for the grant of mining lease.

    10.1. These two categories of applicants are required to fulfil
    all the conditions specified in the Letter of Intent or must
    be in possession of prior approval of the Central
    Government under Section 5 of the MMDR Act within
    two years from 12.01.2015. Exercising power conferred
    under Section 13 of the MMDR Act, the MC Rules, 2016
    have been framed. It is submitted that the mining lease
    applications pending at the time of commencement of
    said Amendment Act, i.e., 12.01.2015, lease could be
    granted subject to fulfilment of conditions stipulated
    therein.

    10.2. Referring to following paragraphs from Bhushan Power
    and Steel Limited Vrs. S.L. Seal, Additional Secretary,
    (Steel and Mines), State of Odisha and Others, (2017) 2
    SCC 125, it was submitted that having not fulfilled
    conditions the petitioner has rightly been refused grant
    of the mining lease:

    “12. It was argued with vehemence that even when
    under sub-section (1) of Section 10-A, all applications
    received prior to the date of commencement of the
    Amendment Act, 2015 have been rendered ineligible,
    sub-section (2) saves certain kinds of applications.
    Clause (c) thereof is invoked by the petitioner to
    submit that in the instant case since “letter of
    intent” had been issued by the State

    W.P.(C) No.743 of 2017 Page 28 of 85
    Government to grant a mining lease, the
    petitioner‟s application stands protected. For
    this purpose, recommendation dated 24.05.2014 is
    treated as letter of intent by the petitioner, laying
    emphasis on the words “letter of intent (by whatever
    name called)”. It was, thus, argued that form of
    letter of intent is not necessary and the substance of
    the letter had to be seen. It was argued that since
    the Letter dated 24.05.2014 of the State Government
    is in the nature of recommendation for grant of lease,
    it signifies intention to grant the mining lease insofar
    as the State Government is concerned and,
    therefore, in substance, it is the letter of intent. It
    was, thus, argued that under the new regime
    contained in Section 10-A, approval of the Central
    Government was not even required and the State
    Government could have proceeded further and
    granted the lease.

    16. Since the State Government had sent the necessary
    letter of request to the Central Government, direction
    contained in the judgment dated 14.03.2012
    [Bhushan Power & Steel Ltd. Vrs. State of Orissa,
    (2012) 4 SCC 246] stands complied with. The issue
    now raised, as reflected and discussed in the earlier
    portion of this judgment, is whether the application
    of the petitioner is rendered ineligible in view of
    Section 10-A of the Act or whether it still survives.

    We are examining this issue as the petitioner’s
    counsel have argued that the petitioner is eligible to
    be considered as its application falls in the category
    carved out by clause (c) of Section 10-A(2) and
    further that since no approval of the Central
    Government is required now, the State Government
    could itself grant the lease. It is argued that failure

    W.P.(C) No.743 of 2017 Page 29 of 85
    of the State Government amounts to contempt of the
    orders of this Court.

    17. Undoubtedly, as per sub-section (1) of Section 10-A,
    all applications received prior to coming into force of
    the Amendment Act, 2015, become ineligible. Reason
    for interpreting such a provision is not far to seek.
    Before the passing of the Amendment Act, 2015, it
    was the Central Government which had the ultimate
    control over the grant of licences insofar as mining of
    major minerals is concerned. As per the procedure
    then existing, the State Government could
    recommend the application submitted by any
    applicant for grant of mining lease to the
    Central Government and the Central
    Government was given the power to grant or
    refuse to grant the approval. Thus, “previous
    approval” from the Central Government was
    essential for grant of lease, without which the
    State Government could not enter into any such
    lease agreement with the applicant.

    Shortcomings of this procedure were noticed by this
    Court in its judgment rendered in Centre for Public
    Interest Litigation Vrs. Union of India, (2012) 3 SCC
    1 (for short “CPIL case”) and also in Natural
    Resources Allocation, In re, Special Reference No. 1
    of 2012, (2012) 10 SCC 1. In these judgments, this
    Court expressed that allocation of natural resources
    should normally be by auction. Judgment in Centre
    for Public Interest Litigation Vrs. Union of India,
    (2012) 3 SCC 1 had a direct relevance to the grant of
    mineral concessions as the Government found that it
    was resulting in multipurpose litigation which was
    becoming counterproductive. Mining Ordinance,
    2015 was passed on 12.01.2015 which was

    W.P.(C) No.743 of 2017 Page 30 of 85
    ultimately replaced when Parliament enacted the
    Amendment Act, 2015.

    18. The exhaustive Statement of Objects and Reasons
    reveals that the extensive amendment in the Act
    were effected after extensive consultations and
    intensive scrutiny by the Standing Committee on
    Coal and Steel, who gave their Report in May 2013.
    As is evident from the Statement that difficulties
    were experienced because the existing Act does not
    permit the auctioning of mineral concessions. It was
    observed that with auctioning of mineral
    concessions, transparency in allocation will improve;
    the Government will get an increased share of the
    value of mineral resources; and that it will alleviate
    the procedural delay, which in turn would check
    slowdown which adversely affected the growth of
    mining sector.

    19. The Amendment Act, 2015, as is evident from the
    objects, aims at: (i) eliminating discretion; (ii)
    improving transparency in the allocation of mineral
    resources; (iii) simplifying procedures; (iv) eliminating
    delay on administration, so as to enable expeditious
    and optimum development of the mineral resources
    of the country; (v) obtaining for the Government an
    enhanced share of the value of the mineral
    resources; and (vi) attracting private investment and
    the latest technology.

    20. The Amendment Act, 2015 ushered in the
    amendment of Sections 3, 4, 4-A, 5, 6, 13, 15, 21
    and First Schedule; substitution of new sections for
    Sections 8, 11 and 13; and, insertion of new
    Sections 8-A, 9-B, 9-C, 10-A, 10-C, 11-B, 11-C, 12-A,
    15-A, 17-A, 20-A, 30-B, 30-C and Fourth Schedule.

    W.P.(C) No.743 of 2017 Page 31 of 85

    21. These amendments brought in vogue : (i) auction to
    be the sole method of allotment; (ii) extension of
    tenure of existing lease from the date of their last
    renewal to 31.03.2030 (in the case of captive mines)
    and till 31.03.2020 (for the merchant miners) or till
    the completion of renewal already granted, if any, or
    a period of 50 years from the date of grant of such
    lease; (iii) establishment of District Mineral
    Foundation for safeguarding interest of persons
    affected by mining related activities; (iv) setting up of
    a National Mineral Exploration Trust created out of
    contributions from the mining lease-holders, in order
    to have a dedicated fund for encouraging exploration
    and investment; (v) removal of the provisions
    requiring “previous approval” from the Central
    Government for grant of mineral concessions in case
    of important minerals like iron ore, bauxite,
    manganese, etc. thereby making the process simpler
    and quicker; (vi) introduction of stringent penal
    provisions to check illegal mining prescribing higher
    penalties up to Rs 5 lakhs per hectare and
    imprisonment up to 5 years; and (vii) further
    empowering the State Government to set up Special
    Courts for trial of offences under the Act.

    22. Newly inserted provisions of the Amendment Act,
    2015 are to be examined and interpreted keeping in
    view the aforesaid method of allocation of mineral
    resources through auctioning, that has been
    introduced by the Amendment Act, 2015. Amended
    Section 11 now makes it clear that the mining leases
    are to be granted by auction. It is for this reason
    that sub-section (1) of Section 10-A mandates
    that all applications received prior to 12-1-
    2015 shall become ineligible. Notwithstanding,

    W.P.(C) No.743 of 2017 Page 32 of 85
    sub-section (2) thereof carves out exceptions by
    saving certain categories of applications even filed
    before the Amendment Act, 2015 came into
    operation. Three kinds of applications are
    saved:

    22.1. First, applications received under Section 11-A of the
    Act. Section 11-A, under new avatar is an exception
    to Section 11 which mandates grant of prospecting
    licence combining lease through auction in respect of
    minerals, other than notified minerals. Section 11-A
    empowers the Central Government to select certain
    kinds of companies mentioned in the said section,
    through auction by competitive bidding on such
    terms and conditions, as may be prescribed, for the
    purpose of granting reconnaissance permit,
    prospecting licence or mining lease in respect of any
    area containing coal or lignite. Unamended provision
    was also of similar nature except that the companies
    which can be selected now for this purpose under
    the new provision are different from the companies
    which were mentioned in the old provision. It is for
    this reason, if applications were received even under
    unamended Section 11-A, they are saved and
    protected, which means that these applications can
    be processed under Section 11-A of the Act.

    22.2. Second category of applications, which are kept
    eligible under the new provision, are those where the
    reconnaissance, permit or prospecting licence had
    been granted and the permit-holder or the licensee,
    as the case may be, had undertaken reconnaissance
    operations or prospecting operations. The reason for
    protecting this class of applicants, it appears, is that
    such applicants, with hope to get the licence, had

    W.P.(C) No.743 of 2017 Page 33 of 85
    altered their position by spending lot of money on
    reconnaissance operations or prospecting
    operations. This category, therefore, respects the
    principle of legitimate expectation.

    22.3. Third category is that category of applicants
    where the Central Government had already
    communicated previous approval under Section
    5(1)
    of the Act for grant of mining lease or the
    State Government had issued letter of intent to
    grant a mining lease before coming into force
    of the Amendment Act, 2015. Here again, the
    raison dêtre is that certain right had accrued
    to these applicants inasmuch as all the
    necessary procedures and formalities were
    complied with under the unamended provisions
    and only formal lease deed remained to be
    executed.

    22.4. It would, thus, be seen that in all the three cases,
    some kind of right, in law, came to be vested in
    these categories of cases which led Parliament to
    make such a provision saving those rights, and
    understandably so.

    23. Here, the petitioner seeks to cover its case under the
    third category with the plea that insofar as the State
    Government is concerned, it had issued “letter of
    intent”. The petitioner is treating Letter dated
    24.05.2014, which was sent by the State
    Government to the Central Government with a
    request to the Central Government to give its
    approval for grant of mineral concessions, as
    the “letter of intent”. It is in this hue, the
    submission is that the intention behind the said
    letter is to be seen even if it is not termed as “letter
    W.P.(C) No.743 of 2017 Page 34 of 85
    of intent” and this argument is predicated on the
    words “by whatever name called”.

