Context-dependent meaning of "mineral" under mining law extends to brick-earth when notified as a minor mineral.

The term "mineral" under the Mines and Minerals (Regulation and Development) Act, 1957 is context-dependent and has no fixed technical meaning. In that statutory setting, substances such as ordinary clay and ordinary sand show that earth-derived materials used for construction may fall within the wider expression "any other mineral" if notified. On that reasoning, brick-earth was treated as covered by the Act and capable of being declared a minor mineral, while the contrary English authorities were distinguished because they arose under different statutory contexts.

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Issues: Whether brick-earth is a mineral capable of being declared a minor mineral under Section 3(e) of the Mines and Minerals (Regulation and Development) Act, 1957.

Analysis: The expression "mineral" was held to have no fixed or technical meaning and to take colour from the statutory context. Since Section 3(e) includes ordinary clay and ordinary sand, the statutory scheme showed that substances taken from the earth used in construction-related purposes could fall within the wider expression "any other mineral" if declared by notification. On that basis, brick-earth was treated as sufficiently covered by the word "mineral" in the setting of the Act, and the contrary English authorities were distinguished on the ground that they turned on different statutory contexts.

Conclusion: Brick-earth is a mineral for the purposes of Section 3(e) and can validly be notified as a minor mineral. The finding is against the appellant and in favour of the respondents.

Ratio Decidendi: The word "mineral" in the Mines and Minerals (Regulation and Development) Act, 1957 is context-dependent and of sufficient amplitude to include brick-earth, so long as the substance answers that description within the statutory setting and is notified as a minor mineral.

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