Mining and environmental laws in India- A Critical Analysis

Tejaswini Lala
Author:

ABSTRACT

The Indian mining industry has immense growth opportunities and its supremacy has been demonstrated to be one of the world's leading mineral suppliers, including iron, coal, zinc, bauxite, etc. India is one of the top ten producers worldwide of a range of various fuel, metal, non-metallic, and industrial mineral products. Because of the growing nature of the Indian economy, its aims for reducing poverty, and its aim to increase the demographics' living standards significantly, the mining industry has and plays a crucial role in the overall growth of the nation. The Environmental Protection Act, 1986 plays a key role in order to protect the environment from such activities. Mining activities have in many cases taken place without regard for environmental 'carrying capacity' and other infrastructural limitations. This has placed avoidable environmental pressure and caused discomfort for the miners. Minerals are frequently sold even cheaper than their value through lobbying, political donations and corruption. In certain ways, illegal mining has a similar impact, causing loss of public income in addition. According to the International monetary fund, many governments of resource-rich nations face a fall in the net value of the public sector because of unsustainable miningThe first part of the study tends to analyze the Environment Impact Assessment techniques and the issues related to it, the second part of the study deals with the National Mineral Policy, its impact and issues related to the environment in order to provide the reader with the lucid understanding of mining and the relation with the environmental laws.

Keywords: Mining, Environment Impact Assesment, National Mineral Policy, Issues

Introduction

The Indian mining industry has strict legal and regulatory regulations Government frameworks implementing a revision of cum at the central and state levels in different actions, laws, norms. Since mining is a 'highly polluting sector' posing significant environmental and social problems, the establishment of regulatory institutions and mechanisms by India has increasingly scountered the negative externalities arising from mining operations.[1]However, political and logistical obstacles, which need urgent attention, have sadly stymied the governance mechanism. Concerning the successful mining operations, underground mining (long-wall mining for coal extraction) and resource-effective surface-drilling technologies are being more and more widely used by large-scale operating procedures in the place of the traditional opencast mining approach.[2] Overall, the key to developing a sustainable mining industry moves from individual adoption to large scale adoption by the mining sector as a whole, which has to be accompanied by a comprehensive regulatory and legislative framework. While legislative and regulatory changes have resulted in many better practices, the government and industry leaders must formulate best practices to ensure the mining sector's overall viability and sustainability.[3]Although these impacts differ between the types and phases of processing of minerals, they may also have a profound influence near the project site, in surrounding areas as well as worldwide (e.g., through global warming).[4]Judiciary has always been very effective and strict in order to protect the environment from the hazardous activities of mining.[5] In the case of The Tarun Bharat Sangh vs. Union of India and Ors[6] A writ petition was filed in the Apex Court .by Tarun Bharat Singh in order to stop mining activities in the Sariska Wildlife Sanctuary. National Mineral Policy, 2019 says that Mining, though, is a small resource removal and use “natural resources, including minerals, are a shared inheritance where the state is the trustee on behalf of the people to ensure that future generations receive the benefit of inheritance.”. In addition, the government of India and the states treat the earnings from sales of minerals as income or revenue.[7]Many small mines operate in most states exist in India (including mining quarries for extraction of minor minerals). Their financial, technological and managerial shortcomings hinder their capacity to take sufficient corrections to the problems of sustainable growth.

I. Issues with the Procedure of Environment Impact Assessment (EIA) and Role of assigned Authorities.

Environment Impact Assessment (herein after referred EIA) as  is a process to assess the potential environmental effects of a proposed project or development, taking into consideration both positive and negative interrelated socio economic, cultural and public health impacts. The environmental impact assessment of India is statutory underpinned by theEnvironment Protection Act 1986 which has various provisions on EIA Framework Approach.

A. EIA In India

The Indian experience about the EIA started over 20 years ago. It began in 1976-77 when the Planning Commission ordered the Science and Technology Department to investigate the schemes in the river valley projects from the environmental perspective. By 1994, the Central Government's environmental clearance had been an administrative decision and lacked legislative support.

In accordance with the Environmental (Protection) Act 1986, on 27 January 1994 the then Union Ministry of the Environment and Forests issued an EIA notification, making it Environmental Clearance (EC) compulsory to expand, modernise any such activities or set up new projects specified in Schedule 1.[8]

A new EIA law was notified in September 2006 by “the Ministry of Environment, Forests & Climate Change”[9]

It majorly stated two points:

· “The notification makes it necessary to ensure environmental clearance for numerous projects, such as the mining, thermal power plants, river valleys, infrastructure (road, highways, port, ports and airports) industries including very small electroplating or foundry units.”