    24. No doubt, having regard to the words “by whatever
    name called”, the expression “letter of intent” is to be
    given wider connotation. It means that nomenclature
    of the letter would not be the determinative factor. It
    is the substantive nature of the letter in question
    that would determine as to whether it can be treated
    as the letter of intent. For this purpose, it is first
    necessary to find the meaning that has to be
    attributed to the term “letter of intent”. As per the
    legal dictionary, “letter of intent” is a document that
    described the preliminary understanding between
    the parties who intend to make a contract or join
    together in another action. This term has come up for
    interpretation on few occasions before this Court.

    25. In Rishi Kiran Logistics (P) Ltd. Vrs. Kandla Port
    Trust, (2015) 13 SCC 233, relying upon an earlier
    decision, this Court held that a letter of intent merely
    indicates a party‟s intention to enter into a contract
    with other party in future, as can be seen from the
    following para 43 thereof, which reads as under:

    „43. At this juncture, while keeping the aforesaid
    pertinent features of the case in mind, we
    would take note of “the Rules and Procedure
    for Allotment of Plots” in question issued by
    Kandla Port Trust. As per Clause 12 thereof the
    Port Trust had reserved with itself right of
    acceptance or rejection of any bid with specific
    stipulation that mere payment of EMD and
    offering of premium will not confer any right or
    interest in favour of the bidder for allotment of
    land. Such a right to reject the bid could be
    W.P.(C) No.743 of 2017 Page 35 of 85
    exercised “at any time without assigning any
    reasons thereto”. Clause 13 relates to
    “approvals from statutory authorities”, with
    unequivocal assertion therein that the allottees
    will have to obtain all approvals from different
    authorities and these included approvals from
    CRZ as well. As per Clause 16, the allotment
    was to be made subject to the approval of
    Kandla Port Trust Board/competent authority.
    In view of this material on record and factual
    position noted in earlier paragraphs we are of
    the opinion that observations in Dresser Rand
    S.A. Vrs. Bindal Agro Chem Ltd., (2006) 1 SCC
    751 would be squarely available in the present
    case, wherein the Court held that:

    „39. … a letter of intent merely indicates a
    party‟s intention to enter into a contract
    with the other party in future. A letter of
    intent is not intended to bind either party
    ultimately to enter into any contract. …

    40. It is no doubt true that a letter of intent
    may be construed as a letter of
    acceptance if such intention is evident
    from its terms. It is not uncommon in
    contracts involving detailed procedure, in
    order to save time, to issue a letter of
    intent communicating the acceptance of
    the offer and asking the contractor to start
    the work with a stipulation that the
    detailed contract would be drawn up
    later. If such a letter is issued to the
    contractor, though it may be termed as a
    letter of intent, it may amount to

    W.P.(C) No.743 of 2017 Page 36 of 85
    acceptance of the offer resulting in a
    concluded contract between the parties.

    But the question whether the letter of
    intent is merely an expression of an
    intention to place an order in future or
    whether it is a final acceptance of the
    offer thereby leading to a contract, is a
    matter that has to be decided with
    reference to the terms of the letter.‟

    When the LoI is itself hedged with the
    condition that the final allotment would
    be made later after obtaining CRZ and
    other clearances, it may depict an
    intention to enter into contract at a later
    stage. Thus, we find that on the facts of this
    case it appears that a letter with intention to
    enter into a contract which could take place
    after all other formalities are completed.
    However, when the completion of these
    formalities had taken undue long time and the
    prices of land, in the interregnum, shot up
    sharply, the respondent had a right to cancel
    the process which had not resulted in a
    concluded contract.‟

    [See also Rajasthan Coop. Dairy Federation Ltd. Vrs.
    Maha Laxmi Mingrate Mktg. Service (P) Ltd., (1996)
    10 SCC 405]

    26. Applying the aforesaid meaning, can it be said
    that Letter dated 24.05.2014 of the State
    Government would constitute a letter of intent?
    We are afraid, answer has to be in the negative.
    Reason is simple. As mentioned above, in order to
    enable the State Government to enter into any lease
    W.P.(C) No.743 of 2017 Page 37 of 85
    agreement/contract with the prospecting licensee,
    “previous approval” of the Central Government was
    essential. Unless such approval came, the State
    Government could not communicate to the
    prospecting licensee/lessee its intention to enter into
    any contract as the prerequisite prior approval
    would be lacking. Therefore, no promise could be
    held by the State Government to any applicant
    showing its intention to enter into a contract in the
    future. Position would have been different had Letter
    dated 24.05.2014 been issued after receiving
    previous approval of the Central Government.
    However, that is not so. This letter to the Central
    Government was only recommendatory in nature
    and ultimate decision rested with the Central
    Government. It is a different thing if the Central
    Government refuses to give its approval on any
    extraneous reasons or mala fides or does not take
    into consideration relevant factors/material while
    rejecting the application, which may form a different
    cause of action and may become a reason to
    challenge the action of the Central Government
    rejecting the application on the grounds that are
    available in law to seek judicial review of such an
    action. However, we are not dealing with that
    situation in the instant case. Our discussion is
    confined to the plea raised before us viz. whether
    Letter dated 24.05.2014 can be termed as “letter of
    intent”. For the reasons stated above, we are of the
    view that it was not a letter of intent. The application
    of the petitioner, therefore, would not be covered by
    clause (c) of Section 10-A of the Act.

    27. We are conscious of the fact that the petitioner
    herein had originally succeeded in the appeal

    W.P.(C) No.743 of 2017 Page 38 of 85
    inasmuch as judgment dated 14.03.2012 was
    rendered giving direction to the State Government to
    recommend the case of the petitioner, in terms of the
    MoU entered into between the parties, to the Central
    Government. This was not done and the decision
    was reiterated in orders dated 22.04.2014 passed
    in Bhushan Power and Steel Ltd. Vrs. Rajesh Verma,
    (2014) 5 SCR 493. It is possible that had the State
    Government acted promptly and sent the
    recommendations earlier, the Central Government
    might have accorded its approval. However, whether
    it could have done so or not would be in the realm of
    conjectures. Insofar as the Central Government is
    concerned, no direction was ever given by this Court.
    On the contrary, it was categorically observed in the
    order dated 22.04.2014 in Bhushan Power and
    Steel Ltd. Vrs. Rajesh Verma that it would be for the
    Central Government to consider the
    recommendations of the State Government on its
    own merits and in accordance with law. If that has
    not been done by the Central Government, it cannot
    be the subject-matter of present contempt petition.”

    10.3. In the present set of facts, there is no dispute that upon
    consideration of the application of the petitioner, the
    State Government recommended the case for prior
    approval of the Central Government and the latter
    approved invoking Section 5(1) and Section 11(5) of the
    MMDR Act read with sub-rules (1) and (2) of Rule 59 of
    the Mineral Concession Rules, 1960. Of course, such
    approval was hedged with certain conditions which were
    required to be fulfilled.

    W.P.(C) No.743 of 2017 Page 39 of 85

    10.4. It may be significant to take note of following
    observations contained in State of West Bengal Vrs.
    Chiranjilal (Mineral) Industries of Bagandih and Others,
    (2023) 12 SCR 277:

    “8. The Respondent No.1-M/s. Chiranjilal (Mineral)
    Industries of Bagandih has relied upon judgment of
    this Court in Bhushan Power and Steel Limited Vrs.
    S.L. Seal, Additional Secretary (Steel and Mines),
    State of Odisha and Others, (2017) 2 SCC 125. In
    the said case, the predecessor-in-interest of the
    petitioner therein had made an application for grant
    of lease before the State of Odisha for mining of Iron
    Ore in an area measuring 1250 acres. The
    application was in view of the proposal to set up a
    steel plant in the district of Sambalpur, Odisha. The
    rejection for the grant of the mining lease to M/s.
    Bhushan Power and Steel Limited was challenged in
    a Writ Petition in the High Court, which was
    dismissed, but the appeal preferred before this Court
    was allowed vide judgment dated 14.03.2012 in
    Bhushan Power and Steel, Limited and Others Vrs.
    State of Orissa and Another, (2012) 4 SCC 246,
    setting aside the order of the State Government
    dated 09.02.2016, with the following directions:

    „41. In the light of the above, the High Court erred
    in holding that it could not interfere with the
    decision of the State Government calling upon
    the appellants to sign a fresh MoU with the
    Government, during subsistence of the earlier
    MoU. Since the State Government has already
    made allotments in favour of others in
    relaxation of the Mineral Concession Rules,

    W.P.(C) No.743 of 2017 Page 40 of 85
    1960, under Rule 59(2) thereof, no cogent
    ground had been made out on behalf of the
    State to deny the said privilege to the
    appellants as well. Accordingly, we allow the
    appeal and set aside the judgment and order
    of the High Court of Orissa and also the
    decision of the State Government dated
    09.02.2006, rejecting the appellants‟ claim for
    grant of mining lease.

    42. During the course of hearing, we have been
    informed that Thakurani Block A has large
    reserves of iron ore, in which the appellants
    can also be accommodated. We, accordingly,
    direct the State of Orissa to take appropriate
    steps to act in terms of the MoU dated
    15.05.2002, as also its earlier commitments to
    recommend the case of the appellants to the
    Central Government for grant of adequate iron
    ore reserves to meet the requirements of the
    appellants in their steel plant at Lapanga.‟

    9. The State of Odisha thereafter filed an application
    for review of the judgment in Bhushan Power and
    Steel Limited and Others Vrs. State of Orissa and
    Another, (2012) 4 SCC 246 which was rejected vide
    order dated 11.09.2012.

    10. Alleging non-compliance and in-action of the
    judgment dated 14.03.2012, a contempt petition
    was filed by M/s. Bhushan Power and Steel Limited.

