Madhya Pradesh Indusi'Ries Ltd. v. Union of India and Others
Case brief
What is this about?
Duty of administrative tribunals to give reasoned ('speaking') orders; revision under rr. 54-55 Mineral Concession Rules 1960; quasi-judicial character of Central Government's revisional function; Rule 55 proviso - opportunity to make representations by written representation suffices, personal hearing not owed as of right; natural justice - consideration of extraneous/subsequent material without notice (Manganese Ore (India) Ltd. application of October 5, 1962); Article 136 discretionary jurisdiction - fit-case doctrine where party has a fresh avenue of application; ss. 5, 8(2), 10, 13, 17, 30 Mines and Minerals (Regulation and Development) Act 1957 - previous Central approval for manganese ore grants; public-sector reservation of mines; State Government 'grant' without Central approval is mere recommendation; Harinagar Sugar Mills v. Shyam Sundar Jhunjhunwala [1962] 2 SCR 339 relied on by Subba Rao J. and distinguished by Bachawat J. (affirmance with agreed reasons vs reversal without reasons); Shivji Nathubhai v. Union of India relied on for tribunality. Split opinion on obligation to give reasons - useful for arguments on reasoned decisions by revisional authorities and limits of Art. 136 interference. Parties: M.P. Industries Ltd. (appellant; G.S. Pathak) v. Union of India, Under Secretary Ministry of Steel and Mines, State of Maharashtra (respondents; S.V. Gupte, Solicitor-General). Outcome: appeal dismissed without costs.