Below the Surface: Mining and Metals Edition - November 2025

After more than three decades of policy duality, the government has finally ended the “minor versus major” divide for limestone. Through GSR 751(E) dated 10 October 2025, the Ministry of Mines amended the Mines and Minerals (Development and Regulation) Act, 1957 (MMDR Act), deleting the minor-mineral carve-out for “lime-kiln” use and bringing all limestone under the central major-mineral regime.

Previously, limestone used for building materials, lime-kilns, and local supply chains was regulated as a minor mineral under State control, while industrial-grade limestone for cement, steel, and chemical industries fell under central oversight. This duality led to fragmented regulation, royalty inconsistencies, and monitoring gaps across State boundaries.

To ensure a smooth transition, an order dated 13 October 2025 issued under Section 20A of the MMDR Act allows existing minor-mineral limestone leases to migrate to the new regime in stages. Lessees must obtain IBM registration and begin filing monthly and annual returns (Forms F-1 and F-2) by 31 March 2026. IBM’s full online compliance reporting will become mandatory from 1 July 2027. Royalty rates have been harmonised under the Second Schedule to the Act - ₹70 per tonne for cement-grade limestone and ₹60 per tonne for all other categories. This reform effectively ends decades of interpretive disputes over whether lime-kiln stone was “major” or “minor”, advancing the “One Mineral, One Regime” principle first articulated in the National Mineral Policy 2019.

Why this matters:

It unifies all limestone mining under a single regulatory and reporting framework, eliminating State-Centre overlap and enhancing environmental, social, and governance (ESG) accountability and compliance.

Impact for you:

Lessees must register with IBM and transition to full digital reporting by July 2027, ensuring contracts, royalties, and disclosures are aligned with the new major-mineral regime. 

1. Milestone Timelines in Mineral Auctions

The Mineral (Auction) Second Amendment Rules, 2025 (GSR 778(E)), notified on 17 October 2025, mark a structural tightening of the mine-allocation process. These rules insert Rule 9A, introducing mandatory intermediate milestones between the Letter of Intent (LoI) and the execution of the Mining Lease (ML):

Any delay beyond these deadlines may lead to automatic LoI cancellation under Rule 9A(6) after due notice. Bank guarantees will be reduced by 1% per month of delay. The policy intent is to discourage speculative bidding and expedite production under the Mining Gati Shakti framework.

2. Captive Mine Sales Liberalised

The Mineral (Auction) Third Amendment Rules, 2025 (GSR 792(E)), issued on 22 October 2025, introduced one of the most consequential changes since 2016.

Under the revised Rule 6(4), captive mine lessees - after meeting their own plant’s requirements - may sell surplus mineral output without the earlier 50% cap. The amendment cross-references Section 15B(1)(b) of the MMDR Act, mandating a 35% revenue share with State Governments on such market sales.

The notification also clarifies thresholds for atomic-mineral inclusion: monazite content below 0.1% or uranium equivalent below 0.05% will remain under State purview. This clarification avoids inadvertent regulatory overlap with the Department of Atomic Energy.

3. NMET Renamed as NMEDT

The National Mineral Exploration Trust (Amendment) Rules, 2025 (GSR 803(E)) issued on 23 October 2025, officially renamed the fund the National Mineral Exploration and Development Trust (NMEDT).

The amendment inserts Rule 9A to establish a five-member Technical Advisory Committee (comprising GSI, MECL, MoM, State representatives, and an independent expert).

Fund allocation has been rationalised:

It also mandates C&AG audits, enhancing transparency. This shift aligns with India’s critical-minerals exploration agenda, linking exploration funding with decarbonisation and technology-security goals.

4. Critical Minerals Recycling Scheme

The Ministry of Mines and Ministry of Heavy Industries jointly notified S.O. 5478(E) on 2 October 2025, launching the Incentive Scheme for Promotion of Critical Minerals Recycling.

The scheme offers up to 15% of capital expenditure (max ₹50 crore for Group-A projects) to encourage closed-loop recovery of strategic materials like lithium, cobalt, and nickel.

Eligibility conditions require at least 90% hydrometallurgical recovery and ban purely thermal recycling routes due to environmental externalities. The scheme will be implemented through the Indian Battery Recycling Mission Cell (IBRMC) under the Geological Survey of India (GSI).

