Coal pricing deregulation upheld: interim price notification, differential linked-consumer pricing, and refund denial all sustained.

Coal pricing deregulated under the applicable control order left the coal company with statutory competence to notify interim prices, and the earlier direction to form an expert committee did not suspend that power. The Supreme Court upheld the 20% higher notified price for linked consumers in the non-core sector, holding that they were not similarly situated to core sector consumers and that the classification had a rational nexus with sustaining supply and the public sector undertaking's operational capacity; the Article 14 challenge failed. The refund claim also failed because the policy was valid and the respondents did not establish on reliable material that the burden had not been passed on, so unjust enrichment barred recovery.

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Issues: (i) whether the appellant had the authority to notify the Interim Coal Policy; (ii) whether the 20% increase in the notified price for linked consumers of the non-core sector violated Article 14; (iii) whether the respondents were entitled to refund of the 20% additional amount.

Issue (i): whether the appellant had the authority to notify the Interim Coal Policy.

Analysis: Price regulation of coal had been deregulated under the applicable control order, and the earlier decision striking down the e-auction mechanism did not divest the coal company of its statutory competence to notify interim prices. The direction to constitute an expert committee was directed to evolve a viable distribution policy, not to disable the coal company from fixing prices in the interregnum. Reading that judgment as imposing such a restriction would impermissibly override the statutory scheme and trench upon the separation of powers.

Conclusion: The appellant had the authority to notify the Interim Coal Policy.

Issue (ii): whether the 20% increase in the notified price for linked consumers of the non-core sector violated Article 14.

Analysis: The linked consumers of the core sector and the non-core sector were not similarly situated for the purpose of coal pricing. The linkage system was an administrative arrangement for supply logistics and did not create a constitutional entitlement to identical pricing. The classification between core and non-core linked consumers bore a rational nexus to the objective of sustaining coal supply and maintaining the financial capacity of the public sector undertaking to operate, maintain and develop coal mines. Reasonable profit, when directed to the common good and continued supply, was not forbidden; the policy was not shown to be a mere profiteering measure.

Conclusion: The 20% increase did not violate Article 14 and was valid.

Issue (iii): whether the respondents were entitled to refund of the 20% additional amount.

Analysis: The claim for refund could not succeed where the policy itself was upheld. In any event, the respondents failed to establish with complete and reliable material that they had not passed on the burden of the additional cost to end consumers. Refund of public money cannot be ordered on an incomplete evidentiary foundation, and the doctrine of unjust enrichment was applicable in principle to such a claim.

Conclusion: The respondents were not entitled to refund of the 20% additional amount.

Final Conclusion: The Interim Coal Policy was held valid, the challenge to the 20% price increase failed, and the refund claim was rejected.

Ratio Decidendi: Where coal pricing is deregulated by statute, the coal company may notify interim prices in the interregnum, and a differential price between core and non-core linked consumers is constitutionally valid if it rests on a rational nexus with the legitimate objective of maintaining supply and the common good rather than on arbitrary profiteering.

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