MINERAL AREA DEVELOPMENT AUTHORITY & ANR. versus M/S STEEL AUTHORITY OF INDIA & ANR. ETC.

Citation: [2024] 8 S.C.R. 540 · Decided: 14-08-2024 · Supreme Court of India · Bench: D.Y. CHANDRACHUD · Disposal: Directions issued

Cited by 5 judgment(s) · cites 21 · see the full citation network in Lexace

Judgment (excerpt)

[2024] 8 S.C.R. 540 : 2024 INSC 607
Mineral Area Development Authority & Anr. 
v.  
M/s Steel Authority of India & Anr. Etc.
(Civil Appeal No. 4056-4064 of 1999)
14 August 2024
[Dr. Dhananjaya Y. Chandrachud,* CJI, Hrishikesh Roy, 
Abhay S. Oka, J.B Pardiwala, Manoj Misra, Ujjal Bhuyan, 
Satish Chandra Sharma and Augustine George Masih, JJ.]
Issue for Consideration
Whether the 9-judge bench judgment in Mineral Area Development 
Authority v. M/s Steel Authority of India & Anr. Etc 2024 INSC 554 
be given prospective effect?
Headnotes†
Constitution of the United States – Evolution of Doctrine of 
Prospective Overruling – Objectives and Purpose – Factors 
to be considered for its applicability – Discussed:
Held: The doctrine of prospective overruling is applied when a 
constitutional court overrules a well-established precedent by 
declaring a new rule but limits its application to future situations – 
The underlying objective is to avert injustice or hardships, per Great 
Northern Railway Co. v. Sunburst Oil and Refining Co., 287 US 358 
(1932) – Relied on Linkletter v. Walker, 381 US 618 (1965) to hold 
that the doctrine was applied by the courts in the US on the basis 
that the US Constitution “neither prohibits nor requires retroactive 
effect.” – US Supreme Court identified three separate factors to be 
considered while deciding the applicability of prospective overruling 
in Chevron Oil Company v. Huson 404 US 97 (1971): (i) the decision 
to be applied prospectively must establish a new principle of law, 
either by overruling clear past precedent on which litigants may have 
relied, or by deciding an issue of first impression whose resolution 
was not foreshadowed; (ii) the court must weigh the merits and 
demerits in each case by looking to the prior history of the rule in 
question,its purpose and effect, and whether retrospective operation 
will further or retard the operation of the rule; and (iii) whether the 
application of nonretroactivity avoids substantial inequitable results, 
injustice or hardships. [Paras 5, 6]
* Author
[2024] 8 S.C.R. 
541
Mineral Area Development Authority & Anr. v.  
M/s Steel Authority of India & Anr. Etc.
Constitution of India – Article 142 – Application of the Doctrine 
of Prospective Overruling in India – Explained:
Held: Relying on Golak Nath v. State of Punjab [1967] 2 SCR 762, 
held that the doctrine of prospective overruling can be invoked only 
in matters arising under the Constitution and that it can be applied 
only by the Supreme Court as it has the constitutional jurisdiction 
to declare law binding on all the courts in India – The scope of 
the retroactive operation of the law is left to the discretion of the 
Supreme Court to be moulded in accordance with the justice of 
the cause or matter before it – The power of the Supreme Court to 
mould the relief claimed to meet the justice of the case is derived 
from Article 142 – It is applied by the Supreme Court while overruling 
its earlier decision, which was otherwise final – It has also been 
applied when deciding on an issue for the first time. [Paras 9, 10]
Principles emerging from application of Doctrine of Prospective 
Overruling – Discussed:
Held: The doctrine of prospective overruling has been accepted 
by the Supreme Court and the following principles emerge from 
the application of doctrine of prospective overruling – The power 
of the Supreme Court to mould the relief claimed to meet the 
justice of the case is derived from Article 142 – It is applied by 
the Supreme Court while overruling its earlier decision, which was 
otherwise final – It has also been applied when deciding on an 
issue for the first time – The object is to validate all the actions 
taken before the date of declaration in the larger public interest – 
The doctrine does not validate an invalid law, but the declaration 
of invalidation takes effect from a future date – Cases that have 
attained finality are saved because doing otherwise would cause 
unnecessary and avoidable hardships – It is applied to bring about 
a smooth transition of the operation of law without unduly affecting 
the rights of the people who acted upon the overruled law – It is a 
device innovated to avoid: (i) reopening settled issues, (ii) refund of 
amounts collected under invalid legislation, and (iii) multiplicity of 
proceedings – It is applied to avoid social and economic disruptions 
and give sufficient time to the affected entities and institutions to 
make ap

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