State Government's Misinterpretation of Mineral (Auction) Rules, 2015 Corrected to Ensure Compliance Period for Gojoli Mineral Block
In a significant ruling, the Bombay High Court's Nagpur Bench has directed the State Government of Maharashtra to grant Dalmia Cement (Bharat) Limited a full two-year extension for executing the mining lease deed for the Gojoli Mineral Block in Chandrapur district. The court quashed the State's earlier decision to curtail the extension period, which had been erroneously interpreted under the Mineral (Auction) Rules, 2015.
The case arose when Dalmia Cement, the preferred bidder for the mining lease of the limestone-rich Gojoli Mineral Block, faced significant delays due to unforeseen regulatory and environmental challenges, including the expansion of forest land and proximity to the Kanhargaon Wildlife Sanctuary. These delays were beyond the company's control and impeded timely compliance with necessary approvals and permits, which are prerequisites for executing the mining lease deed.
Initially, the State Government had granted an extension that was set to expire on September 9, 2025, effectively giving Dalmia Cement less than five months to complete the compliance process. This decision was based on a misinterpretation of Rule 10(6) of the Mineral (Auction) Rules, 2015, which mandates a complete two-year extension when delays are beyond the bidder's control.
The court, presided over by Justices Anil S. Kilor and Rajnish R. Vyas, emphasized the need for a purposive interpretation of statutes, ensuring that legal provisions fulfill their intended purpose. The ruling highlighted that the extension period should start from the date of the extension letter, not retroactively from the end of the initial three-year period.
The court's decision rectifies the State's error, directing it to provide Dalmia Cement the full two-year extension, accounting for the period from April 4, 2025, to September 9, 2025, which had been inadequately covered in the previous extension.
This judgment underscores the importance of adhering to statutory provisions and adopting interpretations that advance the objectives of the law, particularly in complex regulatory environments. The decision is expected to facilitate Dalmia Cement's compliance efforts, enabling the company to proceed with the mining lease execution and subsequent operations without further administrative hindrances.
Bottom Line:
Rule 10(6) of Mineral (Auction) Rules, 2015 - Extension period for execution of mining lease deed - State Government must grant a full two-year extension for compliance under the rules, and cannot curtail the period based on its interpretation.
Statutory provision(s): Rule 10(6) of Mineral (Auction) Rules, 2015
