JANAPADA SABHA, CHHINDWARA ETC. vs THE CENTRAL PROVINCES SYNDICATE LTD. AND ANR.ETC.

The Supreme Court examined the validity of the Madhya Pradesh Koyala Upkar (Manyatakaran) Adhinayam, 1964, specifically Section 3(1), which sought to validate the enhanced cess imposed by the Independent Mining Local Board, Chhindwara. The Court held that the Act did not legally validate the enhanced cess as it did not disclose the nature of amendments to the original Act of 1920, and could not repeal Section 51(2) which applies to all Boards. The Court concluded that the legislature cannot override a court's judgment without explicit language in a taxing statute, thus the enhanced levy remained invalid.