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Supreme Court of India 2024-08-14 partly_allowed

Mineral Area Development Authority & Anr vs M/S Steel Authority of India & Anr Etc

Bench: CB — Dhananjaya Y Chandrachud, Hrishikesh Roy, Abhay S Oka, J B Pardiwala, Manoj Misra, Ujjal Bhuyan, Satish Chandra Sharma, Augustine George Masih

In Brief

In this Constitution Bench judgment, the Supreme Court addressed whether its recent decision in MADA v. Steel Authority of India—which overruled the 35-year-old India Cement precedent on mineral taxation—should apply retroactively or prospectively. The Court rejected prospective application, holding that overruling settled law while upholding State legislative competence would be unjust. Instead, using powers under Article 142, the Court imposed tailored relief: tax demands shall not apply to transactions before 1 April 2005, payment shall be staggered over twelve years from 2026, and all interest and penalties for demands made before 25 July 2024 are waived. This pragmatic solution balances State revenues with fairness to parties who relied on the overruled law.

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Constitutional Law Tax Law Minerals Taxation Prospective Overruling Article 142 Judicial Discretion Equitable Relief Federalism

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