· “Unlike the 1994 EIA Notification, the new law placed the burden on the state government for clearing projects based on the project size and capabilities.”

B. EIA & Mining Laws

The Mines Act has the unique singular purpose of extracting natural resources and of protecting workers' well-being at the present time. In the basic law on mining, the EIA angle has been mostly ignored. In general, the central and state governments jointly control resources in India. The proprietary title covers the federating states, while the centre is responsible and has jurisdiction over the development of mines and minerals. In 1957 Mines and Minerals Act (MMRDA) was enact The MMRDA 1957 and the Mines Act, 1952 are the major pieces of India's mining laws. The Forest Conservation Act 1980 and the Environmental Protection Act 1986 on protection of forestry and environment coincide and apply to mining as well. In the latter stage, in the light of the doubtful record of mining industries in undermining social ecological imperatives, the Mines and Minerals (Development and Regulation) Rules of 1987 expressly included provisions of the pre- and post-EIA. The MMRDA and other legislations is led by the Government of India's National Mineral Policy (NMP), which, initially described in 1993 and subsequently reviewed in 2002 and 2008, was based on Huda Committeerecommendations. Therefore, to ensure that the development of mineral resources conforms to the national policy priorities, the MMDRA has been revised to implement the new 2008 National Mineral Policy 2008. There is a dubious record of undermining the social and ecological imperatives of mining industry in India. In accordance with safety provisions, the basic law regulating the mines apply to EIA. Under the legislative and regulatory powers of the Central Government, the EIA principles can be institutionalised. The national government may establish rules to guarantee the protection of employees working in mine, their means of entrance there into and exit there from, the number of shifts or outlets to be equipped, and the fencing of the shafts, the pit outlets and subsidy roads therein. Safety of passage through the safeguarding of roads and working areas in mines, including sitting, maintaining, extracting or reduction of pillars or mineral blocks and keeping enough baniers between mine and mine.[10]The amendment to the Act of 1887 also has a separate mining and environmental chapter. The EIA principles and practises will be taken up through these clauses.

C. EIA of Mining under Central Laws

The Ministry of Mines, the Minister of the Environment and Forestry, Ministry of Coal and the Ministry of Labour are mostly responsible for guiding mining. Ministry of Mines (MoM) is responsible for developing and implementing mining policies and strategies. Coal Controllers, various committees, the Coal Mines Provident Fund Organization, and the Commissioner of Payments Office are the bodies responsible for drafting regulations to mitigation and regulate environmental pollution and planning under the administrative control of MoC. They also promote and coordinate environmental programmes. The Regional Offices of MoEF and the Central Pollution Control Board CPCB help in the implementation of these obligations. Similarly, the Ministry of Labor (MoL) and Directorate-General for Mining Safety (DGMS) has the authority to ensure compliance on regulatory requirements on protection, health and welfare at the workplace. Any other ministries may take decisions which may have an impact on the competitiveness of the coal-based industry, but they have no direct regulatory authority for this sector. These are the Ministry of Railway (MoR), the Surface Transportation Ministry (MoST), the Ministry Of finance (MoF), the Power Ministry (MoP), Ministry of Industry (MoI) and Ministry of Steel (MoS) etc.[11]

D. EIA of Mining under State

In the States, mining operations within the respective jurisdictions will be undertaken by ministries such as the Department of Mining, the Department of Forests, the Department of Environment and the State Pollution Control Board. The Mining Department is responsible for the review of mineral title applications, monitoring compliance within the standard guidelines and collection of data. In the granting of forest clearances and prescribing of compensatory forestation the mining department has also played an important role. The Department of the Environment works mostly at a lower level, since they do not have the expertise necessary to plan and enforce policies and hence have to limit themselves to the regular budgetary functions of the State Control Boards for Pollution (SPCBs). SPCBs are broader organisations that have established the Water Act in the States, because of their traditional function. Their primary tasks are to ensure that the applicable Acts are implemented, that effluence and emission standards are established, changed or abolished, to plan and enforce policies on emissions prevention, pollution control and reduction and to advise state governments on the same.

