State cannot execute mineral leases for substances reclassified from minor minerals to major minerals by the Central Government.

The petitioner, a registered partnership firm, was provisionally granted a mining lease for ‘Quartz’ and ‘Silica Sand’ over 09.400 hectares for 30 years.

The petitioner completed several formalities, including obtaining SEIAA permission and a mining plan.

A formal grant order dated 07.03.2024 required the execution of the lease deed within three months, failing which the grant would be revoked.

The petitioner failed to execute the deed within this timeframe, citing the Model Code of Conduct for elections (March to June 2024) as a hindrance.

The Mining Officer revoked the grant on 05.09.2024.

Appeals to the Director of Mining and the State Government were dismissed, primarily because a Central Government notification dated 20.02.2025 had reclassified these minerals from 'Minor' to 'Major,' thereby stripping the State's power to grant such leases.

1. Whether the revocation of the mining lease grant was valid despite the petitioner’s plea of administrative delay caused by the Election Code of Conduct.

2. Whether the reclassification of ‘Quartz’ and ‘Silica Sand’ as Major Minerals by the Central Government notification dated 20.02.2025 precludes the State from executing the lease deed.

The M.P. Minor Mineral Rules, 1996, specifically Rule 21(2)(a) regarding lease execution.

Rule 26 regarding the revocation of grants for non-compliance with formalities.

Section 3 of the Mines and Minerals (Development and Regulation) Act, 1957, which empowers the Central Government to notify and classify minerals.

The Gazette Notification dated 20.02.2025, which deleted 'Quartz' from Schedule V of the Minor Mineral Rules, effectively elevating it to a 'Major Mineral' status.

The court observed that while the petitioner performed due diligence, the three-month window for lease execution was a strict condition of the 07.03.2024 grant order.

Regarding 'Quartz', the court found that the 20.02.2025 notification explicitly removed it from the category of minor minerals; thus, the State no longer possessed the jurisdiction to execute a lease for it under the Minor Mineral Rules.

The court found the status of 'Silica Sand' to be "hazy," as the notification’s impact on it was not clearly established in the specific record.

The court reasoned that if the delay in execution prior to the reclassification was attributable to the State’s inaction rather than the petitioner’s negligence, such factors must be weighed by the appellate authority.

Regarding ‘Silica Sand,’ the court set aside the State Government’s orders dated 28.07.2025 and 29.07.2025 and remanded the matter for fresh adjudication.

The State is directed to verify if 'Silica Sand' remains a minor mineral and determine if the delay in lease execution was attributable to the State.

Both writ petitions were disposed of with these directions.