    The contempt petition was contested by the State of
    Odisha on several grounds, including that the
    judgment dated 14.03.2012 is incapable of
    enforcement, for which reliance was placed on a
    subsequent judgment of this Court in Sandur
    W.P.(C) No.743 of 2017 Page 41 of 85
    Manganese and Iron Ores Ltd. Vrs. State of
    Karnataka, (2010) 13 SCC 1. This stand did not find
    favour with this Court and the officers of the State
    Government were found to be in contempt of the
    judgment dated 14.03.2012 vide judgment dated
    22.04.2014 in Bhushan Power and Steel Limited
    Vrs. Rajesh Verma, (2014) 5 SCC 551. Under these
    circumstances, the judgment dated 22.04.2014 had
    given one more opportunity to the State Government
    to send requisite recommendation to the Central
    Government inter alia observing that this Court
    cannot lose sight of the fact that there is a judgment
    inter se the parties, which has become final.
    Accordingly, the contention that the judgment of this
    Court in Sandur Manganese and Iron Ores Limited
    (supra) will not undo the directions given in the
    judgment dated 14.03.2012 was rejected. The
    relevant observations in the judgment dated
    22.04.2014 read as under:

    „21. We cannot lose sight of the fact that there is a
    judgment, inter partes, which has become final.
    Even when the civil appeal was being heard,
    certain other parties claiming their interest in
    these very lands had moved intervention
    applications which were dismissed. At that
    time also it was mentioned that there are 195
    applicants. However, notwithstanding the
    same, this Court issued firm directions to the
    State Government to recommend the case of the
    petitioners for mining lease in both the areas.
    In view of such categorical and unambiguous
    directions given in the judgment which has
    attained finality, merely because another
    judgment has been delivered by this Court in

    W.P.(C) No.743 of 2017 Page 42 of 85
    Sandur Manganese case, cannot be a ground
    to undo the directions contained in the
    judgment dated 14.03.2012. Insofar as law
    laid down in Sandur Manganese is concerned,
    that may be applied and followed by the State
    Government in respect of other applications
    which are still pending. However, that cannot
    be pressed into service qua the petitioner
    whose rights have been crystallised by the
    judgment rendered in its favour. It cannot be
    reopened, that too at the stage of
    implementation of the said judgment.

    22. … Once we hold that the respondents are
    bound to implement the direction contained in
    the judgment dated 14.03.2012, insofar as the
    State Government is concerned, it is obliged to
    comply therewith and such matters, along with
    other relevant considerations, can be left to the
    wisdom of the Central Government while
    taking a decision on the recommendation of the
    State Government.

    ***

    24. … However, we are giving one final opportunity
    to them to purge the contempt by transmitting
    requisite recommendations to the Central
    Government. It would be for the Central
    Government to consider the said
    recommendations on its own merits and in
    accordance with law. In case the
    recommendation is sent within one month from
    the date of copy of receipt of this order, we
    propose not to take any further action and the
    respondents/contemnors shall stand
    W.P.(C) No.743 of 2017 Page 43 of 85
    discharged from this contempt petition.
    However, in case the respondents do not purge
    in the manner mentioned above, it would be
    open to the petitioners to point out the same to
    this Court by moving appropriate application
    and in that event the contemnors shall be
    proceeded against.‟

    11. Consequent to the directions dated 22.04.2014, the
    State Government had sent the requisite
    recommendation to the Central Government for grant
    of mining lease of the area in question. The Central
    Government, however, took the stand that having
    regard to the amendments in the MMDR Act, 1957,
    vide the Amendment Act, 2015 introducing Section
    10-A, the request made by M/s Bhushan Power and
    Steel Limited stands invalidated. In view of the
    aforesaid stand, the Central Government had
    written letters to the State Government, with a copy
    sent to M/s Bhushan Power and Steel Limited. In
    the letter dated 13.05.2015, the Central Government
    had stated that the proposal for according the prior
    approval for grant of mineral concession was
    ineligible in terms of sub-section (1) to Section 10-A
    of the MMDR Act, 1957 and, therefore, should be
    treated as closed. However, the State Government
    might ascertain whether the proposal was safe from
    ineligibility under Section 10-A of the MMDR Act,
    1957 and thereupon the State Government could
    take action accordingly. Similar view was also
    expressed by the Central Government in the letter
    dated 29.05.2015 therein. Consequent to these
    communications, the State Government vide letter
    dated 09.07.2015 had informed M/s Bhushan
    Power and Steel Limited that their applications for

    W.P.(C) No.743 of 2017 Page 44 of 85
    grant of mining lease had become ineligible as per
    sub-section (1) to Section 10-A of the MMDR Act,
    1957.

    12. This Court in M/s Bhushan Steel and Power
    Limited, (2012) 4 SCC 246 specifically
    examined the contention whether in the facts
    of the said case, clause (c) to sub-section (2) to
    Section 10-A of the MMDR Act, 1957 could be
    invoked in view of the contention raised by M/s
    Bhushan Steel and Power Limited that the
    Letter of Intent was issued by the State
    Government for grant of mining lease and,
    therefore, their application stands protected.
    The submission was that the recommendation
    dated 24.05.2014, given by the State
    Government should be treated as a Letter of
    Intent by “whatever name called”, as it
    signifies the intention to grant mining lease
    insofar as the State Government is concerned.
    It was also argued that under the new regime
    contained under Section 10-A of the MMDR Act,
    1957, approval of the Central Government was not
    even required and the State Government could have
    proceeded further and granted the lease.

    13. The aforesaid arguments did not find favour of
    this Court in the case of M/s Bhushan Steel and
    Power Limited (supra) in spite of the earlier
    judgment of this Court dated 14.03.2012 and
    the order passed in the contempt petition
    dated 22.04.2014 with the observations
    therein that there was failure of the State
    Government to comply with the directions. This

    W.P.(C) No.743 of 2017 Page 45 of 85
    Court rejected the submissions in M/s Bhushan
    Steel and Power Limited (supra) and held as under:

    ***

    14. Thus, the object and purpose of the Amendment Act,
    2015 is to ensure that allocation of mineral
    resources is done through auctioning. This is the
    reason why sub-section (1) to Section 10-A of the
    MMDR Act, 1957 mandates that all applications
    received prior to 12.01.2015 shall become ineligible.
    The exceptions or the saving clause applies to three
    kinds of situations specified in sub-section (2) to
    Section 10-A of the MMDR Act. 1957. The first
    category is where an application has been received
    under Section 11-A of the MMDR Act, 1957. The
    second category is where a reconnaissance permit or
    a prospecting licence has been granted the permit
    holder or the licensee has the right to obtain a
    prospecting licence followed by a mining lease and
    the State Government is satisfied that the permit
    holder or the licensee has complied with the
    requirements specified in sub-clauses (i) to (iv) of
    clause (b) of sub-section (2) to Section 10-A of the
    MMDR Act, 1957. The reason for protecting this class
    of cases is on account of the fact that they had
    altered their position by spending money on
    reconnaissance operations or prospecting
    operations. Accordingly, the principle of legitimate
    expectation is applied. The third category is where
    the Central Government had already communicated
    their previous approval or the State Government had
    issue Letter of Intent for grant of mining lease before
    coming into force of the Amendment Act 2015. The
    raison dêtre, it is observed therein, is that certain

    W.P.(C) No.743 of 2017 Page 46 of 85
    rights had accrued to these applicants inasmuch as
    all necessary procedures and formalities had been
    complied with and only formal lease remains to be
    executed.

    15. Delving on the question of whether the letter for
    approval dated 22.05.2014 granted by the State
    Government can be treated as a Letter of Intent
    predicated on the words by whatever name, which
    expression, it was submitted, should be given a
    broad interpretation in view of the words „by
    whatever name called‟ was examined in-depth and
    in detail. Reference was made to the legal
    dictionary for the meaning of the term „Letter
    of Intent‟ as a preliminary understanding
    between the parties who intend to make a
    contract or join together for further action.
    Reference was also made to decisions of this Court
    in Rishi Kiran Logistics Private Limited Vrs. Board of
    Trustees of Kandla Port Trust and Others, (2015) 13
    SCC 233 and Rajasthan Cooperative Dairy
    Federation Limited Vrs. Maha Laxmi Mingrate
    Marketing Service Private Limited and Others, (1996)
    10 SCC 405. ***

    16. The aforesaid judgment is relevant for our purpose,
    though in the present case, post Notification No. S.O.
    423(E) dated 10.02.2015, Dolomite was notified as a
    minor mineral and hence, the approval of the Central
    Government was not required for the reason that the
    Grant Order dated 16.07.2015 was hedged with
    pre-conditions, including the requirement to submit
    consent letters of the owners of the land in question
    (Raiyats) before the execution of the lease deed, or
    there was to be a stipulation that a condition to this

    W.P.(C) No.743 of 2017 Page 47 of 85
    effect would be incorporated in the draft lease.
    Therefore, in our opinion, the Grant Order dated
    16.07.2015 is provisional, and is subject to
    fulfilment of the conditions therein.

    ***

    21. During the course of arguments before us, reference
    was made by the appellants to the provisions of the
    West Bengal Land Reforms Act, 1955 and the
    judgment of this Court in Thressiamma Jacob and
    Others Vrs. Geologist, Department of Mining and
    Geology and Others, (2013) 9 SCC 725. We have not
    examined the said aspects which are left open and
    not adjudicated upon. However, we deem it
    appropriate to observe that the judgment of this
    Court in Thressiamma Jacob and Others (supra) is
    prior to the enforcement of the Amendment Act, 2015
    and the Concession Rules, 2016. The amendments
    made by the Amendment Act, 2015 were not
    subject matter of decision in the said case and
    would have to be considered by the courts and
    the authorities as a judgment‟s binding ratio
    depends upon the legal provisions considered,
    interpreted and applied in a given judgment.
    When the law changes by an amendment in the
    legislation, the amended legal provisions have
    to be considered, interpreted and applied.”

    10.5. It is apposite to say that having got the approval of the
    Government of India, Ministry of Mines vide Letter
    No.5/111/2008-M.IV, dated 29.09.2008 (Annexure-1)
    stipulating condition to ensure compliance of amended
    provisions of the MMDR Act and the Rules framed

    W.P.(C) No.743 of 2017 Page 48 of 85
    thereunder and other applicable Acts and Rules
    including the Forest (Conservation) Act, 1980 and the
    Environmental Notification dated 27.01.1994 as issued
    and amended by MoEF, and the Letter bearing No.8556-
    III(A)SM 46/2002, dated 23.12.2008 (Annexure-2) issued
    by the State Government specifying conditions therein
    for compliance, the applicant (petitioner) confirmed the
    same by accepting terms and conditions embodied in
    said letters for grant of mining lease for iron ore over an
    area of 45.131 hectares in village: Kundaposi in the
    District of Keonjhar. Upon taking all the necessary
    steps, it was granted the approval by the Central
    Government under Section 2(iii) of the Forest
    (Conservation) Act, 1980 over an area of 45.029 hectares
    of forest land within total mining lease area of 45.131
    hectares pertaining to iron ore mining lease in the said
    village subject to conditions (see, Letter F. No.8-
    73/2016-FC, dated 09.01.2017 available at Annexure-

    12) in consonance with Guidelines, as amended/
    modified from time to time including the Ministry of
    Mines Order dated 04.01.2017 vide F.No.7/1/2016-M.IV
    (Part-1), titled “the Mines and Minerals (Development
    and Regulation) Removal of Difficulties Order, 2017″ (for
    brevity, Removal of Difficulties Order”). Upon receipt of
    such approval the petitioner deposited amount of Net
    Present Value on 10.01.2017 (Annexure-13) and
    furnished compliance report on 10.01.2017.

