State Government must re-adjudicate lease execution for minerals not specifically reclassified as major minerals by central notification.

The petitioner, a registered partnership firm, applied for a mining lease for 'Quartz' and 'Silica Sand' over 10 hectares.

Provisional lease was granted for 30 years on 28/07/2022, and the petitioner completed various formalities, including obtaining SEIAA permission (21/03/2023) and an approved mining plan (20/12/2022).

Possession was handed over on 23/12/2022.

On 07/03/2024, the Director of Mining ordered 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 window, citing the Model Code of Conduct (16/03/2024 to 06/06/2024).

Consequently, the Mining Officer revoked the grant on 05/09/2024.

Appeals to the Director and the State Government were dismissed.

During the litigation, a Central Government notification dated 20/02/2025 reclassified 'Quartz' from a minor mineral to a major mineral.

1. Whether the revocation of the mining lease grant was valid despite the intervention of the Model Code of Conduct during the three-month execution window.

2. Whether the reclassification of minerals via the Gazette Notification dated 20/02/2025 legally precludes the State from executing lease deeds for Quartz and Silica Sand.

The court primarily applied the M.P. Minor Mineral Rules, 1996, specifically Rule 26 regarding the revocation of grants for failure to execute lease deeds.

It also relied on the Mines and Minerals (Development and Regulation) Act, 1957, specifically Section 3, which empowers the Central Government to notify and classify minerals.

The court noted the legal transition of 'Quartz' from Schedule V of the 1996 Rules (Minor Minerals) to the status of a 'Major Mineral' via the Gazette Notification dated 20/02/2025.

Regarding 'Quartz', the court reasoned that since the Central Government’s notification deleted it from the minor mineral list and reclassified it as a major mineral, the State Government lost its jurisdiction to execute a minor mineral lease for it.

For 'Silica Sand', the court found the legal status "hazy" as the notification specifically deleted Quartz but was unclear regarding Silica Sand.

The court observed that while the petitioner was delayed in executing the deed, the State failed to sufficiently investigate if the delay was attributable to administrative engagement in election duties during the Code of Conduct.

The court determined that the authorities must verify the current classification of Silica Sand and whether the delay was caused by the State’s own inaction before revoking the grant for that specific mineral.

However, it partially allowed the petition regarding 'Silica Sand', setting aside the State Government’s orders dated 28/07/2025 and 29/07/2025.

The matter was remanded to the State Government to adjudicate: (a) whether Silica Sand remains a minor mineral, and (b) whether the delay in execution was attributable to the State.

The State is directed to pass a fresh order regarding Silica Sand.