E. EIA of Mining at Local Level

Municipalities and Panchayats are the municipal authorities that play an important role in district environmental conservation. The functions include soils conservation, land enhancement and resource conjunctive control, as well as water management. In addition, some other institutions, such as district collectors, magistrates, tax collection departments and royalties and Department of mining licence issuers perform indirect regulatory functions.

F. EIA Procedure in India

The measures mentioned below include the steps of EIA. The EIA mechanism is therefore cyclical with the association of the different phases.[12]

a) Screening- The project plans are examined for investment size, site and form of development and for a statutory clearance of project requirements.

b) Scoping- Potential impacts, impact areas, mitigating opportunities and reporting requirements of the project.

c) Collection of baseline data- Baseline information is the research area's environmental status.

d) Impact of the prediction- The project evaluation agency must be able to anticipate positive and negative, cumulative, inevitable and transient and lasting consequences that would include a clear knowledge of the project.

e) Measures of Mitigation as well as the  EIA report-The EIA study should provide actions and measures to avoid, minimise or transmit effects, or else the extent of compensation for likely harm or injury to the environment.

f) Public hearing- Public and environmental groups located near the project site will be contacted and consulted upon completion of the EIA survey.

g) Decision making Authority- The Impact Assessment Authority and the experts consult with the project in charge as well as the consultant to take the final decision and take into account EIA and EMP (Environment Management Plan).

h) Monitoring as well as implementation of the plan of management of environment -The proposal is checked at different stages of execution. Possible solutions and environmental characteristics should be defined and compared for each initiative.

i) Assessment of Alternatives- Plan site and process technology are alternatives that can protect both. Following the examination of alternate options, a Mitigation Strategy for the selected option should be drawn up and supported by an Environmental Management Plan.

j) Risk assessment- The EIA techniques also include in the inventory review and risk probability and index.

G. Issues and Challenges in EIA Of Mining

Even after the policy and legislative structures have been in place, mining in India has consistently affected the environmental situation in and near the mining areas. The mining companies' behaviour with respect to mining closure and restore shows that their legislation and practises are clearly in violation of the law and policy requirement and the sad part is that there has been no intervention against those infringements.

The key challenges in the mining EIA have been:

1. Incorrect and incomplete data as well as non-adherence of scientific methods.

2. The project proponents are confronted with a conflict of interest as they get the EIA conducted.

3.  Fabrication, repeat of ancient knowledge or skip more relevant information and facts that are vital.

4. Often public hearings are preposterous. Smaller areas (under 5 hectares) are exempt from an EIA requisite, which leads to uncontrolled mining and exploitation.

5.  Evaluation is performed tactfully in the summer when the soil is drier and more medium.

6. Water courses in EIAs are also usually ignored.

7. Poor execution and inadequate supervision have left the EIA as a mere administrative formality.

The lack of a proper coordination process between different government departments and organisations makes the proper application of environmental impact assessment standards difficult. In addition to coordination concerns, the convergence of jurisdictions has been noted, creating new problems in the application and execution of regulations. For example, the regional MoEF and SPCBs have common oversight and enforcement functions of various laws applicable to air, water, and land. In the regulation and control of various facets of coal development, regulatory bodies are evidently ineffective. The lack of trained workforce and lack of equipment supply are two key elements in its inefficiency. These considerations were underlined in discussions with a range of regulatory bodies including SPCBs, DGMS, the State Department of Transport, the State Forest Department etc. In addition, political interference was often found to be one of the key reasons behind the regulatory bodies' lack of or insufficient response to reported errors. The value of coal for power production and the serious effect on the economy due to disruptions of the coal supply are often intentionally overlooked as lapses in implementation

H. Issues related to unsustainable mining

a) Going Beyond Carrying Capability: Mining activities have in many cases taken place without regard for environmental 'carrying capacity' and other infrastructural limitations. This has placed avoidable environmental pressure and caused discomfort for the miners.

b) Loss of public income: Minerals are frequently sold even cheaper than their value through lobbying, political donations and corruption. In certain ways, illegal mining has a similar impact, causing loss of public income in addition. According to the International monetary fund, many governments of resource-rich nations face a fall in the net value of the public sector because of unsustainable mining.

c) Large-range Small Mines: Many small mines operate in most states exist in India (including mining quarries for extraction of minor minerals). Their financial, technological and managerial shortcomings hinder their capacity to take sufficient corrections to the problems of sustainable growth.

d) Growing inequality and loss of natural wealth: Of course, extractors want to extract and carry on as soon as possible. This intensifies inequality, with a few extractors gaining capital without sufficient redistribution. The loss of natural resources also occurs. For example, according to Vedanta's annual reports, Goa State has lost more than 95% of the value of its minerals over eight years (2004-2012).

