Case Statistics: Tara Prasad Singh & Ors vs Union of India & Ors
**Case Name:** Tara Prasad Singh & Ors vs Union of India & Ors
**Court:** Supreme Court of India
**Case No.:** Petition Nos. III, 178, 220, 221, 257, 352, 600 and 1130-1134
**Date of Decision:** 09-05-1980
**Bench:** Y. V. Chandrachud, C.J; V. R. Krishna Iyer, J; V. D. Tulzapurkar, J; R. S. Sarkaria, J; P. S. Kailasam, J; P. N. Bhagwati, J; N. L. Untwalia, J
**Final Decision:** Overruled
**Citations:** AIR 1980 SC 1682; (1980) 4 SCC 179; (1980) 3 SCR 1042
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=279296
Facts of the Case
A group of 61 writ petitions challenged the Coal Mines (Nationalisation) Amendment Act, 1976, alleging violations of Articles 14, 19(1)(f), 19(1)(g), and 31 of the Constitution. Petitioners included coal mine lessees and composite mine lessees (coal and fireclay). They argued their leases were wrongly terminated, causing loss of investment and disruption of operations. The State of Bihar contended the leases were already terminated before the Act for violations of mining rules.
Law Points Raised
- Whether the Coal Mines (Nationalisation) Amendment Act, 1976 was constitutionally valid.
- Whether it violated fundamental rights under Articles 14, 19(1)(f), 19(1)(g), and 31.
- Whether composite mines with alternating layers of coal and fireclay fell under the scope of the Act.
- Legislative competence of Parliament under Entries 23 & 54 of List I and List II.
- Effect of prior lease terminations before enactment of the Amendment Act.
Acts / Provisions / Articles Referred
Constitution of India, 1950 — Article 32, Article 14, Article 19(1)(f), Article 19(1)(g), Article 31
Criminal Procedure Code, 1973 — Section 144
Coal Mines (Nationalisation) Amendment Act, 1976
Bihar Land Reforms Act, 1950 — Section 10
Mines and Minerals (Regulation and Development) Act, 1957 — Section 2
Mineral Concession Rules, 1960 — Rule 37
Judgements Referred
Kesavananda Bharati v. State of Kerala (Basic Structure Doctrine relevance)
Obiter Dicta
The Court observed that unregulated mining posed threats to conservation, safety, and labour welfare. Nationalisation aimed at ensuring scientific development of mineral resources.
Ratio Decidendi
The Coal Mines (Nationalisation) Amendment Act, 1976 was held constitutionally valid. Parliament had legislative competence under Entry 54 List I. Termination of leases before the Act’s enforcement could not be challenged under the Act.
Final Ruling
The petitions were dismissed. The Court upheld the validity of the Act and ruled that Parliament had competence to enact it. Leases already terminated prior to the Act could not be revived.
Summary
This landmark judgment upheld the Coal Mines (Nationalisation) Amendment Act, 1976, affirming Parliament’s power to regulate and nationalise mines for public interest. The Court dismissed all writ petitions, holding that prior lease terminations stood unaffected and that nationalisation was essential for planned, scientific mineral development.
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=279296