Quarterly technical reviews will be led by the Additional Secretary (Mines), ensuring traceable ESG outcomes. This marks India’s first financial-incentive framework linked directly to mineral circularity.

5. Coal Sector - 14ᵗʰ Round of Commercial Auctions

The 14ᵗʰ Tranche of Commercial Coal Mine Auctions, launched on 29 October 2025, offered 41 coal blocks, including 21 identified for Underground Coal Gasification (UCG) - a first for India.

Under a special MoEFCC dispensation, pilot UCG projects (≤25 hectares, ≤3 years) will not require Environmental Clearance during the pilot phase.

The Directorate General of Mines Safety (DGMS) will supervise well integrity and subsidence controls. UCG technology converts in-situ coal into syngas, potentially cutting surface disturbance and improving carbon efficiency.

The reform dovetails with India’s carbon-intensity reduction pledge, positioning coal innovation within a managed ESG framework.

6. Judicial Developments - Supreme Court, NGT & High Courts

(a) Supreme Court - Odisha Mining Dues (29 Oct 2025)

In Common Cause v Union of India, W.P.(C) No. 114/2014, the Supreme Court reprimanded the Odisha Government for delays in recovering ₹2,700 crore in compensation from illegal iron and manganese mining lease-holders.

A fresh status report was directed by 1 December 2025, with the Chief Secretary held personally accountable. The Court also directed a CAG-verified audit of recovered sums.

(b) Supreme Court - Sand Mining Doctrine (14 Oct 2025)

In Association for Environment v Union of India, C.A. No. 2045/2023, the Court reaffirmed that District Survey Reports (DSRs) without scientific replenishment studies are invalid under MoEFCC’s in 2010 Office Memorandum.

This strengthens environmental governance and will influence EC challenges in sand and riverbed-mining cases.

(c) NGT - Yamuna Floodplains (22 Oct 2025)

The National Green Tribunal (Principal Bench) ordered Delhi and Uttar Pradesh to establish a joint task force to curb illegal sand mining on the Yamuna floodplains.

The task force must submit compliance reports fortnightly, supported by GPS-based truck-tracking systems.

(d) Punjab & Haryana High Court - Stone Crusher Buffer Rule (10 Oct 2025)

In CWP 21524/2025, the High Court issued an interim status-quo order on Haryana’s notification mandating a 100-metre buffer between crushers and mining areas.

The Court sought affidavits from the HSPCB and Mining Department by 6 November 2025.

The October 2025 reforms mark a decisive shift from administrative discretion to time-bound, rule-based accountability. The Second and Third Amendment Rules collectively transform how mining projects are structured and monitored.

For compliance teams, the 6-18-12-month clock (for Mining Plan, EC, and ML execution) must now be embedded in performance-security matrices. Each stage delay now carries tangible financial exposure via BG deductions.

Contract managers should revise conditions precedent and force-majeure clauses in auction-linked joint ventures, ensuring that environmental-clearance delays are allocated fairly.

When one of the world's leading smartphone companies faced a challenging regulatory issue, we helped them navigate a complex compliance matter involving lithium-ion batteries, plastic packaging, and multi-brand products.

In line with India's new Battery Waste Management and Plastic Waste Management Rules (2025), the company had to fully adhere to its Extended Producer Responsibility (EPR) requirements without affecting its current suppliers or production processes.

What We Did: 

• We looked at the company’s entire supply chain and found where they might run into compliance problems.

• We created a compliance system using technology that covers EPR labelling, tracking, and reporting to the CPCB across all product types.

Outcome: 

• The company avoided possible fines and legal trouble by smoothly implementing compliance.

• It also became a leader in sustainability, setting a new standard for responsible manufacturing in India’s tech industry.

·      Critical Minerals Policy 2026:

India’s first overarching critical-minerals policy is expected to define strategies for securing lithium, cobalt, rare earths, and other strategic inputs. The draft will probably initiate a National Strategic Minerals Framework, stockpile policy, and clearer foreign-investment thresholds.

·      14ᵗʰ Coal Auction Round:

Expected to expand commercial participation in large-scale Underground Coal Gasification and introduce a new environmental-performance index. The focus will be on sustainable coal utilisation and methane-mitigation protocols.

In 2025, India became the second-largest producer of coal in the world, producing more than 1 billion tonnes for the first time.

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