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M/s Haryana Mining Company vs. State of Haryana & Ors.

Civil Appeal · 2022 INSC 541Decided 9 May 2022
Civil Appeal No. 3795 of 2022
L. Nageswara Rao · B.R. Gavai

Background

Haryana Mining Company won an e-auction and was granted a mining lease for stone and associated minor minerals in a village in Mahendargarh district, Haryana, starting operations in 2016. Following complaints of illegal mining beyond the leased area, the Director General of Mines and Geology, Haryana terminated the company's lease in 2020, and an appellate authority upheld the termination. The Punjab and Haryana High Court dismissed the company's challenge to both orders. The company appealed to the Supreme Court.

Decision Breakdown

The Supreme Court allowed the appeal and set aside the termination order, the appellate order, and the High Court's judgment. It found that the termination was arbitrary and unreasonable because the authorities had ignored a report from the Divisional Forest Officer that had specifically examined the same allegations and found no evidence against the company, while relying instead on inconclusive reports that could not identify who had actually carried out the illegal mining. The Court reiterated that while constitutional courts do not ordinarily reassess the sufficiency of evidence in administrative decisions, they will intervene where a decision is not supported by any real evidence at all or is contrary to the weight of the evidence, making it perverse.

Lesson Learnt

A government authority cannot cancel a licence or lease based on selective reliance on inconclusive material while ignoring a favourable, more thorough investigative report on the very same allegation: such one-sided decision-making is legally unsustainable and can be struck down by courts even though they generally avoid reweighing evidence.

Official source (sci.gov.in)View Judgment (PDF)

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