S. S. GAREWAL vs MESSRS. BHOWRA KANKANEE COLLERIES

The Supreme Court held that under Section 24 of the Mines Act, 1952, a Court of Inquiry does not become functus officio upon submitting its report, allowing for subsequent quantification of expenses as per Rule 22 of the Mines Rules, 1955. The Court clarified that the order to pay expenses, even if not quantified initially, implies that quantification can occur later. Furthermore, the absence of assessors during the quantification does not invalidate the order, as it is considered a ministerial act rather than a judicial one. The appeal was dismissed, affirming the validity of the quantification order.