    W.P.(C) No.743 of 2017 Page 49 of 85

    11. Sri Pinaki Misra, learned Senior Advocate appearing for
    the petitioner referring to the Mines and Minerals
    (Development and Regulation) Act, 1957
    as amended by
    virtue of the Mines and Minerals (Development and
    Regulation) Amendment Act, 2015 emphasised that
    there has been paradigm shift from “grant of lease” to
    “auction regime”. Therefore, necessary amendments
    have been brought not only in the statute but also the
    Rules framed thereunder. Nevertheless, he would
    emphatically submit that the cut-off date which has
    been fixed for execution of mining lease deed, i.e.,
    11.01.2017 inasmuch as the Mines and Minerals
    (Development and Regulation) Amendment Act, 2015
    came into force with effect from 12.01.2015, has no
    rational bearing. He would submit that since the
    petitioner has complied with all the necessary terms and
    conditions put upon in the Letter of Intent dated
    23.12.2008 issued by the State Government read with
    the prior approval of the Central Government in terms of
    Section 5 of the MMDR Act vide Letter dated 29.09.2008
    prior to said cut-off date, that is on 10.01.2017, which
    fact was duly communicated to proper quarters on this
    date, instead of going ahead with the execution of the
    lease deed on 11.01.2017, the petitioner could not be
    discriminated vis-à-vis other similarly situated
    person/entities. Therefore, while not pressing for the
    consideration of the present matter with regard to attack
    W.P.(C) No.743 of 2017 Page 50 of 85
    on the vires of Rule 8(4) of the MC Rules, 2016, he
    advanced arguments based on protection postulated in
    Article 14 of the Constitution of India.

    11.1. Sri Pinaki Misra, learned Senior Advocate has taken this
    Court to Letter of Intent of the Government of Odisha in
    Department of Steel and Mines issued way back on
    23.12.2008 (Annexure-2) to contend that pursuant to
    Government of India in Ministry of Mines Letter dated
    29.09.2008 (Annexure-1) according approval under
    Section 5(1) of the MMDR Act invoking provisions of
    Section 11(5) of said Act read with Rule 59 of the Mineral
    Concession Rules, 1960, such Letter of Intent contained
    certain terms and conditions including requirement of
    obtaining statutory clearance under the Forest
    (Conservation) Act, 1980
    .

    11.2. Dates and events indicates the following facts:

    i. Mining plan was approved on 24.08.2009 by the
    Indian Bureau of Mines, Office of the Regional
    Controller of Mines subject to conditions.

    ii. Collector issued Certificate on 24.11.2010
    indicating compliance under the Scheduled Tribes
    and Other Traditional Forest Dwellers (Recognition
    of Forest Right) Act, 2006
    .

    W.P.(C) No.743 of 2017 Page 51 of 85

    iii. On 14.01.2013 the State Environment Impact
    Assessment Authority (SEIAA), Odisha sought for
    authentic copy of Stage-I Forest Clearance for issue
    of Environmental Clearance.

    iv. Guidelines were issued frequently in quick
    succession with change in procedures. Such
    Guidelines were issued on 01.04.2015, 19.10.2015,
    16.11.2016 and 17.11.2016. Though the
    amendment of the MMDR Act came into force with
    effect 12.01.2015 with stipulation of two years from
    the date of commencement of said Amendment Act
    for grant of mining lease, an Inter-Departmental
    Committee constituted by the Government of
    Odisha in Steel and Mines Department vide
    Notification No.2507-IV(AB)SM-10/2010/SM, dated
    19.03.2015 was vested with power by Notification
    bearing No.3736-III(A)SM-29/1998, dated
    07.05.2016 to examine all proposals for grant of
    mining lease under clauses (b) and (c) of sub-

    section (2) of Section 10A of the MMDR Act and
    make recommendation to the Government.

    v. Even while pending consideration of the online
    application of the petitioner which was submitted
    in view of amended Guidelines, notwithstanding
    earlier one being pending, the Ministry of Mines by

    W.P.(C) No.743 of 2017 Page 52 of 85
    Order dated 04.01.2017 [vide F. No.7/1/2016-M.IV
    (Part-1)] clarified as follows:

    “Ministry Mines
    Order
    New Delhi, the 4th January, 2017

    S.O.27(E).–

    Whereas difficulties have arisen in giving effect to
    the provisions of clause (c) sub-section (2) of Section
    10A of the Mines and Minerals (Development and
    Regulation) Amendment Act, 2015 (10 of 2015),
    insofar as it relates to fulfilment of conditions laid in
    the letter of intent (by whatever name called) issued
    by the State Governments within a period of two
    years from the date of commencement of the said
    Act.

    Now, therefore, in exercise of the powers conferred
    by the sub-section (1) of Section 24 of the Mines and
    Minerals (Development and Regulation) Amendment
    Act, 2015 (10 of 2015), the Central Government
    hereby makes the following order to remove the
    difficulties relating to fulfilment of conditions laid in
    the letter of intent, namely:

    1. Short title and commencement.–

    (1) This order may be called the Mines and
    Minerals (Development and Regulation)
    Removal of Difficulties Order, 2017.

    (2) It shall come into force on the date of its
    publication in the Official Gazette.

    2. Environmental Clearance.–

    W.P.(C) No.743 of 2017 Page 53 of 85

    Notwithstanding anything contained in clause

    (c) of sub-section (2) of Section 10A of the Mines
    and Minerals (Development and Regulation)
    Amendment Act, 2015 (10 of 2015), it is
    clarified that where the condition of obtaining
    environmental clearance has not been complied
    with by the applicant on or before 11 th
    January, 2017, but all other conditions
    specified in previous approval or the letter of
    intent have been fulfilled, the applications shall
    be considered under that section and mining
    lease shall be granted by the concerned State
    Governments in accordance with the
    notifications issued under the Environment
    (Protection) Act
    1986) (29 of 1986):

    Provided that no mining activity shall
    commence unless and until the applicant
    obtain Environmental Clearance as laid down
    under the Environment (Protection) Act, 1986
    and the rules made thereunder.”

    vi. The present context is relatable to Section 10A(2)(c)
    which indicates on a bare reading that the mining
    lease shall be granted subject to fulfilment of
    conditions of previous approval of the Central
    Government or the Letter of Intent within a period
    of two years from the date the Mines and Minerals
    (Development and Regulation) Amendment Act,
    2015 came into force, i.e., 12.01.2015. This would
    mean that the fulfilment of conditions by an
    applicant as instructed in the Letter concerning

    W.P.(C) No.743 of 2017 Page 54 of 85
    prior approval of Government of India in Ministry of
    Mines Letter dated 29.09.2008 or in the Letter of
    Intent of the Government of Odisha in Department
    of Steel and Mines issued in Letter dated
    23.12.2008 ought to be on or before 11.01.2017.

    The provisions of Section 10(2)(c) of the MMDR Act
    read with Rule 8(4) of the MC Rules makes it
    abundantly clear that such cut-off date is non-
    negotiable.

    vii. Order of the Government of India, Ministry of
    Environment, Forest and Climate Change (Forest
    Conservation Division) in F. No.3-1/2016-FC, dated
    10.10.2016 reconstituted the Forest Advisory
    Committee in exercise of power conferred under
    Section 3 of the Forest (Conservation) Act, 1980.
    The Forest Advisory Committee postponed its
    meeting vide Office Memorandum F.No.11-
    91/2012-FC, dated 09.12.2016.

    viii. Order of the Ministry of Mines dated 04.01.2017
    merely provides for obtaining the Environment
    Certificate subsequently where it could not be
    obtained on or before 11.01.2017. Nevertheless,
    said order clearly lays down that no mining activity
    shall commence until the applicant obtains the
    Environment Clearance Certificate as laid down
    under the Environment (Protection) Act, 1986 and
    W.P.(C) No.743 of 2017 Page 55 of 85
    Rules, retaining such mandatory requirement to
    obtain the Environment Clearance.

    ix. The minutes of the meeting held on 10.05.2016 at
    the Ministry of Mines inter alia reveals as follows:

    “A meeting to expedite the pending mining lease
    cases saved under Section 10A(2)(c) was held under
    the Chairmanship of Union Secretary (Mines) on 10 th
    May, 2016 at 12 AM at Aluminium Rood, 101-D,
    Shastri Bhavan, New Delhi, 110001. The list of
    participants of the meeting is given in Annexure-1.

    ***

    5. Further, the Union Secretary (Mines) desired that a
    pro forma be circulated to all State Governments for
    obtaining a uniform status of the saved cases under
    Section 10A(2)(c) with the request to complete the
    data, so that the consolidated list of pending
    clearances from Ministry of Environment, Forest and
    Climate Change and Indian Bureau of Mines may be
    expedited, within prescribed time limit. The pro
    forma has been circulated and the same is given in
    Annexure-III.”

    11.3. The sequel of events depicts that it is the authorities/
    opposite parties who have delayed the consideration of
    Environment Clearance and Forest Clearance. It
    emanates from paragraph 10 of the counter affidavit of
    Government of Odisha in Steel and Mines Department
    that:

    W.P.(C) No.743 of 2017 Page 56 of 85

    “That, the petitioner is not eligible for grant of mining
    lease in terms of Section 10A(2)(c) of MMDR Act and Rule
    8 of the MC Rules, 2016 for the following reasons:

    (i) The applicant has not submitted any compliance
    letter in time as required under Rule 8(1) of the MC
    Rules, 2016 for consideration of his case for issuing
    the letter of grant of mining lease to him.

    (ii) The applicant has obtained forest clearance as
    required under the provisions of Section 2(iii) of the
    Forest Conservation Act, 1980, which is a pre-

    condition for grant of a mining lease only on
    09.01.2017 and submitted on 10.01.2017 late after-
    noon.

