NEW SATGRAM ENGINEERING WORKS & ANR. vs UNION OF INDIA & ORS. AND VICE VERSA

The Supreme Court held that disputes regarding property rights related to coal mines, specifically the definition of 'mine' under Section 2(h) of the Coal Mines (Nationalisation) Act, 1973, must be adjudicated in civil court rather than under Article 226 of the Constitution. The Court dismissed the appeal of New Satgram Engineering Works and allowed the Union of India's appeal, emphasizing that serious questions of title cannot be resolved in writ proceedings. The judgment clarifies that the definition of 'mine' is broader than that in the Mines Act, 1952, as per the Nationalisation Act.