Statutory renewal power and promissory estoppel supported second mining lease renewals where the State had induced reliance.

Section 8(3) of the Mines and Minerals (Development and Regulation) Act, 1957 remained available for second renewal of mining leases, because the Supreme Court's Goa mining ruling was read as restricting only mining beyond deemed extension and first renewal, not as nullifying the statutory renewal power. Where the State had processed renewal applications, approved mining plans, relied on Indian Bureau of Mines reports, issued enhanced stamp duty demands and accepted payment, its conduct amounted to a clear representation supporting promissory estoppel and legitimate expectation. On that basis, completed renewal cases were to proceed to execution of lease deeds, while pending matters still required prompt decision under the statutory framework.

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Issues: (i) Whether the Supreme Court judgment in the Goa mining matter barred execution of second renewal lease deeds under Section 8(3) of the Mines and Minerals (Development and Regulation) Act, 1957. (ii) Whether the petitioners were entitled to execution of second renewal lease deeds or a decision on pending renewal applications on the basis of promissory estoppel and legitimate expectation.

Issue (i): Whether the Supreme Court judgment in the Goa mining matter barred execution of second renewal lease deeds under Section 8(3) of the Mines and Minerals (Development and Regulation) Act, 1957.

Analysis: The judgment held that the Supreme Court had ruled only that mining beyond the period of deemed extension and first renewal under Section 8(2) read with Rule 24A was illegal after 2007. It further held that Section 8(3) was neither struck down nor rendered inoperative, and that renewal under that provision remains available where the State Government records reasons and forms the requisite opinion in the interest of mineral development. The expression "fresh leases" in the Supreme Court judgment was treated as consistent with renewal being a fresh grant. On that basis, the Court concluded that the Supreme Court judgment did not prohibit action under Section 8(3).

Conclusion: The Supreme Court judgment was not a bar to execution of second renewal lease deeds under Section 8(3).

Issue (ii): Whether the petitioners were entitled to execution of second renewal lease deeds or a decision on pending renewal applications on the basis of promissory estoppel and legitimate expectation.

Analysis: The Court found that the State Government had processed the renewal applications, approved mining plans, obtained and acted upon the Indian Bureau of Mines report, issued demand notices for enhanced stamp duty, and in several cases accepted payment. These actions amounted to a clear representation that second renewal would be granted, and the petitioners altered their position by paying substantial stamp duty. Applying the doctrine of promissory estoppel, and noting the corresponding legitimate expectation created by the State's conduct, the Court held that the State could not resile from its promise. For cases where stamp duty had not been paid and final renewal action had not been completed, the applications still required a decision under Section 8(3).

Conclusion: The petitioners who had paid stamp duty were entitled to execution of lease deeds, and the remaining petitioners were entitled to expeditious decisions on their renewal applications.

Final Conclusion: The writ petitions succeeded in part: completed renewal cases were to be carried through by execution of lease deeds, while pending renewal matters were to be decided promptly under the statutory renewal framework.

Ratio Decidendi: A statutory renewal power that remains on the book and is supported by governmental representations and acceptance of consideration cannot be denied by invoking an earlier judgment that did not nullify that power, and promissory estoppel applies where the promisee has altered position on the faith of the State's conduct.

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