II. Impact of National mining Policy (NMP) on Environment Protection

In March 2019, the Indian government established a new “National Mineral Policy (NMP)” that replaced its policies of earlier 2008. A main outcome of the recent mineral policy pertains to the non-coal and non-fuel minerals which states that the important result of the policy proposals is predicted "to increase production of major minerals by 200 percent in 7 years." The aim is linked with the existing government's initiative "Make in India" and to stimulate economic growth in India.[13]

The creation of the new NMP was driven by a guidance from the Supreme Court in August 2017 in the case of Supreme Court of India in the matter of Common Cause Vs Union of India & Others[14].

The Apex Court found that these operations ruined climate and forest, and caused much suffering to the local communities, while delivering its ruling on rapacious mining in Odisha's top mining districts (Keonjhar and Sundargarh) (the tribals in the area), The Court observed that mining activities are not effectively regulated and that there is no effective mining policy to direct that,  It was also noted that the policy of 2008 was too dated to cope with today's problems such as rapacious mining in many parts of the country, The Court then called on the Government of India to review the 2008 NMP and announce a new, more efficient and substantive scheme, The mining industry has long been involved in non-scientific mining, low environmental and social records and high levels of illegal activity, This too has been sustained by our regulatory environment, capacity and transparency of the authorities. Given this, it was a timely proposal to establish a new NMP,  It was a key chance for the country, apart from economic concerns, to come up with a policy document that will direct the mining industry to work with maximum social and environmental accountability.”

A. Characteristics of the aforesaid Policy.

· It seeks to encourage private investment by way of an incentive such as a financial package and the right to refuse first at the time of the auction etc. or any other suitable incentive in accordance to the international practices.

· Introduces the concept of “Exclusive Mining Zones with statutory clearances in principle for the grant of mining leases”.

· It simplifies the clearing process and makes it time-bound for mineral development and beginning operations. Proposals for the identification of vital fragility and declaration of areas such as 'no-go areas'/'inviolate areas'.

· Promote the merger and acquisition of mining companies and the transfer of transparently issued mining leases to ensure smooth supply of ores and the expansion of the enterprise.

· The aim is to provide stability for investment in large-scale commercial mining activity through a long-term export/import strategy for the mineral sector.

· Proposed harmonisation of mining jurisdiction worldwide in royalties, and all other levies and taxes.

· Emphasizes on the resettlement and rehabilitation of mining impacted persons and populations and the proper application of all applicable laws/regulations.

· Introduces the Inter-Generational Equity framework for the development of mineral resources.

· It proposes the creation, under the aegis of the “Ministry of Mines, of an overarching inter-ministerial body to institutionalise sustainable mining arrangements, the body will also provide advice on royalty rates, dead rent, etc. to the Government.”[15]

B. The key advantages of the National Mineral Policy, 2019 are as follows:

A business-friendly policy

“A 29-member Committee, chaired by K Rajeswara Rao, Additional Secretary of the Union Ministry of Mines, was set up by the Ministry in August 2017 in order to create the new NMP, in accordance with SC guidance”[16]the SC guided that[17]In a period of one and a half years, it is a win-win for mining companies and investors that is the policy finally established, If the document states that mining must be environmentally sustainable and equitable, significant concerns exist as to how successful this Policy can be in protecting the environment, preserving the environment and protecting people's rights in mining fields.” The new policy is largely driven by the need to 'easily doing of business ' and to draw investment with its aim to increase massively mineral production. To ensure this, a variety of methods were suggested.[18]

