ORDER : 1. This writ petition is filed under Article 226 of the Constitution of India for the following relief: “……to issue a Writ of Mandamus declaring the proceedings No 12697/D8/2017 dated 31.12.2020 issued by the Respondent No 2 to the extent of renewing the quarry lease of the petitioner for a period of 10 years only as against in principle grant of renewal of 20 yrs vide proceedings 12697/R31/2017 dated 10.05.2017, as illegal and arbitrary and provisions of APMMC Rules 1966 r/w Art 14 of the Constitution of India and consequently direct the Respondents to renew lease for period of 20 yrs as mentioned in proceedings 12697/R31/2017, dated 10.05.2017 of Respondent No 2 and pass….” 2. Brief facts of the case are that, initially, the petitioner company was granted mining lease for Mica in the year 1959 in respect of an extent of Ac.362.07 cents in survey Nos. 65, 66, 68 and 71 of Kalichedu village, Rapur taluk, Nellore district, and subsequently the lease was transferred in favour of the petitioner in the year 1961 vide G.O.Ms.No.1467. The lease period was renewed for a period of 20 years vide G.O.Ms.No.142 in the year 1976 and a part of the leased area was transferred to another company in the year 1983 vide G.O.Ms.No.290. The remaining extent of lease was renewed in the year 1999 for a further period of 20 years, vide G.O.Ms.No.316 for a further period of 20 years. It is stated that, the petitioner submitted application dated 28.09.2016 for renewal of the lease for a further period of 20 years as per the Rules in force by then, in respect of an extent of Ac.287.70 cents in survey No.153, 160P, 161, 165 of Kalichedu village, Sydapuram mandal, Nellore district. Pursuant to the said application, respondent No.3 submitted proposals recommending for grant of 3 rd renewal for a further period of 20 years, and thereupon, respondent No.2 issued proceedings vide No.12697/R3-1/2017, dated 10.05.2017, according in principle approval for renewal of the lease period in favour of the petitioner for a further period of 20 years with effect from 09.12.2017, subject to submission of approved mining plan along with Environmental Clearance (EC) from the Ministry of Environment and Forests (MoEF) and the Consents for Establishment (CoE) from the Andhra Pradesh Pollution Control Board(APPCB). Accordingly, the Mining plan of the petitioner was approved on 29.6.2017 and the time for submission of EC was extended vide letters dated 06.11.2018 and 24.04.2019. Thereafter, the EC was issued by MoEF on 01.07.2020 and CoE was issued by the APPCB on 12.08.2020. However, surprisingly, the 2 nd respondent issued the impugned proceedings vide No.12697/D8/2017, dated 31.12.2020, to the extent of renewing the lease for a period of ten years only, as against the in principle grant of renewal for twenty years vide proceedings dated 10.05.2017, as illegal and arbitrary. Challenging the same, the present Writ Petition is filed. 3. The counter affidavit has been filed by the respondents. While denying the material averments made in the Writ Petition, inter alia, contended that, the petitioner company was granted mining lease for Mica in the year 1959 for an extent of Ac 362.07 cents in Sy No.65, 66,68 and 71 of Kalichedu Village, Rapur Taluk, Nellore District and the said lease was subsequently transferred in favour of the petitioner in the year 1961. The renewal of the said lease for a period of 20 years from 09.12.1977 to 08.12.1997, the part transfer of lease over an extent of Ac.69.27 cents and retaining Ac.287.70 cents for the unexpired portion of lease period up to 08.12.1997 and thereafter 2 nd renewal from 09.12.1997 to 08.12.2017, the filing of 3 rd renewal application by the petitioner on 28.09.2016, the submission of proposals for grant of 3 rd renewal and issuance of Letter of Intent dated 10.05.2017, deciding in principle to grant 3 rd renewal of lease for a further period of 20 years from 09.12.2017 subject to submission of the documents, as stated supra. The respondents also admitted about approval of the mining plan vide letter No.2055/MP/NLR/2017, dated 29.06.2017. It is further stated that 2 nd respondent, vide Letter No.12697/R3-1/2017, dated 06.11.2018 informed that the Letter of Intent dated 10.05.2017 issued to the petitioner holds good for obtaining EC and CoE. Respondents also admitted about grant of extension of time vide proceedings dated 24.04.2019. It is further stated that 2 nd respondent issued the impugned order dated 31.12.2020 granting 3 rd renewal of quarry lease for a period of 10 years as per Rule 