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Sanjeev Coke Manufacturing Company versus Bharat Coking Coal Ltd. and Another

(1983) 1 SCC 147cited in 108 judgementsfollowed or applied in 41

Read the judgement · Every citing judgement, by treatment

How later courts have used it

AI overview
  • The Supreme Court has held that Article 31C, as upheld in Kesavananda Bharati, remains in force, with the unamended text revived after Minerva Mills.1
  • The authority erred in its handling of observations on Article 39(b), per the later Supreme Court ruling.1
  • An auction regime for major minerals does not violate Articles 14, 19, or 39(b).2
  • A levy on carriers is a fee, not a tax, and is intra vires.3
  • Mere filing of an application for a mining lease does not create a vested right.2
Read the full overview· 3 paragraphs

The authority headnote itself concerns the meaning of 'material resources of the community' under Article 39(b), the validity of Article 31C, and the vesting of coke oven plants under the 1972 Act. Within the judgements here, a subsequent Supreme Court decision delivered a sweeping ruling on Article 31C, holding that the provision as upheld in Kesavananda Bharati remains in force, that the unamended text was revived after Minerva Mills, and that the earlier authority erred in its treatment of observations on Article 39(b). No other judgement in the corpus directly engages with the themes of nationalisation or the definition of 'mine' under the 1972 Act.1

Other judgements here cite the authority only incidentally or distinguish it on unrelated grounds. Several High Court decisions in mining, tenancy, and levy contexts rely on general constitutional principles, with one holding that an auction regime for minerals does not violate Articles 14, 19, or 39(b), and another upholding a cess on carriers as a fee within State competence. The remaining judgements concern wholly different topics—disciplinary powers of a society, interim stay vacation, encroachment writs, MACT Rules validity, and Goa succession amendments—with the authority acknowledged but not followed on point.2,3,4,5,6,7,8,9,10,11,12,13,14

Several judgements are nearly identical in content, particularly those addressing the Bihar MACT Rules and the Goa succession amendments, which appear multiple times in the sample. The only substantive engagement with the authority's core holding comes from the 2024 Supreme Court decision.7,8,9,10,11,12,13,14,1

Only one judgement engages with the authority's core holding on Article 39(b) and Article 31C; the rest are unrelated or duplicate. Sample includes several nearly identical headnotes and recent High Court orders. Machine-written from the headnotes of the judgements on this page; numbers link to the source judgements. Not legal advice — read the judgements before relying on them.

Citing judgements

All 108, by treatment

The most-cited judgements that cite it, with how each treated it.

  1. Property Owners Association & Ors. versus State of Maharashtra & Ors.

    Supreme Court5 Nov 20242024 INSC 835D.y. Chandrachud

    Article 31C survival and revival after Minerva Mills; doctrine of substitution and composite legislative intent; repeal-without-substitution exception; Article 39(b) interpretation; 'material resources of the community'; privately owned resources; qualifier of 'material needs'; 'personal effects' exclusion;

    Reference answeredDisapproved
    Open

  2. State of Kerala Vs Sunil C.Kurien

    Kerala HC28 Mar 2017WA/1765/2016Antony Dominic

    Appeal by the State against quashing of its order superseding the Managing Committee of the Indian Red Cross Society's State Branch. The Division Bench held that the Act, Rules and Regulations give neither the State Government nor the State Branch President power to discipline the Managing Committee or its Chairman,…

    DismissedDistinguished
    Open

  3. Union Territory of Goa, Daman and Diu and Anr. versus Lakshmibai Narayan Patil etc. etc.

    Supreme Court23 Jul 19901990 INSC 210L.m. Sharma

    Supreme Court of India, 23-07-1990, Sharma, J. (bench: Lalit Mohan Sharma and T. Kochu Thommen, JJ.) — Union Territory of Goa, Daman and Diu v. Lakshmibai Narayan Patil, Civil Appeals Nos. 1314-1318 of 1979 allowed; Writ Petition No. 864 of 1988 dismissed.

    AllowedDistinguished
    Open

  4. Sh. Jilubhai Nanbhai Khachar etc. etc. versus State of Gujarat and Anr. etc. etc.

    Supreme Court20 Jul 1994ESCR010002661994K. Ramaswamy

    The Supreme Court upheld the validity of the Land Tenure Abolition Laws (Gujarat Amendment) Act, 1982 and Section 69-A of the Bombay Land Revenue Code, 1982. The Court held the Act falls under Entries 18 and 23 of the State List and is saved by Article 31-A as agrarian reform.

