North Eastern Coalfields Coal India Ltd vs Mubarak Ali & Ors

The Supreme Court held that the definition of 'Mine' under Section 2(h) of the Coal Mines (Nationalization) Act, 1973 is crucial in determining the rights of the appellant, a successor-in-interest of the Assam Railways and Trading Company Ltd. The Court found that the Division Bench of the Gauhati High Court erred in reversing the Single Judge's decision, which had upheld the appellant's status as a lessee and the legality of the land's declaration as 'Sarkari'. The Court reinstated the Single Judge's order, emphasizing that the appellant had paid land revenue and thus could not be declared in default without proper procedure.