12 (5) (h) (xi) of the APMM Rules, amended vide G.O.Ms.No.87, Industries and Commerce (M.II) Department, dated 01.08.2018. It is further stated that 2 nd respondent issued the impugned order dated 31.12.2020 granting 3 rd renewal of quarry lease for a period of 10 years as per Rule 12 (5) (h) (xi) of the APMM Rules, amended vide G.O.Ms.No.87, Industries and Commerce (M.II) Department, dated 01.08.2018. It is further stated that after issuance of Letter of Intent dated 10.05.2017, vide G.O.Ms.No.87, dated 01.08.2018, the Government amended Rule 12 (5) (h) (xi) (i) of the APMM Rules, amending the period of subsequent renewals of lease to the period not exceeding 10 years at a time or till the mineral is exhausted, and accordingly, the lease was rightly renewed for a period of 10 years in favour of the petitioner. Hence, the Writ Petition is liable to be dismissed. 4. Heard Sri K.Chidambaram, learned Senior Counsel representing Uttara Legal, appearing for the petitioner and the learned Government Pleader for Mines and Geology appearing for respondents. 5. On hearing, learned senior counsel appearing for the petitioner while reiterating the contents made in the petition, argued that, the 2 nd respondent, having given Letter of Intent (LOI) dated 10.05.2017, agreeing, in principle, to renew the lease period for a period of twenty years pursuant to the recommendations of respondent No.3, ought to have renewed the lease period for twenty years. He submitted that the 2 nd respondent in exercise of the powers conferred under Rule 12(5)(h)(xi)(i) of the APMMC Rules, 1966 granted 3 rd renewal for a further period of 10 years only. He submits that the reason for restriction of the lease period to ten years is the amendment to Rule 12(5)(h)(xi)(i) vide G.O Ms.No.87 dated 01.08.2018 whereunder the subsequent lease renewals is restricted to 10 years at a time, however till the mineral is exhausted. He submits that, subsequent amendment brought to Rule 12 (5) (h) (xi) (i) of the APMMC Rules, 1966 cannot be given retrospective effect and it is not applicable to the case of the petitioner. He submits that the petitioner is entitled to renewal of lease period for a period of twenty years, pursuant to the Letter of Intent dated 10.05.2017, and hence, he prays to allow the Writ Petition. 6. He submits that the petitioner is entitled to renewal of lease period for a period of twenty years, pursuant to the Letter of Intent dated 10.05.2017, and hence, he prays to allow the Writ Petition. 6. To support his contention, learned Senior counsel has placed reliance on a decision of High Court of Judicature, Telangana and Andhra Pradesh at Hyderabad reported in V.U.S.B. Bhushan Kumar v. State of Andhra Pradesh and others , 2018 (5) ALD 636 , wherein, it was held that right accrued from letter of Intent before amended Act came into force is saved and crystallized. 7. Learned Senior counsel while relying upon the above decision, submits that, the right accrued from the letter of intent before the amended Act came into force is saved and crystallized as enforceable by the amended Act. Further more, the subject renewal is saved by clauses (b), (c) and (e) of Section 6 of the GENERAL CLAUSES ACT , 1897. 8. Per contra, learned Government Pleader for Mines and Geology submitted that as per the amended Rule 12 (5) (h) (xi) (i) of the APMMC Rules, 1966 vide G.O.Ms.No.87, Industries and Commerce (M.II) Department, dated 01.08.2018, the lease period for 2 nd and subsequent renewals is restricted to 10 years only and accordingly, the 2 nd respondent renewed the lease period for ten years, though it is mentioned in the Letter of Intent dated 10.05.2017 as 20 years, and hence, as there are no merits in the present Writ Petition, prays to dismiss the same. 9. On a perusal of the record, this Court observed that, the mining lease for Mica was granted vide G.O.Ms.No.367, Industries Department, dated 23.03.1959 in respect of Ac.362.07 cents in survey Nos. 65, 66, 68 and 71 of Kalichedu village, Sydapuram mandal, SPSR Nellore district in favour of one Y.K.KrishnaYachendra, who is the Proprietor of petitioner company. Subsequently, vide G.O.Ms.No.1467, Industries Department, dated 05.10.1961, the said Y.K.KrishnaYachendra was permitted to transfer the mining lease for the unexpired portion up to 08.12.1977 in favour of petitioner firm. Thereafter, 1 st renewal was granted vide G.O.Ms.No.142, Industries and Commerce (M.II) Department, dated 16.02.1976 in favour of the petitioner for a period of 20 years and a part of the leased area was transferred to another company in the year 1983 vide G.O.Ms.No.290. Thereafter, 1 st renewal was granted vide G.O.Ms.No.142, Industries and Commerce (M.II) Department, dated 16.02.1976 in favour of the petitioner for a period of 20 years and a part of the leased area was transferred to another company in the year 1983 vide G.O.Ms.No.290. Thereafter, vide G.O.Ms.No.107, Industries and Commerce (M.I) Department, dated 11.02.2000, 2 nd renewal of lease was granted for a period of 20 years from 09.12.1997 to 08.12.2017. 