Mineral regulation and field occupation bar State sale and disposal restrictions inconsistent with the central statutory regime.

Parliament's occupation of the mines and minerals field under the 1957 Act and the Central conservation rules left no room for a State executive policy that added sale, priority and disposal restrictions on iron ore fines, overburden and other waste materials. The statutory lease framework in Form K recognised the lessee's rights to process, carry away and dispose of minerals, while the conservation rules addressed proper deposition and disposal of fines, rejects and tailings to prevent environmental harm. A State policy inconsistent with that regime was beyond competence and without authority of law.

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Issues: Whether the State Government had authority to issue a policy decision permitting disposal and sale of iron ore fines, overburden and other waste materials subject to restrictions, and whether such decision was contrary to the Mines and Minerals (Development and Regulation) Act, 1957 and the Mineral Conservation and Development Rules, 1988.

Analysis: The central legislative field in relation to mines and minerals stood occupied by the declaration under Section 2 of the Mines and Minerals (Development and Regulation) Act, 1957, and the relevant regulatory regime, including the conservation and development rules framed by the Central Government, governed the subject. The statutory lease deed in Form K and the rules recognized the lessee's right to process, carry away and dispose of minerals, including fines, while Rule 33(6) dealt with proper deposition and disposal of fines, rejects and tailings to prevent environmental harm. The impugned policy decision introduced conditions relating to the sale, priority of supply, and disposal of fines, which went beyond the State's competence and trench upon the field occupied by the Central enactment and rules. The Court also found that the State's earlier restrictive order and the subsequent policy decision were not supported by authority of law.

Conclusion: The State Government had no authority to impose the impugned restrictions, and the challenged policy decision was illegal and without jurisdiction.

Final Conclusion: The writ petition failed on merits, and the impugned State action was held to be unsustainable in law.

Ratio Decidendi: Where Parliament has occupied the field of regulation and conservation of mines and minerals, a State Government cannot by executive policy impose sale or disposal restrictions inconsistent with the statutory regime and the statutory lease conditions.

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