BAIJNATH KEDIA vs STATE OF BIHAR & ORS.

The Supreme Court held that the Bihar Legislature lacked jurisdiction to enact the second proviso to Section 10(2) of the Bihar Land Reforms Act, 1950, as the field was already covered by Section 15 of the Mines and Minerals (Regulation and Development) Act, 1957. The Court clarified that Entry 54 of List I of the Seventh Schedule grants the Union power over mines and minerals, while Entry 23 of List II allows States to legislate subject to Union control. Consequently, the Bihar Minor Minerals Concession Rules, 1964 were declared invalid for lack of legislative support, affirming the supremacy of central legislation in this domain.