10. It is not in dispute that the petitioner firm made an application on 28.09.2016 in prescribed format within the stipulated time as per Rule 12 (5) (h) (xi) of the APMMC Rules, 1966 for 3 rd renewal of the lease for a period of 20 years and 3 rd respondent submitted proposals to 2 nd respondent recommending renewal of lease for a period of 20 years with effect from 09.12.2017, and 2 nd respondent issued Letter of Intent, vide Notice No.12697/R3-1/2017, dated 10.05.2017. 11. As seen from the LoI vide Notice No.12697/R3-1/2017, dated 10.05.2017, wherein it was mentioned, as under: “…..After careful examination of the proposals of the Assistant Director of Mines and Geology, Nellore it is decided in principle to grant 3rd Renewal of Quarry Lease for Mica, Quartz & Feldspar over an extent of 116.430 Hectares (287.70 Acres) In Sy. Nos. 153, 160/P, 161 & 165 of Kalichedu Village, Sycapuram Mandal, SPSR Nellore District in favour M/s. Sree Kalyana Rama Company for a further period of (20) years w.e.f. 09.12.2017 subject to submission of Approved Mining Plan within a period of (6) months from the date of issue of this notice under Rule 12(5) (c) of APMMC Rules, 1966 along with consent for Establishment from A.P. Pollution Control Board & Environmental Clearance from Ministry of Environment & Forests as per Environment Impact Assessment Notification through SO.1533, dt.14.09.2006. 12. In pursuance of the same, the petitioner made an application for approval and the Mining Plan for Mining Lease held by the petitioner was approved by the respondents vide Letter No..2055/MP/NLR/2017, dated 29.06.2017. It is pertinent to mention here that the respondents extended time for submission of the documents as stated in the above Notice, from time to time. Vide Proceedings No.12697/R3-1/2017, dated 24.04.2019, the 2 nd respondent extended the time for a period one year. 13. It is pertinent to mention here that the respondents extended time for submission of the documents as stated in the above Notice, from time to time. Vide Proceedings No.12697/R3-1/2017, dated 24.04.2019, the 2 nd respondent extended the time for a period one year. 13. This Court further observed that, in pursuance of the proposals submitted by the 3 rd respondent recommending renewal of lease for a period of 20 years with effect from 09.12.2017, the 2 nd respondent issued Letter of Intent, vide Notice No.12697/R3-1/2017, dated 10.05.2017, agreeing, in principle, to grant 3 rd renewal of lease for a further period of 20 years with effect from 09.12.2017. Thereafter, mining plan of the petitioner was approved by the respondents vide letter No.2055/MP/NLR/2017, dated 29.06.2017, and that, time for submission of the documents mentioned in the Letter of Intent was extended from time to time vide letters dated 06.11.2018 and 24.04.2019, even after the amendment to Rule 12 (5) (h) (xi) of the APMMC Rules, 1966, came into force w.e.f.01.08.2018. 14. It is pertinent to mention here that, the reason for restriction of the lease period to 10 years is the amendment to Rule 12(5)(h)(xi)(i) vide G.O.Ms.No.87 dated 01.08.2018, where-under the subsequent lease renewals is restricted to 10 years at a time. The said rule is extracted hereunder: (xi) Rule 12(5)(h)(xi)(i): If the lessee to whom a quarry lease is granted has complied with all the conditions of the lease and filed an application for renewal in Form Q. to the Assistant Director of Mines and Geology before twelve months of the expiry of the lease and accompanied by a treasury or bank challan for Rs. 10,000/- (Rupees Ten Thousand only) towards non-refundable application fee, the Director of mines and geology shall initially for a period of 20 years. In case of subsequent renewals, the Director of Mines and Geology with prior permission of the state government .shall grant such renewals, not exceeding 10 years at a time till the mineral is exhausted, subject to adherence to and non-violation of Rules during the operation of mining lease. In case of subsequent renewals, the Director of Mines and Geology