VidhiSangh

Supreme Court of India · 03/10/2024

STATE OF U.P. & ANR. versus NORTHERN COAL FIELDS

[2024] 10 S.C.R. 1918 · 2024 INSC 948

AI-generated headnote. Verify against the judgment before relying on it. Paragraph numbers refer to the judgment.

Summary

The State of Uttar Pradesh demanded annual lease rent from a coal Government company for forest land diverted to its mining projects. The Supreme Court held that the land had vested in the Central Government free from all encumbrances under Section 10(1) of the Coal Bearing Areas (Acquisition and Development) Act, 1957, and then in the company under Section 11(1). With no pre-existing mining lease, the company was not a deemed lessee of the State, so no statute supported the demand. The State's appeal was dismissed, though for reasons different from the High Court's.

Issues

  1. Whether the State Government could demand lease rent from a Government company in which coal-bearing land acquired under the Coal Bearing Areas (Acquisition and Development) Act, 1957 had been vested.
  2. What separates vesting under Sections 10(1) and 11(1) from vesting under Sections 10(2) and 11(2), and when the Government company becomes a deemed lessee of the State.
  3. Whether the High Court rightly rested its decision on the Constitution Bench ruling on legislative competence in State of West Bengal v. Union of India.
  4. Whether the acquisition was flawed for want of prior consultation with the State Government.

Provisions considered

Held

Result

Appeal by the State dismissed, for reasons different from the High Court's; the lease-rent demand was held to lack any statutory basis. No order as to costs.

Judgment PDF: Supreme Court of India, [2024] 10 S.C.R. 1918.