AMBICA QUARRY WORKS & ANR. vs STATE OF GUJARAT & ORS.

The Supreme Court held that the renewal of mining leases under Rule 18 of the Gujarat Minor Mineral Rules, 1966, is not a matter of right after the enactment of the Forest (Conservation) Act, 1980. The Court clarified that while the words 'may be renewed' could imply a duty, the context of the 1980 Act, which requires prior approval from the Central Government for any non-forest use, prevails. Consequently, the appellants' applications for lease renewal were rightly rejected as they could not claim renewal post the 1980 Act's implementation.