Following the Supreme Court's nine-judge bench ruling in Mineral Area Development Authority v. Steel Authority of India (MADA), which held that states can levy taxes on mineral rights beyond royalty, Parliament enacted a validation law under Section 9D of the Mines and Minerals Act to limit retrospective recovery. Several states have now challenged this validation legislation before the Supreme Court under Article 131, arguing it unconstitutionally overrides the MADA judgment and infringes state fiscal autonomy over mineral taxation.

The MADA case (2024) settled a long-running constitutional dispute: a nine-judge bench held that royalty paid on minerals is not a 'tax,' and states have legislative competence under Entry 50, List II to impose taxes on mineral rights. This overruled the 1989 India Cement ruling.

Post-MADA, Parliament swiftly amended the Mines and Minerals (Development and Regulation) Act by inserting Section 9D, which effectively validates past royalty arrangements and bars states from recovering arrears retrospectively — neutralising the financial windfall the MADA ruling had created for mineral-rich states like Jharkhand, Odisha, and Chhattisgarh.

The constitutional challenge now has three distinct layers:

1. Validation doctrine: Parliament can retrospectively cure a legal defect — but a validation law cannot simply declare a court's judgment wrong. It must change the underlying legal basis. States argue Section 9D fails this test because it does not alter any legislative foundation; it merely negates the judgment's effect.

2. Article 131 jurisdiction: The suit between states and the Union before the Supreme Court is an original suit. The critical question is whether a dispute about the validity of a central law affecting state revenues qualifies as a 'legal right' dispute under Article 131, or whether it is really a constitutional interpretation question better suited to writ proceedings.

3. Federalism and fiscal autonomy: Since MADA recognised states' sovereign taxing power over minerals, a central validation law cutting off that revenue strikes at fiscal federalism — bringing Article 246, Entry 50 List II, and the doctrine of legislative competence into sharp focus.

The validation doctrine test, as settled in Shri Prithvi Cotton Mills v. Broach Municipality and later in Bakhtawar Trust, requires that the legislature must remove the substratum of the court's decision — not merely declare the outcome void.