Quasi-judicial revision under mineral law requires fairness, but written representation may suffice and no final lease arose without approval.

Revisional powers under the Mineral Concession Rules were treated as quasi-judicial, so the authority was expected to hear the parties and consider the State Government's comments, but a written representation could satisfy natural justice and no reversible breach was found on the record. The dispute also confirmed that a mining lease could not be finally granted by the State without prior Central Government approval, so the earlier State order was only a recommendation and not a completed grant. Section 17 of the Mines and Minerals Act was held inapplicable because it concerns Central Government operations in areas not already held under a licence or lease.

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Issues: (i) whether the Central Government, acting in revision under the Mineral Concession Rules, was bound to give reasons while disposing of the revision application; (ii) whether refusal of a personal hearing and consideration of alleged extraneous material vitiated the revisional order on the ground of breach of natural justice; (iii) whether the State Government's earlier order amounted to a final grant of the mining lease and whether section 17 of the Mines and Minerals (Regulation and Development) Act, 1957 applied to the dispute.

Issue (i): whether the Central Government, acting in revision under the Mineral Concession Rules, was bound to give reasons while disposing of the revision application.

Analysis: The revisional framework under sections 13 and 30 of the Act and rules 54 and 55 of the Mineral Concession Rules, 1960 contemplates a judicially exercised revisional power. The requirement that the applicant be heard against comments received from the State Government indicates a quasi-judicial process. In the main opinion, the absence of reasons in the revisional order was treated as fatal because reasons are the safeguard against arbitrariness and enable effective supervisory review. In the separate opinion, it was held that where the State Government had already recorded reasons and the revisional authority merely agreed with them, fuller reasons were not mandatory.

Conclusion: The revisional authority was required to act judicially, but the appeal was not allowed on this ground and the impugned order was not set aside.

Issue (ii): whether refusal of a personal hearing and consideration of alleged extraneous material vitiated the revisional order on the ground of breach of natural justice.

Analysis: Rule 55 embodies the principle that no adverse order may be made without affording an opportunity to meet the comments of the State Government or other authority. That opportunity need not necessarily be by oral hearing and may be satisfied by written representation, depending on the facts. On the record, a written representation was held to be sufficient. As to the alleged subsequent public sector application, the record did not establish that the appellant was denied a fair chance to meet that material, and this point was not treated as decisive.

Conclusion: The appellant was not entitled as of right to a personal hearing, and no reversible violation of natural justice was found.

Issue (iii): whether the State Government's earlier order amounted to a final grant of the mining lease and whether section 17 of the Mines and Minerals (Regulation and Development) Act, 1957 applied to the dispute.

Analysis: A grant of a mining lease for manganese ore required previous approval of the Central Government under section 8(2) of the Act, and without such approval the State Government could not finally grant the lease. The earlier State order was therefore only capable of being treated as a recommendation. Section 17 applies where the Central Government itself proposes to undertake prospecting or mining operations in an area not already held under a licence or lease; it has no bearing where the dispute concerns State-controlled grant and renewal proceedings.

Conclusion: The earlier State order was not a final grant, and section 17 had no application.

Final Conclusion: The revisional challenge failed, and the Court declined to interfere in its discretionary appellate jurisdiction; the dismissal of the appeal was sustained.

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