    DismissedReferred
    Open

  5. High Court Bar Association, Allahabad versus State of U.P. & Ors.

    Supreme Court29 Feb 20242024 INSC 150D.y. Chandrachud

    Five-Judge Constitution Bench reference decision on automatic vacation of interim stays granted by High Courts. Holds that interim stay orders do not lapse automatically with the passage of time;

    Reference answeredFollowed
    Open

  6. Basudev Agrawal Vs State

    Orissa HC18 Nov 2025WP(C)/12747/2004Dixit K.s.

    Orissa High Court, Cuttack — W.P.(C) No. 12747 of 2004, decided 18.11.2025 by Dixit Krishna Shripad, J. LRs of deceased petitioner Basudev Agarwal sought allotment/regularization of encroached Government land adjoining his ½-acre industrial plot (lease 25.02.1967) and interdiction of coercive eviction;

    DismissedRelied on
    Open
Show 6 more

  1. The General Insurance Council Vs The State of Bihar

    Patna HC21 Feb 2025CWJC/480/2024Ashutosh Kumar Partha Sarthy

    Bihar Motor Vehicle Accident Claims Tribunal (Constitution And Service Condition) Rules 2023; ultra vires challenge; Sections 165, 166, 176 Motor Vehicles Act 1988; Section 166(2) choice of forum; Section 212(2) savings; divisional-level MACT; Selection Committee chaired by Chief Justice;

    DismissedRelied on
    Open

  2. Shoshila Devi Vs The State of Bihar

    Patna HC21 Feb 2025CWJC/17455/2024Ashutosh Kumar Partha Sarthy

    Patna High Court; CWJC 480/2024 batch (with 627, 740, 1166, 2453, 2966, 3265, 6704, 17455 of 2024); decided 21-02-2025; validity of Bihar Motor Vehicle Accident Claims Tribunal (Constitution And Service Condition) Rules 2023 (amended 27.08.2024) upheld;

    DismissedRelied on
    Open

  3. Shantosh Singh Vs The State of Bihar

    Patna HC21 Feb 2025CWJC/6704/2024Ashutosh Kumar Partha Sarthy

    Batch of 9 Bihar writ petitions (CWJC 480/2024 lead; also 627, 740, 1166, 2453, 2966, 3265, 6704, 17455 of 2024) dismissed by Patna High Court on 21-02-2025 challenging Bihar Motor Vehicle Accident Claims Tribunal (Constitution And Service Condition) Rules 2023 as amended 27.08.2024.

    DismissedRelied on
    Open

  4. Rajdeep Kumar Vs The State of Bihar

    Patna HC21 Feb 2025CWJC/3265/2024Ashutosh Kumar Partha Sarthy

    Patna High Court, CAV judgment dated 21-02-2025 (Ashutosh Kumar, ACJ; Partha Sarthy, J): validity of Bihar Motor Vehicle Accident Claims Tribunal (Constitution And Service Condition) Rules, 2023 as amended in 2024 upheld; ultra vires challenge under Section 166(2)/Sections 165, 166, 176 MV Act 1988 rejected;

    DismissedRelied on
    Open

  5. Orient (Goa) Pvt. Ltd. through Director Shashikala Kakodkar and Anr., Vs State of Goa through Chief Secretary and Anr.

    Bombay HC10 Jan 2024WP/232/2009G. S. Kulkarni Bharat P. Deshpande

    This judgment addresses constitutional challenges to the Goa Rural Improvement and Welfare Cess Act, 2000. The petitioners argued the levy was an invalid tax on free trade and discriminatory.

    DismissedRelied on
    Open

  6. Larsen @ Tourbo Limited Vs Union of India

    Orissa HC2 Mar 2023WP(C)/4301/2021B.r.sarangi M.s.sahoo

    The Court examined the validity of the 2021 Amendment to the Mines and Minerals (Development and Regulation) Act regarding the auction regime for mining leases. It held that the proviso to Section 10A(2)(b) is constitutional and mandates the lapse of pending applications, prioritizing public revenue through auctions.

    DisposedRelied on
    Open