NCLT jurisdiction over mining lease disputes is excluded where the issue concerns statutory decisions under the MMDR framework.

The NCLT has no jurisdiction to direct execution of supplemental lease deeds for extension of a mining lease under the Mines and Minerals (Development and Regulation) Act, 1957, where the dispute concerns decisions of statutory or quasi-judicial authorities under that regime. The proper remedy in such matters lies in judicial review of administrative action, not in proceedings before the NCLT. On that basis, the order directing execution of supplemental lease deeds and treating the State Government's rejection of deemed extension as null and void was held unsustainable and was set aside.

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Issues: Whether the National Company Law Tribunal had jurisdiction to direct execution of supplemental lease deeds for extension of a mining lease under the Mines and Minerals (Development and Regulation) Act, 1957, and whether the State Government's order rejecting deemed extension could be displaced in such proceedings.

Analysis: The binding Supreme Court decision had already held that the NCLT could not adjudicate disputes arising under the MMDR Act and the rules made thereunder, particularly where the controversy related to decisions of statutory or quasi-judicial authorities. The proper remedy lay in judicial review of administrative action, and the NCLT's assumption of jurisdiction was therefore without legal authority.

Conclusion: The NCLT order directing execution of supplemental lease deeds and declaring the State Government's order null and void was unsustainable and was set aside.

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