    (iii) The mining lease application has thus become
    ineligible for consideration and letter of
    intent/previous approval under Section 5 of the
    MMDR Act have become invalid for consideration.”

    11.4. The reasons so ascribed for attributing the petitioner’s
    laches in obtaining the necessary clearance from
    competent Department of the Government could not
    persuade this Court to accede to the contention of the
    learned Additional Government Advocate.

    11.5. Careful scrutiny of the documents enclosed with the writ
    petition would demonstrate that all the conditions were
    fulfilled including approval under Section 2(iii) of the
    Forest (Conservation) Act, 1980. The approval found
    mentioned in Letter dated 09.01.2017 issued by the
    Ministry of Environment, Forest and Climate Change

    W.P.(C) No.743 of 2017 Page 57 of 85
    has been issued in consideration of State Government
    Letter No.10F(Con) 138/2016/23789/F&E, dated
    20.12.2016. Such approval further seems to have been
    issued after clarification in Removal of Difficulties Order
    dated 04.01.2017 being issued by the Ministry of Mines.

    11.6. From the aforesaid discussions it is not apt to say that
    the delay or laches could be attributed to the petitioner.
    Examination of claim of the petitioner and
    recommendation of the State Government being the
    domain of the Central Government, knowing fully well
    that there was frequent changes in modalities for
    making application and scrutiny of contents thereof
    during 2015-17, at the fag end (i.e., 04.01.2017) the
    Mines and Minerals (Development and Regulation)
    Removal of Difficulties Order, 2017 was issued, and it
    was also well within knowledge of all concerned that the
    cut-off date was fixed on 11.01.2017 for execution of
    lease deed. However, after receipt of Letter dated
    09.01.2017 according approval under Section 2(iii) of the
    Forest (Conservation) Act, 1980, the petitioner took
    immediate step on the very next date i.e., 10.01.2017 by
    making deposit of Net Present Value (Annexure-13) and
    submitting compliance report.

    11.7. A stance is taken by the learned Additional Government
    Advocate that as the petitioner furnished compliance
    report at the last moment on 10.01.2017, due to paucity
    W.P.(C) No.743 of 2017 Page 58 of 85
    of time the lease deed could not be prepared and
    executed. It is interesting to notice counter affidavit filed
    on behalf of the opposite party No.2, Ministry of
    Environment, Forest and Climate Change. Referring to
    history of legislation, reproducing Section 2 of the Forest
    (Conservation) Act, 1980, it is only asserted at
    paragraph 9 of the counter affidavit that proposal
    received from the State Government has been granted
    approval by the Ministry of Environment, Forest and
    Climate Change, New Delhi vide Letter dated
    09.01.2017. The opposite party No.3 also made it clear
    that the stand of the petitioner at paragraph 5(H) of the
    writ petition needs no reply. None of the counter affidavit
    does show any explanation with respect to the fact
    stated at paragraph 5(H) of the writ petition, which is as
    follows:

    “That on 17.06.2011, the DFO Keonjhar forwarded the
    proposal to RCCF (Rourkela) after verifying the Forest
    Diversion Proposal of the petitioner No.1-Company. Finally
    on 11.04.2014, the Government of Odisha, Forest &
    Environment Department forwarded the proposal of the
    petitioner No.1 to the MoEF. Thereafter, on 30.05.2014,
    the MoEF scrutinizing the proposal, forwarded the same
    to the Forest Appraisal Committee. It is submitted that the
    proposal of the petitioner No.1 for diversion of 41.01
    hectares of forest land under Section 2(ii) of the Forest
    Conservation Act, 1980 is pending with the MoEF.”

    W.P.(C) No.743 of 2017 Page 59 of 85

    11.8. No reply is proffered by the said opposite party No.3 as
    to why the approval could be accomplished on
    09.01.2017 though it was within its knowledge that
    time-frame is stipulated in the Mines and Minerals
    (Development and Regulation) Amendment Act, 2015. It
    is not out of place to have reference to Letter dated
    31.10.2016 addressed to Principal Secretary,
    Department of Steel and Mines, Government of Odisha
    (Annexure-24), whereby the petitioner candidly
    intimated that “The Forest Appraisal Committee after
    detailed deliberations recommended that decision on the
    proposal involving diversion of large area of forest land for
    execution of a fresh mining lease may be deferred till
    completion of the carrying capacity study proposed to be
    undertaken by Ministry of Environment, Forest and
    Climate Change”. As it has already been mentioned in
    the foregoing paragraphs there were very many
    Guidelines issued by the Ministry concerned and the last
    such clarification in the form of the Mines and Minerals
    (Development and Regulation) Removal of Difficulties
    Order, 2017 was issued only on 04.01.2017. It is
    thereafter within five days of such Order, the approval
    under Section 2(iii) of the Forest (Conservation) Act,
    1980 was accorded.

    11.9. The petitioner enclosing all necessary documents
    submitted a representation under the Subject

    W.P.(C) No.743 of 2017 Page 60 of 85
    “Compliance Report with respect to grant proceeding vide
    Letter No.III(A)SM 46/02/8556/SM, BBSR, dated
    23.12.2008 and Memo No.897/SM, BBSR, dated
    04.02.2009” with request to issue lease execution order.
    Said representation dated 10.01.2017 addressed to the
    Principal Secretary to Government of Odisha in
    Department of Steel and Mines, was received in the
    Office of the Secretary, Steel and Mines Department. A
    letter indicating compliance of all the requirements has
    been filed in the Office of Divisional Forest Officer,
    Keonjhar Division, on 11.01.2017.

    11.10. It is not the case of the opposite parties that the
    petitioner did not comply with the conditions envisaged
    for execution of lease deed. It is the allegation of the
    opposite parties that the compliance report was received
    by them at late hours of 10.01.2017 just before the last
    date, i.e., 11.01.2017.

    11.11. The petitioner having complied with all such terms
    and conditions including deposit of Net Present Value
    and approval under Section 2(iii) of the Forest
    Conservation Act, 1980 (see, Annexures-12, 13 and 14),
    in the considered view of this Court, the Government of
    Odisha should have been more pragmatic than pedantic
    in its approach, particularly when it could execute many
    lease deeds on a single day, i.e., 11.01.2017 with respect
    to others. Save and except receipt of compliance report
    W.P.(C) No.743 of 2017 Page 61 of 85
    “late afternoon”, no explanation is offered by the
    opposite parties as to why the petitioner was
    discriminated.

    12. It is in the wake of aforesaid factual scenario and legal
    position, Sri Pinaki Misra, learned Senior Advocate
    pressed into service provisions of Article 14 of the
    Constitution of India by demonstrating that to the
    information of the petitioner sixteen numbers of mining
    leases with respect to major minerals pertaining to
    Section 10A(2)(c) of the MMDR Act were executed and
    registered on a single day, i.e., 11.01.2017 (See,
    Annexure-1 to the written note of submission dated
    15.12.2025). Amongst them, to illustrate, he
    categorically wished to demonstrate the case of Sree
    Metaliks Ltd., whose facts and circumstances are akin to
    that of the petitioner.

    12.1. Referring to Annexure-31 enclosed with the Additional
    Affidavit dated 11.09.2025 (filed on 15.09.2025)
    emphasis is laid on the date of execution of Mining Lease
    Deed in specified format in Schedule VII (See Rules
    7(11), 8(4), 9(2), 12(1)(d) of the MC Rules, 2016. It is
    submitted that the lease deed was not only executed on
    11.01.2017 between the Governor of Odisha acting
    through the Department of Steel and Mines, Government
    of Odisha signed by the Collector, Keonjhar (Lessor) and
    the Sree Metaliks Ltd. (Lessee) and registered on the very
    W.P.(C) No.743 of 2017 Page 62 of 85
    same date. To further clarify the position with the
    similarity between Sree Metaliks Ltd. and the instant
    petitioner, the submission of learned Senior Counsel
    proceeded to state that said Sree Metaliks Ltd. also got
    approval under Section 2(iii) of the Forest Conservation
    Act, 1980 on 10.01.2017, i.e., one day prior to
    11.01.2017. He stated that rather the petitioner was on
    better footing.

    12.2. Sri Saswat Das, learned Additional Government
    Advocate as against the plea taken by the petitioner in
    the Rejoinder Affidavit that discrimination has been
    caused to it as it is similarly circumstanced in
    comparison to the facts of Sree Metaliks Ltd., submitted
    that Article 14 of the Constitution of India emphasises
    equality before law which is subject to reasonable
    restriction. In other words, the fundamental right are
    subject to reasonable restriction. The reasonable
    restriction is apparent under the provisions envisioned
    under 10A(2)(c) of the MMDR Act read with Rule 8(4) of
    the MC Rules, 2016. The petitioner cannot claim equity
    vis-a-vis operation of law as constricted under sub-rule
    (4) of Rule 8 of the MC Rules, 2016. The claim of the
    petitioner is hit by negative equality. Merely because the
    lease deed could be timely executed with Sree Metaliks
    Ltd. it is with vehemence urged that non-execution of
    lease deed in favour of the petitioner cannot be agitated

    W.P.(C) No.743 of 2017 Page 63 of 85
    as a matter of right by comparing with the facts of said
    company. It is arduously contended that it does not cast
    an obligation on the State Government to execute the
    lease deed in favour of the petitioner contrary to the
    conditions with cut-off date laid down in Section
    10A(2)(c)
    of the MMDR Act read with sub-rule (4) of Rule
    8 of the MC Rules.