with prior permission of the state government .shall grant such renewals, not exceeding 10 years at a time till the mineral is exhausted, subject to adherence to and non-violation of Rules during the operation of mining lease. Prior to amendment to Rule 12(5)(h)(xi)(i), reads as under: Rule 12(5)(h)(xi)(i): If the lessee to whom a quarry lease has been granted has dulyobserved all the conditions of the lease and filed an application for renewal in Form Q. to the Assistant Director before twelve months of the expiry of the lease and accompanied by a treasury or bank challan for Rs. 5,000/- (Rupees Five Thousand only) towards non-refundable application fee, the Director shall grant renewal for a period not exceeding 20 years subject to adherence to and non violation of rules during the period of occupation by the lessee.” 15. It is not in dispute that a Letter of Intent can be construed as a letter of acceptance, if such intention is evident from its terms. Though such a letter is termed as a letter of intent, it may amount to acceptance of offer resulting in a concluded contract between the parties. From the terms of the Letter of Intent and the subsequent conduct of respondents in extending the time even after amendment to Rule 12 (5) (h) (xi) of the APMMC Rules, 1966 w.e.f. 01.08.2018, including the Letter No.12697/R3-1/2017, dated 06.11.2018 of 2 nd respondent, whereby it was informed that the Letter of Intent dated 10.05.2017 issued to the petitioner holds good for obtaining EC and CoE, it can be concluded that it is a concluded contract between the parties. Further, a Rule or Law can be construed as prospective in operation. The subject Letter of Intent was issued as per the Scheme of Rules as existed when the 3 rd renewal application was made by the petitioner. Rules amended subsequent to issuance of Letter of Intent are considered prospective and apply only to future actions and do not affect the terms of the Letter of Intent already issued. 16. It is not the case of the respondents that the amendment made to Rule 12 (5) (h) (xi) of the APMMC Rules, 1966 is retrospective in operation. Courts are to be cautious in applying the amendments retrospectively, for, doing so would affect vested rights already acquired under the contract. 17. 16. It is not the case of the respondents that the amendment made to Rule 12 (5) (h) (xi) of the APMMC Rules, 1966 is retrospective in operation. Courts are to be cautious in applying the amendments retrospectively, for, doing so would affect vested rights already acquired under the contract. 17. In the present case, the petitioner arranged all his efforts on the basis of getting the lease for a period of 20 years with effect from 09.12.2017 as per the Scheme of APMMC Rules, 1966 as it existed then, pursuant to the Letter of Intent dated 10.05.2017, and though the subsequent letters date 06.11.2018 and 24.04.2019 were issued subsequent to the amendment to Rule 12 (5) (h) (xi) (i) of the APMMC Rules, 1966 came into force, the respondents never curtailed period of third renewal to 10 years instead of 20 years, and it led the petitioner to make his legitimate claim towards third renewal for a period of 20 years pursuant to making its third renewal application dated 28.09.2016 in time as stipulated under the Rules, 1966 and subsequently obtain the subject Letter of Intent from the respondents. 18. In view of the foregoing discussion, this Court has no hesitation to hold that under the garb of amendment to Rule 12 (5) (h) (xi) (i) of the APMMC Rules, 1966, which came into force with effect from 01.08.2018, the respondents cannot deprive the petitioner of its right accrued under the subject Letter of Intent dated 10.05.2017, and the petitioner is entitled to renewal of the lease for a period 20 years. Therefore, this Court is inclined to allow the writ petition while declaring the proceedings dated 31.12.2020 issued by the 2 nd respondent, as illegal and arbitrary. 19. Accordingly, the Writ Petition is allowed. The impugned proceedings No.12697/D8/2017, dated 31.12.2020 issued by 2 nd respondent is hereby set aside to the extent of renewing the quarry lease of the petitioner for a period of ten years only as illegal and arbitrary. Further, the respondents are directed to renew the quarry lease in favour of the petitioner for a period for 20 years as mentioned in the Letter of Intent vide Notice No.12697/R3-1/2017, dated 10.05.2017 issued by 2 nd respondent. No costs. 20. As a sequel, all the pending miscellaneous applications in the writ petition, shall stand closed.