Coal India Vs. Competition Commission Of India: Case Analysis

One of the basic rules of interpretation states that no provision of a statute should be read in isolation to the other statutes and that while interpreting a law, it should be presumed that the Parliament, at the time of making such law, was well aware of the existence of all the other laws in force in India.

This rule, also known as the ‘rule of harmonious construction', being one of the cardinal principles of interpretation of statutes, recently formed the basis of the decision in the recent case of Coal India Limited & Anr. vs the Competition Commission of India & Anr.¹ (hereinafter referred to as the ‘CIL' and ‘CCI', respectively), where the Hon'ble Supreme Court was presented with a question of whether the Coal Mines (Nationalization) Act, 1973 (hereinafter referred to as the ‘Nationalization Act') would preclude the Appellants from being governed by the Competition Act, 2002 (hereinafter referred to as the ‘Competition Act').