    12.3. Sri Saswat Das, learned Additional Government
    Advocate stemmed on following observations of the
    Hon’ble Supreme Court of India made in R. Muthukumar
    Vrs. Chairman and Managing Director, TANGEDCO,
    (2022) 1 SCR 577:

    “A principle, axiomatic in this country‟s constitutional lore
    is that there is no negative equality. In other words, if
    there has been a benefit or advantage conferred on one or
    a set of people, without legal basis or justification, that
    benefit cannot multiply, or be relied upon as a principle of
    parity or equality. In Basawaraj & Anr. Vrs. Special Land
    Acquisition Officer, (2013) 14 SCC 81 = (2013) 8 SCR 227,
    this court ruled that:

    „8. It is a settled legal proposition that Article 14 of the
    Constitution is not meant to perpetuate illegality or
    fraud, even by extending the wrong decisions made
    in other cases. The said provision does not envisage
    negative equality but has only a positive aspect.
    Thus, if some other similarly situated persons have
    been granted some relief/benefit inadvertently or by
    mistake, such an order does not confer any legal
    right on others to get the same relief as well. If a

    W.P.(C) No.743 of 2017 Page 64 of 85
    wrong is committed in an earlier case, it cannot be
    perpetuated.‟

    Other decisions have enunciated or applied this principle
    (Ref: Chandigarh Admn. Vrs. Jagjit Singh, (1995) 1 SCC
    745, Anand Buttons Ltd. Vrs State of Haryana, (2005) 9
    SCC 164, K.K. Bhalla Vrs. State of M.P., (2006) 3 SCC
    581; Fuljit Kaur Vrs. State of Punjab, (2010) 11 SCC 455;
    and Chaman Lal Vrs. State of Punjab, (2014) 15 SCC

    715). Recently, in The State of Odisha Vrs. Anup Kumar
    Senapati, 2019 SCC Online SC 1207 this court observed
    as follows:

    „If an illegality and irregularity has been committed in
    favour of an individual or a group of individuals or a
    wrong order has been passed by a judicial forum, others
    cannot invoke the jurisdiction of the higher or superior
    court for repeating or multiplying the same irregularity or
    illegality or for passing a similarly wrong order. A wrong
    order/decision in favour of any particular party
    does not entitle any other party to claim benefits on
    the basis of the wrong decision.”

    12.4. Per contra, it is submitted by the learned Senior Counsel
    for the petitioner that the explanation/reply in the
    counter affidavit(s) does not emerge any distinctive
    feature being drawn between the circumstances of the
    petitioner and Sree Metaliks Ltd. Highlighting that the
    opposite parties, in view of Mohinder Singh Gill Vrs. The
    Chief Election Commissioner, AIR 1978 SC 851, cannot,
    in absence of any pleading in that regard, contend that a
    wrong order/decision in favour of any particular party
    does not entitle any other party to claim benefits on the

    W.P.(C) No.743 of 2017 Page 65 of 85
    basis of the wrong decision. Nothing is placed on record
    to suggest that steps are being taken against the err, if
    at all, perpetrated by the functionaries. No dispute is set
    out by the opposite parties with respect to execution and
    registration of sixteen mining lease deeds with respect to
    major minerals on a single date, i.e., 11.01.2017.

    12.5. In order to bring to fore the similarity between the two,
    Sri Pinaki Misra, learned Senior Advocate insisted to
    consider Letter dated 10.01.2017 issued by the
    Conservator of Forests (Central) addressing the Principal
    Secretary, Forest and Environment Department,
    Government of Odisha (Annexure-28 of the Rejoinder
    Affidavit filed by the petitioner) and Letter dated
    09.01.2017 issued by Assistant Inspector General of
    Forests (Annexure-12 of the writ petition). Minute
    excursion into both the letters reveals that approval
    invoking Section 2(iii) under the Forest (Conservation)
    Act, 1980
    was accorded to Sree Metaliks Ltd. in the
    Letter marked as Annexure-28, whereas Letter marked
    as Annexure-12 was issued in favour of the petitioner.

    The tenor and nature of both the letters are found to be
    identical requiring certain conditions to be fulfilled. Sri
    Saswat Das, learned Additional Government Advocate
    could not dispute the similitude in both the letters of
    approval issued under Section 2(iii) of the Forest
    (Conservation) Act. This Court finds force in the

    W.P.(C) No.743 of 2017 Page 66 of 85
    contention of the learned Senior Advocate that though
    Sree Metaliks Ltd. got the said approval on 10.01.2017,
    its lease deed could be prepared, executed and registered
    on 11.01.2017; whereas the approval accorded in favour
    of the petitioner granted on 09.01.2017 and compliance
    report with respect to grant proceeding was submitted
    by the petitioner on 10.01.2017 having deposited the
    amount of Net Present Value (Annexure-13), its lease
    deed was not executed and/or registered.

    12.6. It is, thus, observed that the case law cited and relied
    upon by the learned Additional Government Advocate to
    counter the argument of the petitioner qua equality/
    parity in treatment between two similarly situated
    entities/persons has no application on the present facts
    and in the circumstances of the matter.

    12.7. In the considered view of this Court, the State
    Government should have been considerate and it could
    not discriminate the petitioner particularly when it is
    demonstrated that sixteen lease deeds in respect of
    major minerals could be executed and registered on a
    single day, i.e., 11.01.2017 including similarly situated
    entity, namely Sree Metaliks Limited.

    13. It is pointed out by Sri Saswat Das, learned Additional
    Government Advocate that in Balasore Alloys Limited
    Vrs. State of Odisha, 2019 (I) ILR-CUT 214 this Court

    W.P.(C) No.743 of 2017 Page 67 of 85
    while taking cognizance of the fact that the matter
    pertaining vires of provisions of Section 10A(2)(c) of the
    MMDR Act read with Rule 8(4) of the MC Rules, 2016,
    being sub judice before the Hon’ble Supreme Court of
    India, passed the following order:

    “21. So far the various provisions contained in Section
    10-A(2)(c) of MMDR Amendment Act, 2015 read with
    Rule 8(4) of the Concession Rules, 2016 are
    concerned, it has been brought to the notice of this
    Court that the matter is pending before the apex
    Court for consideration. Therefore, this Court is
    refrained from examining the same, when the matter
    is sub judice before the apex Court. But at the same
    time, this Court is of the considered opinion that
    there is nothing available on record to stand in the
    way of petitioner No.1 for executing the mining lease,
    as it has already complied all the requirements
    under various provisions of the Act and all the
    authorities concerned have acknowledged the
    requisite fees deposited for the purpose of execution
    of such mining lease. Therefore, we direct the
    opposite parties to execute the mining lease as
    expeditiously as possible, preferably within a period
    of two months hence.

    22. The writ application is thus allowed. No order to
    costs.”

    13.1. Against the said judgment and order, the State of Odisha
    moved the Hon’ble Supreme Court of India in Special

    W.P.(C) No.743 of 2017 Page 68 of 85
    Leave Petition (Civil) Diary No(s).6602 of 201910 wherein
    the following order was passed on 11.03.2019:

    “Delay condoned.

    Issue notice.

    In the meantime, the operation of the impugned order
    passed by the High Court shall remain stayed.”

    13.2. It is submitted by the learned Additional Government
    Advocate that in Larsen & Toubro Limited Vrs. Union of
    India, W.P.(C) No.4301 of 2021, vide Judgment dated
    02.03.202311 this Court upheld the vires of the Mines
    and Minerals (Development and Regulation) Amendment
    Act
    No.16 of 2021, which came into force with effect
    from 28.03.2021 whereby proviso to Section 10A(2)(b)
    was added and further Section 10A(2)(d) inserted. In the
    said case, this Court held as follows:

    “70. Above apart, the Amendment Act, 2021 is also
    protected under Article 31C of the Constitution of
    India, inasmuch as, it is a law towards securing that
    the ownership and control of the material resources
    of the community („minerals‟ in the present case) are
    so distributed to best subserve the common good, as
    has been referred to Article 39(b) of the Constitution
    of India. Sanjeev Coke Manufacturing Company Vrs.
    Bharat Coking Coal Limited, (1983) 1 SCC 147 is to
    be referred to reach at the conclusion.

    10 Numbered as Civil Appeal No.2336 of 2026 : State of Odisha Vrs. Balasore Alloys
    Limited.

    11 The judgment of this Court reported at 2023 SCC OnLine Ori 706 being
    challenged before the Hon’ble Supreme Court of India in SLP(C) No.006163 of
    2023 [now, numbered as C.A. No.013687 of 2024], the same is pending.

    W.P.(C) No.743 of 2017 Page 69 of 85

    71. In view of the fact and law, as discussed above, it is
    held that the provisions contained in Section
    10A(2)(b)
    of the Amendment Act, 2021 cannot be
    declared as ultra vires rather it is intra vires of
    Constitution of India. As it appears, under Sub-
    section (1) of Section 5 of the MMDR Act, of 1957,
    prior approval of the Central Government is essential
    and that itself cannot be construed to be an empty
    formality rather the recommendation made by the
    State Government is not binding on the Central
    Government. The saving clause, i.e., Section
    10A(2)(b)
    , which has been inserted vide MMDR
    Amendment Act
    2015, with effect from 12.01.2015
    does not create vested right automatically, it merely
    saves the applicants from ineligibility due to
    introduction of auction as the only method of
    obtaining mineral concession. Even the right to
    obtain a mining lease is subject to compliance of the
    terms and conditions mentioned in Section 10A(2)(b),
    which has also lapsed on coming into effect of the
    MMDR Amendment Act, 2021.

    ***

    77. As discussed above, by way of Mineral
    Concession Rules Fourth Amendment Rules,
    2021, the Central Government also omitted
    Rule 7 and Rule 8 of the Mineral Concession
    Rules, 2016, by which the modalities for saved
    applications under Section 10A(2)(b) and
    Section 10A(2)(c) of the Amendment Act, 2015
    were wiped out. Needless to say, prior to the 2015
    Amendment, for all minerals under First Schedule
    (major mineral) of the Act, the State Government only
    had the authority to recommend to the Central

    W.P.(C) No.743 of 2017 Page 70 of 85
    Government for grant or mining lease. Such
    authority was governed by the then existing Section
    11
    of the Act. The State was only a recommendatory
    authority. The ultimate authority for approving the
    grant of mining lease for all First Schedule (major
    mineral) of the Act lay with the Central Government
    under Section 5(1) of the then prevailing MMDR Act,
    1957
    . After the 2015 Amendment, Section 10A(2)(b)
    of the Act and the proviso to Section 10A(2)(c)
    mandate the Central Government‟s approval for
    grant of mining lease. Therefore, Section 10A(2)(b)
    does not vest any right on the petitioner to obtain a
    mining lease without the prior approval of the
    Central Government.

    ***

    91. On the factual matrix, as discussed above, it is
    made clear that the petitioner has breached the
    terms and conditions of the PL as it had made three
    PL applications for bauxite deposits on 31.10.1990
    for use in its captive plant. In its applications, the
    petitioner stated that it is proposing to set up
    alumina plant. The Central Government
    communicated its approval on 22.05.1992 under
    Section 5(1) (b) of the MMDR Act, 1957 to grant PL
    for all the 3 applications for a period of 2 years
    subject to the condition, inter alia, that in case the
    petitioner failed to get the LOI for the plant within a
    year or if such LOI is issued to any other party for a
    project, the PL will be prematurely determined under
    Rule 14 (3) of the M.C. Rules, 1960. If the petitioner
    seeks to take benefit of its status as PL holder under
    Section 10A(2)(b) of the Act despite the fact that its
    PL had expired in 1993, it should have complied

    W.P.(C) No.743 of 2017 Page 71 of 85
    with its terms and conditions. But the petitioner is in
    continuing breach of the terms and conditions of the
    PLs all along as it failed to establish an alumina
    plant and extended its LOI with the Central
    Government.