Establishment of exclusive mining areas and simplification in clearances

The establishment of 'exclusive mining zones' is a central initiative proposed in the NMP. These "zones" would be accompanied by approved clearances in principle to "curtail delay in commencing mining operations." “Clearance in Principle” is linked to “the forest land diversion related to non-forestry purposes”. The plan would also establish significant gaps in the achievement of successive clearances and permits for mining companies who are to be included in the exclusive mining area and in accordance with clearance and permit requirements. Altogether the effect of this initiative on forest ecology, wildlife corridors and forestry-dependent populations is seriously concerned. In reality, the policy emphasises on the simplification and speed of the clearance process for the beginning of mining operations. The Policy says that if delays occur, arrangements for "generate triggers at higher level" would be provided for the project promoter in the online clearance portal. For ease of project backers, “the method of environmental clearance (EC) and forest clearance (FC) in the past five years has been optimised and condensed (making it simple window)”. What has not been achieved, is to robustly and thoroughly improve the standard of the assessments prior to the clearance of projects. Also, the post-clearance surveillance is not been strengthened as well. There is a fractured solution to the clearance mechanism. The method is now overwhelmingly hierarchical, with no focus on environmental and social protection.

C. Issues in the National Mineral Policy, 2019 are as follows:

Deficiency in environmental pollution management

In most mining regions, environmental pollution is a big concern. This is caused by non-scientific and rampant mining, inadequate emissions and pollution monitoring levels as well as improper mining and closure management procedures. Problems related to air, water and soil contamination have seriously affected the health and living conditions in almost every major mining district in India. The Policy would not offer effective guidelines in order to change this though. For example, our environmental regulations – “the Environment (Protection) Act of 1986, the Water Act of 1974, and the Air Act (1981)”[19]– do not include precise standards in the area of mining environmental contamination. Only Pollution standards for iron-ore mining under the “Environmental Protection Rules 2010” are established for non-coal minerals. In reality, baseline surveillance data are either non-existent or exceedingly low in the majority of mining fields. In view of this, recommendations for guidelines and mechanisms for controlling emissions in mining areas should have been given in accordance with the laws in concern in the new Policy. At least for minerals that are expected to produce significantly and have a greater propensity to pollute the atmosphere, this should have been proposed.[20]

Community issues were well addressed, but can't be post scripted

The safeguarding of the health of the people impacted by mining is a more articulated aspect of the policy. In this respect, three focus was put on relief and rehabilitation for displaced and affected people, the devolution of the mining benefits to affected people through “the District Mineral Foundation (DMF)” and the protection and welfare of tribal communities. The Policy further emphasises the implementation of all recovery and rehabilitation provisions outlined in the Right to Fair Compensation and Transparency in the Land Acquisition, Rehabilitation and Resettlement (RFCTLARR) Act, 2013”.[21] But the need to ease mining and attract investors can only lead to the postscript of such operations, ensuring the welfare of populations. In so doing, government needs to develop clearance processes, environmental waste control and the conservation of natural resources, with which the lives and livelihoods of these people relate intricately, in order to ensure the protection of the people of mining regions and ensure their rights. In essence, the NMP 2019 fails to provide the required guidelines for some of the essential aspects of a strong guideline for ensuring environmental and socially responsible mining, in accordance with the Supreme Court's intention. But now the expectation is that the regulations will be carefully processed by our decision makers.[22]

Conclusion

Mining contributes greatly to the commercial, social and environmental fabric of a much larger region adjacent to the mining sector. Although there is no way of undermining the economic contribution of mining, land depletion attributable to mining and the ecological and socio-economic problems arising from such activity are very risky. In addition to this extraction, the social costs of migration, the lack of livelihood and social isolation have always been high. The predominance of open-cast mining requires greater areas of land that eventually lead to further habitat destruction and livelihoods. This is exacerbated.

With Regards to issues related to EIA, Sustainable mining and the National Mineral Policy, 2019 dissemination for local communities and the public with all project-related material from approval to approval. The previously excluded groups of initiatives that have an effect on the environment should be covered by public hearings. In both programmes, where major habitat changes are expected to occur, the environmental approval process must be carried out without exception. In environmentally vulnerable areas no industrial construction project should be allowed. Therefore, the possible detrimental effect of the mining on the flora and fauna of a wider region is very necessary to carry out adequate tests before permitting mining operations. In the preparation phase itself, potential effects need to be detected in order to avoid them. To do so, one should be mindful of the different environmental practises.

REFERENCES

CM Jariwala, MINING AND ENVIRONMENT: INDIAN LAW SCENARIO, 37 11.

Aqa Raza & Mukesh Dwivedi, Regulatory Framework of Minerals and Mining Industry in India in Relation to Environmental Concerns: A Critical Analysis (2017), https://papers.ssrn.com/abstract=3415706 (last visited Feb 23, 2021).

