STATE OF MADHYA PRADESH & ANR. vs DADABHOY'S NEW CHIRIMIRI PONRI HILL COLLIERY CO. PVT. LTD.

The Supreme Court examined the applicability of Section 9(1) and Section 30A of the Mines & Minerals (Regulation and Development) Act, 1957, regarding the royalty rates for pre-1949 coal mining leases. The Court held that the Central Government's notification under Section 30A, which modified the royalty rate to 2.5% or as per the lease agreement, was valid and enforceable. Consequently, the demand for arrears of royalty by the Collector was upheld, affirming the government's authority to modify royalty rates through notification.