THE AMALGAMATED COALFIELDS LTD. AND OTHERS vs THE JANAPADA SABHA, CHHINDWARA

The Supreme Court upheld the validity of the coal tax imposed by the Independent Mining Local Board under Section 51 of the Central Provinces Local Self-Government Act, 1920, ruling that the Act had received the necessary assent from the Governor-General, thus satisfying Section 80A(3) of the Government of India Act, 1915. The Court clarified that subsequent amendments to the Government of India Act did not affect the validity of the 1920 Act. It also held that the levy of the coal tax was within the powers of the local authority and remained valid even after the enactment of the Government of India Act, 1935, and the Constitution of India, citing Section 143 of the 1935 Act and Article 227 of the Constitution.