    92. During the year 2020-2021, the State of Odisha
    received revenue to the tune of approximately Rs.
    20,600/- crores from 140 working mines whereas
    auction premium from 23 auctioned mines alone was
    Rs. 19,250/- crores. Similarly, during the same
    period Karanataka had earned royalty revenue of
    Rs. 649/- crores from 131 working mines whereas
    the auction premium from 11 auctioned mines alone
    was Rs. 1883.8 crores. Therefore, the amended Acts
    2015 and 2021, because of the introduction of the
    auction regime not only got well established in last 7
    years, but also gave encouraging results to the State
    Governments in terms of participation of bidders.
    Therefore, the augmentation of revenue being
    encouraging one, which will be utilized for greater
    public interest, the amendment cannot be said to be
    arbitrary, unreasonable and contrary to the
    provisions of law.

    93. Though a large number of judgments were cited on
    behalf of the parties, but the judgments, which are
    apt for the just and proper adjudication of the case,
    have been taken into consideration.

    94. In view of the facts and law, as discussed above,
    this Court is of the considered view that the
    provisions contained in Section 10A(2)(b) in the
    Amendment Act, 2021 is intra vires. Thereby, the
    application of the petitioner under Section 10A(2)(b)
    for grant of mining lease has lapsed by operation of
    W.P.(C) No.743 of 2017 Page 72 of 85
    law and the petitioner is not entitled to get any relief
    in this writ petition.”

    13.3. Sri Pinaki Misra, learned Senior Advocate contended
    that the said case was with respect to consideration of
    three applications for prospecting licenses which were
    recommended by the State Government stating inter alia

    (i) the applicant had proposed to set up the plant; and
    that (ii) issuance of LoI in favour of the applicant for
    setting up such plant. Drawing distinction, he submitted
    that the petitioner being conscious of the factum of
    matter pending before the Hon’ble Supreme Court of
    India with respect to validity of the amendment, it does
    not press for adjudication of such vires. On the contrary,
    it is harped by the petitioner that even though on
    10.01.2017 it complied with necessary conditions
    attached to the approval order of the Central
    Government under Section 5 of the MMDR Act and the
    LoI issued by the State Government, there was no
    impediment on the part of the Government of Odisha to
    execute and register the mining lease deed along with
    sixteen others including Sree Metaliks Limited, whose
    case is identical to the instant petitioner. The entire case
    in the present context is on the anvil of discriminatory
    treatment falling within the scope of provisions
    envisioned in Article 14 of the Constitution of India.

    W.P.(C) No.743 of 2017 Page 73 of 85

    13.4. Sri Saswat Das, learned Additional Government
    Advocate could not improve upon to justify the action of
    the authorities concerned as to why the lease deed could
    not be executed on 11.01.2017, though in case of Sree
    Metaliks Limited which got the approval under Section
    2(iii)
    of the Forest (Conservation) Act, 1980 on
    10.01.2017 whereas the petitioner got such approval on
    09.01.2017 and deposited the Net Present Value on
    10.01.2017 and also submitted the compliance report on
    the very same date. Only explanation rendered in the
    counter affidavit filed on behalf of the opposite party
    No.3 was that the petitioner submitted the compliance
    report in the “afternoon” on the eve of last date for
    execution of lease deed. In the considered opinion of this
    Court such vague explanation cannot be countenanced.
    As the Government of Odisha was fully conscious of
    such date-line and facilitated many other similarly
    situated entities/persons no rational and plausible
    explanation is forthcoming from the opposite parties.
    Even the counter affidavit of the opposite party No.2, as
    has already been stated in the foregoing paragraphs, is
    silent as to why it took considerable period to grant
    approval invoking Section 2(iii) of the Forest
    (Conservation) Act, 1980. The events in issuing
    Guidelines and clarification through the Ministry of
    Mines Order dated 04.01.2017 vide F.No.7/1/2016-M.IV
    (Part-1), titled “the Mines and Minerals (Development
    W.P.(C) No.743 of 2017 Page 74 of 85
    and Regulation) Removal of Difficulties Order, 2017″

    came at the fag end of two years period stipulated under
    Section 10A(2)(c) of the MMDR Act read with Rule 8(4) of
    the MC Rules, 2016.

    13.5. Under the above scenario, delay and laches cannot be
    attributed to the petitioner.

    14. Valiant attempt was made by Sri Saswat Das, learned
    Additional Government Advocate to support his
    contention to deny direction to execute mining lease. The
    rights of parties being crystallised on the date of filing of
    writ petition12, i.e., in the year 2017. Rule 8 of the MC

    12 See, Beg Raj Singh Vrs. State of U.P., (2003) 1 SCC 726 wherein it has been held
    that,
    “6. The only submission made by the learned counsel for the appellant is that
    the appellant has been given a very rough deal by the State Government
    and the injustice done to the appellant the High Court has failed to
    redeem. He had identified and explored the new mining area and made
    huge expenditure in making the mining area approachable and therefore it
    was the legitimate expectation of the appellant that he would be entitled to
    operate the mine for a minimum period of three years as per the declared
    policy of the State Government. The State Government should not have
    interfered with the order of the Collector and that too at the instance of a
    third party — Respondent 3, when no auction was held and no right was
    created in favour of Respondent 3. Matter as to the grant or renewal of the
    lease for a total period of three years was in accordance with the policy of
    the State Government and was a matter between the State and the
    appellant. It was submitted at the end that the appellant has been
    agitating his right diligently throughout and the time lost in prosecuting
    legal proceedings up to the High Court wherein the plea raised by the
    appellant laying challenge to the order of the State Government was found
    to be meritorious and the order of the State Government held liable to be
    set aside, the appellant should not have been denied relief and should
    have been allowed to operate the mine for that period by which the mining
    operation by the appellant fell short of three years‟ time.

    7. Having heard the learned counsel for the petitioner, as also the learned
    counsel for the State and the private respondent, we are satisfied that the
    petition deserves to be allowed. The ordinary rule of litigation is that
    the rights of the parties stand crystallized on the date of
    commencement of litigation and the right to relief should be
    decided by reference to the date on which the petitioner entered
    the portals of the court. A petitioner, though entitled to relief in law,
    W.P.(C) No.743 of 2017 Page 75 of 85
    Rules, 2016 was in vogue at the relevant point. By virtue
    of the Minerals (Other Than Atomic and Hydro Carbon
    Energy Mineral) Conservation (Fourth Amendment)
    Rules, 2021 Rule 8 stood omitted with effect from
    02.11.2021. It is submitted that in absence of specific
    provisions saving the actions under Rule 8, Section 6 of
    the General Clauses Act, 1897 cannot come to rescue of
    the petitioner. What is essentially submitted by the
    learned Additional Government Advocate is that in
    absence of saving clause in said Amendment Rules of
    2021, all the rights, privileges, applications or liability
    acquired or accrued under the enactment so repealed

    may yet be denied relief in equity because of subsequent or intervening
    events i.e. the events between the commencement of litigation and the
    date of decision. The relief to which the petitioner is held entitled
    may have been rendered redundant by lapse of time or may have
    been rendered incapable of being granted by change in law. There
    may be other circumstances which render it inequitable to grant the
    petitioner any relief over the respondents because of the balance tilting
    against the petitioner on weighing inequities pitted against equities on the
    date of judgment. Third-party interests may have been created or
    allowing relief to the claimant may result in unjust enrichment on
    account of events happening in-between. Else the relief may not be
    denied solely on account of time lost in prosecuting proceedings in
    judicial or quasi-judicial forum and for no fault of the petitioner. A
    plaintiff or petitioner having been found entitled to a right to relief, the
    court would as an ordinary rule try to place the successful party in the
    same position in which he would have been if the wrong complained
    against would not have been done to him. The present one is such a case.
    The delay in final decision cannot, in any manner, be attributed to the
    appellant. No auction has taken place. No third-party interest has been
    created. The sand mine has remained unoperated for the period for which
    the period of operation falls short of three years. The operation had to be
    stopped because of the order of the State Government intervening which
    order has been found unsustainable in accordance with stipulations
    contained in the mining lease consistently with GO issued by the State of
    Uttar Pradesh. Merely because a little higher revenue can be earned by
    the State Government that cannot be a ground for not enforcing the
    obligation of the State Government which it has incurred in accordance
    with its own policy decision.”

    W.P.(C) No.743 of 2017 Page 76 of 85

    stood continued to operate in view of Section 6 of the
    General Clauses Act, 1897.

    14.1. This Court on perusal of written note of submission
    dated 11.12.2025 furnished by the learned Additional
    Government Advocate finds the following stand taken by
    the opposite parties:

    “4. *** Cummulative reading of the statutory provisions
    basically Section 10A and Section 10A(2)(c) of the
    MMDR Act read with the provisions of sub-rule (4) of
    Rule 8 of the MC Rules, 2016 and Section 6 of the
    General Clauses Act, it is the clear mandate of law
    that the lease deed has to be executed between the
    parties (lessor and lessee) on or before 11.01.2017
    after having fulfilled all the conditions by the lessee
    as per the exception carved out under Section
    10A(2)(c)
    .

    In this regard the law is well settled by the Hon‟ble
    Apex Court in case of Sangram Spinners Vrs.
    Regional Provident Fund Commissioner reported in
    (2008) 1 SCC 391 where in the Hon‟ble apex court
    held as follows:

    „It is the cardinal principle of construction that every
    statute is prima facie prospective unless it is
    expressly or by necessary implication made to have
    retrospective operation. The absence of a saving
    clause in a new enactment preserving the
    rights and liabilities under the repealed law is
    neither material nor decisive of the question. In
    terms of Section 6(c) of the General Clauses Act,
    1897 unless a different intention appears the repeal

    W.P.(C) No.743 of 2017 Page 77 of 85
    shall not affect any right, privilege or liability
    acquired, accrued or incurred under the enactment
    repealed. The appellant would be entitled to the
    protection for the period of three years starting from
    the date the establishment was set up irrespective of
    the repeal of the provision for such infancy
    protection.‟

    5. The plea taken by the petitioner during the course of
    argument that the said rule having been amended
    and repealed by virtue of the Notification
    dt.02.11.2021, cannot be placed into operation to
    deny the benefits to the petitioner as carved out in
    the exception in 10A(2)(c) does not hold good in view
    of the provision of Section 6 of the General Clauses
    Act. Admittedly, in the present case in hand,
    though the petitioner complied with all the
    statutory requirements and submitted
    compliance on 10.01.2015 before the
    authorities, but as there was no time to execute
    th lease deed within a short span of time.

