JUDGMENT

CHANDRACHUD, CJI. :— These appeals by special leave involve the question of the legality of the demand for property-tax made by respondent 1 on the appellant Companies. Civil Appeal No. 213 of 1979 filed by the Bharat Aluminium Company Ltd. arises out of Misc. Petition No. 555 of 1977 filed by it in the High Court of Madhya Pradesh under Art. 226 of the Constitution. Respondent 1 is the Special Area Development Authority, Korba, District Bilaspur, M. P. respondent 2 is its Chairman and respondent 3 is the State of Madhya Pradesh. Since the three appeals raise similar questions, we will refer to the facts of Civil Appeal No. 213 of 1979 only. Civil Appeals Nos. 1025 and 1026 of 1978 are by Western Coalfields Ltd.

2. The appellant. Bharat Aluminium Company Ltd., is a Government, company incorporated under the Companies Act, 1956, the entire share capital being owned by the Government of India. Respondent 1, the Special Area Development Authority for the Korba Special Area, is constituted under S. 65 of the M. P. Nagar Tatha Gram Nivesh Adhiniyam. (23 of 1973), referred to hereinafter as the Act of 1973. That Act was passed by the M. P. Legislature in order "to make provision