Statutory extension under Section 8A MMDR Act is inapplicable to mining leases rejected or lapsed before the 2015 Amendment.

The petitioner, a mining firm, held a limestone lease over 12.347 hectares in Satna, originally granted in 1975 for 20 years

In 1991, the State raised royalty demands which were disputed; the lease was determined in 1992 but restored in 1994 by a Revisional Authority with directions for verification

Prior to the lease expiry in 1995, the petitioner applied for renewal

Between 1997 and 2003, the State issued multiple notices for outstanding royalty (Rs. 7,43,682/-) and document submission, to which the petitioner allegedly failed to respond

Consequently, the State rejected the renewal and determined the lease on 09.08.2004

A revision against this was dismissed on 30.04.2010

A subsequent review application remained pending for ten years and was dismissed on 24.08.2021 as non-maintainable under the 2016 Mineral Rules

The petitioner challenged these orders under Article 226

1. Whether the Revisional Authority erred in upholding the State’s 2004 order rejecting the lease renewal due to non-compliance with royalty demands and notices

2. Whether the review application filed under the 1960 Rules could be rejected as non-maintainable following the implementation of the 2016 Concession Rules

3. Whether the petitioner was entitled to a statutory extension of the lease under the Mines and Minerals (Development and Regulation) Amendment Act, 2015

Section 8A of the Mines and Minerals (Development and Regulation) Act, 1957 (as amended in 2015), which provides for the extension of lease periods but specifically excludes cases where renewal has already been rejected or the lease determined

Minerals (Other Than Atomic and Hydrocarbons Energy Minerals) Concession Rules, 2016, regarding the maintainability of review proceedings

the principle from Savita Rawat v. State of Madhya Pradesh (W.P. No. 4278 of 2001) that renewal of a mining lease is not a vested right but subject to the fulfillment of statutory conditions and the payment of public dues

The Court found that the petitioner was afforded multiple opportunities to settle dues and complete the renewal application via notices issued between 1997 and 2003, yet failed to comply or provide evidence of non-receipt

This compliance failure negated the claim of violation of natural justice

Regarding the 2015 Amendment, the Court observed that Section 8A(9) bars the application of statutory extensions to leases where renewal had already been rejected or the lease determined prior to the amendment

Since the petitioner's lease was determined in 2004 and had remained non-operational since 1997 without an approved mining plan, the 2015 benefits did not accrue

the Court upheld the dismissal of the review application, noting that the change in the regulatory framework (2016 Rules) effectively removed the maintainability of the review under the old 1960 Rules

The Court affirmed that the 2015 Amendment Act did not apply to leases already rejected or determined

No jurisdictional error or perversity was found in the orders dated 30.04.2010 and 24.08.2021

No order as to costs was made