Statutory reservation of mineral land upheld; executive assurances could not compel mining leases against valid public sector exploitation policy.

The statutory reservation of the Ghatkuri iron ore area for public sector exploitation was upheld as consistent with the State's proprietary power over mines and minerals and the mining statute. The Court held that the 1962, 1969 and 2006 notifications were valid, and that executive assurances, recommendations, or memoranda did not create an enforceable right to a mining lease contrary to that reservation. Promissory estoppel, legitimate expectation, and desuetude could not override a valid statutory policy or compel action prohibited by law. The State was therefore entitled to withdraw overlapping recommendations, and the Central Government was justified in rejecting the related lease proposals.

---

---

Issues: (i) whether the 1962, 1969 and 2006 notifications reserving the Ghatkuri iron ore area for public sector exploitation were valid; (ii) whether the appellants could invoke promissory estoppel, legitimate expectation, or desuetude to compel grant of mining leases; (iii) whether the State Government validly withdrew its recommendations and the Central Government validly rejected the proposals.

Issue (i): whether the 1962, 1969 and 2006 notifications reserving the Ghatkuri iron ore area for public sector exploitation were valid.

Analysis: The reservation of mineral-bearing land was held to flow from the State's ownership of the mines and minerals vested in it, and the regulatory scheme under the mining law did not divest that ownership. The declaration in the central mining statute was construed as limiting State legislative power only to the extent covered by the statute, but not as destroying the State's proprietary power to reserve its own minerals for public sector exploitation. The earlier notifications were treated as consistent with the statutory framework, and the later notification was treated as a prospective reaffirmation of the existing reservation.

Conclusion: The notifications were held valid, and the challenge to them failed.

Issue (ii): whether the appellants could invoke promissory estoppel, legitimate expectation, or desuetude to compel grant of mining leases.

Analysis: The memoranda of understanding and recommendations were held not to create an enforceable promise to grant mining leases contrary to the statutory reservation. Equity could not be used to compel an act prohibited by law or inconsistent with public interest. The doctrine of legitimate expectation could not override a decision taken under law in the public interest. The plea of desuetude also failed because mere non-use of the notifications did not amount to repeal, and no long-established contrary practice was shown.

Conclusion: None of these doctrines entitled the appellants to relief.

Issue (iii): whether the State Government validly withdrew its recommendations and the Central Government validly rejected the proposals.

Analysis: Once the areas were found to be reserved, the State Government was entitled to withdraw proposals that overlapped the reserved areas, and the Central Government was justified in rejecting the corresponding applications. No vested or fundamental right to a mining lease existed in favour of the applicants, and the administrative action was held to be in furtherance of the statutory policy.

Conclusion: The withdrawal and rejection were upheld.

Final Conclusion: The statutory reservation of the iron ore area for public sector exploitation was sustained, and the appellants were found not entitled to any mining lease or ancillary relief.

Ratio Decidendi: Where mineral-bearing land vests in the State, the State may reserve it for public sector exploitation consistently with the mining statute, and no applicant has a vested right to compel grant of a mining lease contrary to such valid reservation or on the basis of an unenforceable executive assurance.

---