Niharranjan Mishra & Nabanita Das, Coal Mining and Local Environment: A Study in Talcher Coalfield of India, 10 Air Soil Water Res. (2020), https://bioone.org/journals/air-soil-and-water-research/volume-10/issue-1/1178622117728913/Coal-Mining-and-Local-Environment--A-Study-in-Talcher/10.1177/1178622117728913.full (last visited Feb 23, 2021).

Assessment of Environmental Impact due to Mining Activities and its Mitigation in Coal India Limited, PRSIndia (2019), https://www.prsindia.org/report-summaries/assessment-environmental-impact-due-mining-activities-and-its-mitigation-coal-india (last visited Feb 23, 2021).

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Mihir Deb & Sanjib Sarkar, Issues of Sustainable Development in the Mines and Minerals Sector in India519–551 (2017).

Sustainable waste management in the Indian mining industry - V. P. Deshpande, A. V. Shekdar, 2005, , https://journals.sagepub.com/doi/10.1177/0734242X05056994 (last visited May 3, 2021).

[1] CM Jariwala, MINING AND ENVIRONMENT: INDIAN LAW SCENARIO, 37 11.

[2] Nilmadhab Mohanty, SUSTAINABLE DEVELOPMENT: Emerging Issues in India’s Mineral Sector310.

[3] Assessment of Environmental Impact due to Mining Activities and its Mitigation in Coal India Limited, , PRSIndia (2019), https://www.prsindia.org/report-summaries/assessment-environmental-impact-due-mining-activities-and-its-mitigation-coal-india (last visited Feb 23, 2021).

[4] Aqa Raza & Mukesh Dwivedi, Regulatory Framework of Minerals and Mining Industry in India in Relation to Environmental Concerns: A Critical Analysis (2017), https://papers.ssrn.com/abstract=3415706 (last visited Feb 23, 2021).

[5] Niharranjan Mishra & Nabanita Das, Coal Mining and Local Environment: A Study in Talcher Coalfield of India, 10 Air Soil Water Res. (2020), https://bioone.org/journals/air-soil-and-water-research/volume-10/issue-1/1178622117728913/Coal-Mining-and-Local-Environment--A-Study-in-Talcher/10.1177/1178622117728913.full (last visited Feb 23, 2021).

[6] Tarun Bharat Sangh vs. Union of India and Ors, 1993 SCR (3) 21

[7]Sustainable waste management in the Indian mining industry - V. P. Deshpande, A. V. Shekdar, 2005, , https://journals.sagepub.com/doi/10.1177/0734242X05056994 (last visited May 3, 2021).

[8] Dhruv Katoria, Dhruv Sehgal & Sameer Kumar, Environment Impact Assessment of Coal Mining 6.

[9] The impacts of EIA procedure on the mining sector in the permit process of mining operating activities & Turkey analysis - ScienceDirect, , https://www.sciencedirect.com/science/article/abs/pii/S0301420719310128 (last visited May 3, 2021).

[10] Mishra and Das, supra note 6.

[11]environmental-impact-assessment-of-mining-projects.pdf, , https://elibrarywcl.files.wordpress.com/2015/02/environmental-impact-assessment-of-mining-projects.pdf (last visited May 3, 2021).

[12] EIA analysis of coal mining project, , https://www.cseindia.org/eia-analysis-of-coal-mining-project-by-m-s-jayaswals-neco-limited-1209 (last visited May 3, 2021).

[13] Will the new National Mineral Policy ensure responsible mining?, , https://www.downtoearth.org.in/news/mining/will-the-new-national-mineral-policy-ensure-responsible-mining--63741 (last visited May 3, 2021).

[14] Common Cause Vs Union of India & Others ,77 taxmann.com 245 (SC)

[15] National Mineral Policy 2019: a Remedy as Bad as the Disease?, , https://www.teriin.org/research-paper/national-mineral-policy-2019-remedy-bad-disease (last visited May 3, 2021).

[16] M K Yadav, National Mineral Policy 2019 & Mineral Concession Rules (India)18.

[17] Common Cause Vs Union of India & Others ,77 taxmann.com 245 (SC)

[18] National Mineral Policy 2019, supra note 29.

[19] Id.

[20] Id.

[21] Id.

[22] “Will the new National Mineral Policy ensure responsible mining?", supranote 27.