THE MINERAL DEVELOPMENT LTD., CALCUTTA vs THE UNION OF INDIA AND ANOTHER.

The Supreme Court held that the definition of 'Mining lease' under Section 3(d) of the Mines and Minerals (Regulation and Development) Act, 1948, encompasses sub-leases, clarifying that a mining lease includes leases executed by both proprietors and lessees. The Court ruled that the Mineral Concession Rules, 1949, apply to sub-leases made after the Act's enforcement, affirming that the nature of the transfer remains unchanged regardless of the lessor's status as a lessee. The appeal was dismissed, upholding the lower court's decision.