Statutory relaxation power upheld where special-case departures are tied to recorded reasons, public interest, and mineral development.

Rule 39 of the Tamil Nadu Minor Mineral Concession Rules, 1959 was upheld as a valid relaxation provision because it operated only in special cases, required recorded reasons, and was tied to the objective considerations of mineral development and public interest. The statutory scheme under the Mines and Minerals (Regulation and Development) Act, 1957 showed that these considerations were sufficiently definite and that the power remained subject to judicial review. The rule was therefore not arbitrary, unguided, or uncanalised, and did not require reading down to preserve its validity. The challenge under Article 14 failed, while any individual exercise of the power could still be examined on its own merits.

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Issues: Whether Rule 39 of the Tamil Nadu Minor Mineral Concession Rules, 1959 conferred arbitrary, unguided and uncanalised power on the State Government and was therefore unconstitutional under Article 14 of the Constitution of India; and whether the rule required to be read down to sustain its validity.

Analysis: Rule 39 empowered the State Government, in special cases and for reasons to be recorded in writing, to grant or renew quarry leases on terms and conditions different from those in the rules where it considered such action necessary in the interest of mineral development and public interest. The statutory scheme of the Mines and Minerals (Regulation and Development) Act, 1957, including the power delegated under Section 15(1) and the relaxation power recognised in Section 31, showed that mineral development and public interest were the governing considerations. Those expressions were held to be definite and objective enough, especially when the exercise had to be supported by recorded reasons and remained open to judicial review. The rule was also treated as a permissible relaxation provision consistent with the overall scheme of regulation, and not as a provision warranting restrictive reading down merely because it allowed departure from the general rules.

Conclusion: Rule 39 was held valid and not violative of Article 14. The challenge to the rule failed.

Final Conclusion: The judgment of the High Court striking down Rule 39 and setting aside leases granted under it was reversed, and the validity of the relaxation power was upheld, while leaving open challenge to any individual exercise of that power on its own merits.

Ratio Decidendi: A statutory relaxation power framed with objective criteria, a requirement of recorded reasons, and a nexus to public interest and mineral development is not invalid merely because it permits departure from the general rule in special cases.

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