    Admittedly the lease deed could not be
    executed between the parties on or before
    11.01.2017 and as such by operation of sub-
    rule (4) of Rule 8 of MC Rules, 2016, the right of
    the applicant (petitioner) under clause (c) of
    sub-section (2) of Section-10A for grant of
    mining lease stood forfeited and therefore,
    there was no requirement for the State
    Government to issue any further order in this
    regard.

    ***

    7. That the plea taken by the petitioner in the Rejoinder
    Affidavit that a discrimination has been caused to it
    W.P.(C) No.743 of 2017 Page 78 of 85
    as in similar circumstances, lease deed has been
    executed in respect of Sree Metaliks Limited. In this
    regard, it is humbly submitted that Article 14 of the
    Constitution of India which emphasises equality
    before law puts also certain reasonable restrictions
    to such fundamental right. In other words, all
    fundamental rights are subject to reasonable
    restrictions. The reasonable restrictions are apparent
    under the provisions prescribed under Section
    10A(2)(c)
    of the MMDR Act read with Rule 8(4) of the
    MC Rules and Section 6 of the General Clauses Act.
    The petitioner cannot claim equity over and above
    the operation of law as prescribed under sub-rule (4)
    of Rule 8 of the MC Rules, 2016. The claim of the
    petitioner is hit by negative equality merely because
    the lease deed could be timely executed with Sree
    Metaliks Ltd. on or before 10.01.2015 (sic.,
    11.01.2017) does not cast an obligation on the State
    Government to execute the lease deed in favour of
    the petitioner contrary to the condition stipulated
    under sub-rule (4) of Rule 8 of the MC Rules, 2016.”

    14.2. This Court on examination of rival contentions and
    submissions in this respect finds that there is no
    material put forth by the opposite parties to show that
    by efflux of time third-party interests have been created
    or allowing relief to the petitioner would result in unjust
    enrichment on account of events happening in between.
    Hence, this Court is in a position to say that the relief
    may not be denied solely on account of time lost in
    prosecuting proceedings in judicial or quasi judicial
    forum and for no fault of the petitioner.

    W.P.(C) No.743 of 2017 Page 79 of 85

    14.3. It may be fruitful to repeat that this Court in Order
    dated 16.01.2017 while entertaining the instant writ
    petition as an interim measure directed that the
    provisions of sub-rule (4) of Rule 8 of the MC Rules,
    2016 shall not be made applicable in the case of the
    petitioners.

    14.4. Nothing is argued on behalf of the opposite parties to
    indicate that Sree Metaliks Limited could comply with
    the conditions attached to the approval under Section
    2(iii)
    of the Forest (Conservation) Act, 1980 much prior
    to the compliance being made by the petitioner. The
    counter affidavit and the written note of submission are
    silent in this regard. Nothing is put forth by the learned
    Additional Government Advocate to demonstrate that
    Sree Metaliks Limited was in an advantageous position
    than the petitioner and nothing is spelt out by the
    opposite parties to show that the circumstances which
    led to consider the applications of Sree Metaliks Limited
    and fifteen others in preference to the petitioner.

    14.5. This Court vide Order dated 24.04.2018 in the instant
    writ petition passed the following in consideration of
    Misc. Case No.17260 of 2017:

    “The primary prayer of the petitioners in this Misc.
    Case is for a direction to the Forest Advisory
    Committee to consider the application of the
    petitioners for grant of forest clearance under Section

    W.P.(C) No.743 of 2017 Page 80 of 85
    2(ii) of the Forest (Conservation) Act, 1980, and,
    during the pendency of this writ petition, the result
    of the same be kept in sealed cover, which would be
    subject to further order passed in this writ petition.
    To such application, a counter affidavit has been
    filed by the Ministry of Environment, Forest and
    Climate Change, Government of India, to which
    rejoinder affidavit has also been filed.

    2. Shri A. Mohanty, learned Central Government
    Counsel for the opposite party-Ministry of Forest has
    submitted that a decision was taken by Forest
    Advisory Committee on 16th May 2017, while
    dealing with Agenda No.1, wherein the Forest
    Advisory Committee has opined that
    permission to the State Government will not be
    granted for considering the application of the
    petitioners for forest clearance because of
    pendency of this writ petition in which this
    Court had passed interim order on 11.01.2017.
    After quoting the interim order, the Forest Advisory
    Committee opined that the State Government may
    not consider the application of the petitioners for
    forest clearance.

    3. In our view, in our order dated 11.01.2017 there
    was no direction with regard to the consideration of
    the application of the petitioners for forest clearance.
    The submission of learned counsel for the petitioners
    is that this Court may not issue a direction to give
    the order/decision to the petitioners on their
    application for grant of forest clearance, but the
    application for grant of forest clearance filed by the
    petitioners may be considered in accordance with
    law and the decision on the same be kept in sealed

    W.P.(C) No.743 of 2017 Page 81 of 85
    cover, so that in case this writ petition is allowed,
    there may not be any further delay.

    4. Since we are of the view that our order dated
    11.01.2017 can in no way be interpreted as if we
    have expressed any opinion with regard to
    consideration of the application of the petitioners for
    grant of forest clearance, the opinion given by the
    Forest Advisory Committee while dealing with
    Agenda No.1 on 18.09.2017 regarding not granting
    permission to the State Government to consider the
    application of the petitioners for grant of forest
    clearance is not justified, as there was no such
    observation even made in our order dated
    11.01.2017.

    5. As such, we allow this application and direct the
    opposite parties to consider the application of
    the petitioners for grant of forest clearance
    under Section 2(ii) of the Forest Conservation
    Act, 1980 expeditiously and in accordance
    with law, and the same be kept in sealed cover
    to be opened as per the direction of this Court
    in this writ petition. We make it clear that we
    have not expressed any opinion with regard to
    merits of the application of the petitioners, which
    shall be considered by the concerned authority while
    considering the application of the petitioners.

    The Misc. Case stands disposed of.”

    Despite such clear direction, there has been non-
    compliance of such order by the concerned authority.

    14.6. On the contrary, the learned Senior Counsel for the
    petitioner in his fairness could establish that whereas
    W.P.(C) No.743 of 2017 Page 82 of 85
    the petitioner got the approval under Section 2(iii) of the
    Forest (Conservation) Act on 09.01.2017 and deposited
    Net Present Value on 10.01.2017 and also submitted
    compliance on the said date itself, record reveals that
    Sree Metaliks Ltd. having obtained approval on
    10.01.2017 and there is nothing forthcoming from the
    side of the opposite parties to show that Net Present
    Value could be deposited prior to the petitioner. It is un-
    understandable that if the time could be given for Sree
    Metaliks Limited for consideration of its application who
    could submit compliance report on the same date when
    the petitioner submitted, no explanation is proffered by
    the opposite parties in their counter affidavit nor could
    any reply be offered in this regard by the learned
    Additional Government Advocate.

    14.7. In such view of the matter, the stance of the learned
    Additional Government Advocate taken that the case of
    the petitioner could not be considered inasmuch as it
    stood unequally circumstanced in comparison to Sree
    Metaliks Limited is repelled.

    Conclusion:

    15. Having diligently considered each aspect of arguments
    advanced by the counsel for the respective parties and
    on the afore-discussed factual matrix, in consideration
    of provisions embedded in Article 14 of the Constitution

    W.P.(C) No.743 of 2017 Page 83 of 85
    of India, this Court finds no other scope than to hold
    that the State Government treated the petitioner with
    discrimination. As the learned Senior Advocate
    representing the petitioner confined his arguments to
    invoke doctrine of equality inviting consideration of this
    Court for parity in treatment with other entities whose
    cases were considered by the State Government with
    alacrity on the last date specified in Section 10A(2)(c) of
    the MMDR Act read with Rule 8(4) of the MC Rules,
    2016 for execution and registration of lease deed, this
    Court, hence, holds that the State Government having
    admitted that the petitioner has “complied with all the
    statutory requirements and submitted compliance
    on 10.01.2017”, it could not single out the petitioner.
    Therefore, the submission of the learned Additional
    Government Advocate is negatived and it is, hence, to be
    held that the petitioner being identically circumstanced
    with the other entities more particularly in comparison
    with the case of Sree Metaliks Limited, the action of the
    functionaries of the State Government is tainted with
    arbitrariness, whims and it does attract vice of Article 14
    of the Constitution of India.

    16. Under the above premise, it is felt expedient to issue writ
    of mandamus to the opposite parties particularly the
    opposite party No.3 to consider the case of the petitioner
    as the opposite parties in the written note of submission

    W.P.(C) No.743 of 2017 Page 84 of 85
    dated 11.12.2025 admitted that it has complied with all
    statutory requirements on 10.01.2017 prior to the cut-
    off date envisaged under Section 10A(2)(c) of the MMDR
    Act read with Rule 8(4) of the MC Rules, 2016. Such
    exercise and follow up action is required to be completed
    within a period of eight weeks from date.

    17. With the above observations and directions, the writ
    petition including pending Interlocutory Application(s), if
    any, stands disposed of; but in the circumstances, there
    shall be no order as to costs.

    I agree.

                                         (HARISH TANDON)                 (MURAHARI SRI RAMAN)
                                          CHIEF JUSTICE                        JUDGE
    
    
    
    
    Signature Not
    Verified
    Digitally Signed
    Signed by: ASWINI KUMAR
    SETHY
    Designation: Personal
    Assistant (Secretary in
    Charge)
    Reason: Authentication       High Court of Orissa, Cuttack
    Location: ORISSA HIGH        The 28th July, 2026//Aswini/Laxmikant
    COURT, CUTTACK
    Date: 28-Jul-2026 18:24:17
    
                                 W.P.(C) No.743 of 2017                              Page 85 of 85
     



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