Shibam Talukdar, Assistant Professor of Law (Senior Scale) at UPES School of Law, Dehradun
ABSTRACT
The Supreme Court judgment in Mineral Area Development Authority & Anr. v. M/S Steel Authority of India & Anr. (2024 INSC 554) addresses critical issues of federalism, resource governance, and taxation. This landmark decision clarified the constitutional interplay between Union and State legislative powers over mines and minerals, while focusing on Entries 23 and 50 of List II and Entry 54 of List I in the Seventh Schedule. The Court held that royalty under the MMDR Act is not a tax but a consideration for the right to extract minerals. It further emphasised that State-imposed taxes on mineral-bearing lands must not measure tax liability based on extracted mineral values, as this would conflict with Union prerogatives. Reaffirming the Union’s primacy in regulating minerals, the judgment underscores cooperative federalism, sustainable resource management, and intergenerational equity. It provides a crucial precedent for balancing economic development with constitutional limitations and environmental stewardship.
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