Supreme Court

Coal supply directed at current rates precludes monetary compensation for price differences during the suspension period.

Union Of India vs Prakash Industries Limited

Supreme CourtJUDGMENT: March 17, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

In 2006, the Ministry of Coal allocated a coal block to Prakash Industries Limited (PIL).

Source reference: para. 5

In 2011, the Ministry suspended coal supplies alleging diversion of coal.

Source reference: para. 5

PIL challenged this suspension before the High Court of Chhattisgarh, which quashed the suspension order.

Source reference: para. 5

In 2013, a Division Bench directed South Eastern Coalfields Limited (SECL) to compensate PIL for the period of non-supply (October 2011 to December 2012) based on the price difference between E-auction and the agreement rate, plus 6% interest.

Source reference: para. 5

On 09.04.2014, the Supreme Court modified this direction, granting the Union of India (UOI) liberty to supply coal at the "current rate" in lieu of monetary compensation for the suspended period.

Source reference: para. 6

Subsequently, SECL offered coal on a "tapering basis" rather than a normal linkage, leading to a second round of litigation.

Source reference: para. 7

The High Court in 2019 quashed the tapering linkage offer and directed supply under normal linkage.

Source reference: para. 7

The UOI’s challenge to this was dismissed by the Supreme Court on 19.08.2025.

Source reference: para. 8

In the present Miscellaneous Applications, PIL sought monetary compensation of approximately ₹106 Crore instead of physical coal, arguing they no longer required the coal and that the UOI's current offer was arbitrary.

Source reference: para. 10.4, 10.5
02

Issues

1. Whether the Respondent (PIL) is entitled to claim monetary compensation for the period of suspended coal supply in lieu of physical coal supply.

Source reference: para. 11, 14

2. Whether the "current price" for coal supply should be determined as of 2014, 2019, or the present date.

Source reference: para. 14, 15
03

Law Applied

The Court primarily applied the principle of judicial finality regarding its own modified directions from the first round of litigation (S.L.P. No. 8436 of 2013), which substituted monetary compensation with the supply of coal at the "current rate" and "prevalent policy".

Source reference: para. 6, 12

The Court also relied on the principle of commercial prudence in interpreting the term "current price" within the context of long-standing litigation and the subsequent orders of the High Court dated 17.05.2019.

Source reference: para. 14, 15
04

Reasoning

The Court observed that both parties were interpreting prior orders to suit their convenience, which was impermissible.

Source reference: para. 11

It clarified that the 2014 Supreme Court order explicitly replaced the High Court’s direction for monetary compensation with an option to supply physical coal at the "current rate".

Source reference: para. 12

The 2019 High Court order (confirmed in 2025) did not revive the claim for monetary compensation; it only corrected the mode of supply from "tapering" to "normal linkage".

Source reference: para. 13, 14

Consequently, PIL’s demand for ₹106 Crore in price differences was legally unavailable.

Source reference: para. 14

Regarding the "current price," the Court reasoned that interpreting it as the price in 2025 would be a misconstruction of the prior adjudications.

Source reference: para. 14

To balance equity and commercial prudence, the Court determined that the Respondent should have the option to choose the price regime applicable at the time of the major judicial milestones (2014 or 2019) to ensure the UOI/SECL does not benefit from their previous non-compliance.

Source reference: para. 15
05

Holding

The Supreme Court rejected the Miscellaneous Applications seeking monetary compensation.

The Court held that UOI/SECL remains obligated to supply coal for the suspended period under "normal coal linkage" and not on a tapering basis.

Source reference: para. 15

It directed PIL to choose between the "current price/prevalent policy" as of 09.04.2014 or 17.05.2019.

Source reference: para. 15

Upon PIL communicating its choice, SECL must enter into a Fuel Supply Agreement (FSA) within two weeks, and the entire process must be completed within four weeks from the date of the judgment.

Source reference: para. 15

All pending applications were disposed of accordingly.

Source reference: para. 16
Supreme Court

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Union Of IndiavsPrakash Industries Limited

Supreme Court · March 17, 2026

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