THE LODNA COLLIERY CO. LTD. vs BHOLA NATH ROY

The Supreme Court determined that individuals with whom resumed invalid Lakhraj land was permanently settled possess rights to the sub-soil minerals, akin to those of Zamindars. The Court held that such rights extend to the sub-soil minerals of the land held by them, thereby affirming the plaintiffs' proprietary rights against the defendant company, which had wrongfully extracted coal from the land. The judgment referenced prior cases, including Ranjit Singh v. Kali Dasi Debi (1917) and others, but found them inapplicable to the current matter.