JUDGMENT

PARIPOORNAN, J. :—The State of Orissa and the authorities in the Mines Department of the State are the appellants in this batch of appeals. M/s. Mahanadi Coalfields Ltd., a Government company, in whom the lands in question vests in accordance with Section 11 of the Coal Bearing Areas (Acquisition and Development) Act, 1957 (Central Act 20 of 1957), and Union of India are the respondents in the main appeal. In the other appeals, the consumers of coal who purchase coal from Mahanadi Coalfields Ltd. for their own consumption as well as some traders in Coal are the respondents. The Mahanadi Coalfields Ltd., the consumers of coal who purchase coal from Mahanadi Coalfields Ltd., and some traders in coal assailed the validity of the Orissa Rural Employment, Education and Production Act, 1992 (Orissa Act 36 of 1992), as amended, hereinafter referred to as the Act, before the High Court of orissa in a series of writ petitions. The main controversy in the cases was regarding the levy of tax under the Act on "coal bearing lands". By a common Judgment dated 26-4-1994* the Division Bench of the High Court held that the State Legislature did not have the competence to levy the tax on co