Mining lease applications create no vested right; the State may amend allotment rules and apply revised procedure to pending claims.

A pending application for a mining lease over Government land does not create a vested right or an enforceable legitimate expectation. The State may amend the mineral concession regime in public interest, including by replacing a first-come first-served process with auction and applying the amended rules to pending applications. The impugned amendments were upheld as valid because they were made under the parent Act's rule-making power, were not shown to be colourable or malicious, and did not breach natural justice merely because no individual hearing preceded the policy change. Earlier High Court directions did not freeze the pre-existing regime or confer a perpetual right to disposal under it.

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Issues: (i) Whether pending applications for mining leases over Government land conferred any vested right or enforceable legitimate expectation so as to prevent amendment of the leasing rules and to require disposal under the earlier regime. (ii) Whether the impugned amendments introducing delineation, auction and rejection of pending applications were invalid for want of hearing, legal malice, or inconsistency with earlier High Court directions.

Issue (i): Whether pending applications for mining leases over Government land conferred any vested right or enforceable legitimate expectation so as to prevent amendment of the leasing rules and to require disposal under the earlier regime.

Analysis: A mere application for grant of a mining lease does not create any vested right. The Government retains regulatory control over mineral resources and may change the mode of grant in public interest, including by substituting a first-come first-served process with auction. Legitimate expectation does not override a lawful policy change, and it cannot be used to compel grant of a lease or to freeze the rules in force when the application was made.

Conclusion: The issue is answered against the applicants and in favour of the State.

Issue (ii): Whether the impugned amendments introducing delineation, auction and rejection of pending applications were invalid for want of hearing, legal malice, or inconsistency with earlier High Court directions.

Analysis: The amendments were made under the rule-making power conferred by the parent Act and were intended to introduce a revised and more transparent allotment mechanism. The earlier High Court directions did not confer a perpetual right to have all pending applications decided under the old regime, and the impugned rules were not shown to be a colourable exercise of power or a deliberate attempt to defeat any accrued legal right. Since no vested right existed in the applicants, the absence of individual hearing before amendment did not invalidate the rule-making exercise.

Conclusion: The impugned amendments are valid and are not vitiated by legal malice or breach of natural justice.

Final Conclusion: The challenge to the amended mining rules fails, and the State was competent to the revised leasing procedure to pending applications.

Ratio Decidendi: A pending application for a mining lease does not confer a vested or enforceable right, and the competent Government may amend the mineral concession regime in public interest and apply the rules in force at the time of disposal.

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