A Bench of Justices Dipankar Datta and Satish Chandra Sharma has held that a mining lessee cannot claim a vested right to pay a static royalty or dead rent for the entire lease term merely because the lease deed is silent on revision, where the State's statutory power to revise such levies flows independently from Section 15 of the Mines and Minerals (Development and Regulation) Act, 1957 and rules made thereunder.
The Court set aside a 2016 Punjab and Haryana High Court judgment that had quashed a Haryana government notification enhancing royalty and dead rent on minor-mineral leases originally auctioned in 2001, allowing the State's appeals and confirming that a lease's silence on revision cannot be read as an implicit promise that the original rate would apply for the full lease term.
The ruling confirms that mining lessees across India cannot rely on silence in a lease deed to resist statutory royalty revisions, giving state governments a strong precedent to enforce revised royalty and dead-rent notifications against minor-mineral and other lessees mid-lease, regardless of what the original lease deed does or does not say about future rate changes.