Major Port Authorities and Tariff Powers in India: Authority, Procedures, Jurisdiction, and Penalties

Executive Summary
India’s major ports are in the midst of one of the most significant regulatory transformations in decades. The Major Port Authorities Act, 2021 (“MPA Act”), in force since 3 November 2021, has replaced the erstwhile Major Port Trusts Act, 1963. At its core, this reform shifts India’s port governance model away from a heavily centralized tariff-fixing regime dominated by the Tariff Authority for Major Ports (TAMP), toward a board-driven, market-aligned framework under the Boards of Major Port Authorities, supported by an Adjudicatory Board for disputes.
Table of Contents
By September 2025:
- All twelve major ports function as Major Port Authorities, with their Boards empowered to fix tariffs for services and port assets.
- The Adjudicatory Board has been formally notified (August 2025) and has assumed jurisdiction over disputes between ports, concessionaires, and users.
- Appeals from the Adjudicatory Board lie directly to the Supreme Court of India, raising questions of efficiency and access.
- The MPA Act codifies penalties, offences, and procedures for enforcement, signalling stronger compliance expectations.
- This article provides a comprehensive examination of these developments in a manner suitable for clients, investors, and port users.
Evolution: From TAMP to MPA
1. The TAMP Regime under the 1963 Act
- Established in 1997, TAMP was a statutory authority responsible for fixing tariffs for all major ports and their BOT (PPP) terminals.
- Operated on a cost-plus methodology: tariffs were calculated on audited costs plus a reasonable return.
- While transparent, this led to:
- Inflexibility: ports could not rapidly adjust tariffs to market conditions.
- Competitiveness issues: non-major ports (regulated by state maritime boards) often attracted more investment due to flexible pricing.
- Excessive litigation: concessionaires often challenged TAMP’s determinations.
2. Reform Imperatives
Private sector participation required a predictable yet flexible tariff environment. Global landlord port models showed that board-driven tariffs subject to competition law and policy oversight could balance user protection with efficiency. The MPA Act was designed to:
- Enhance port autonomy;
- Streamline tariff procedures;
- Provide a specialized dispute resolution body.
3. Transition Timeline
- 2021: MPA Act notified, replacing Major Port Trusts Act.
- 2021–2025: TAMP continued residual jurisdiction pending constitution of Adjudicatory Board.
- August 2025: Adjudicatory Board notified; TAMP formally wound up.
Institutional Structure under the MPA Act
1. Major Port Authority Board Composition:
- Chairperson & Deputy Chairperson (appointed by Central Govt).
- Central Government nominees.
- State Government nominee.
- Two employee representatives.
- Independent members with expertise in transport, finance, logistics.
Functions:
- Fix tariffs (Sec. 34).
- Manage land and assets (Sec. 22).
- Enter into PPP concessions.
- Frame regulations for service delivery.
2. Central Government
- Retains power to issue policy directions binding on Boards.
- Can override decisions in public interest (Sec. 111).
- Issues tariff guidelines (e.g., Tariff Guidelines, 2021 for PPPs).
3. Adjudicatory Board
- Presiding Officer (currently Justice Ashish J. Desai) + two members.
- Functions (Sec. 54):
- Resolve disputes between ports and PPP concessionaires.
- Hear complaints from port users.
- Review stressed PPP projects and recommend revival.
- Appeals: Directly to the Supreme Court.
Tariff Powers and Procedures
1. Scope (Sec. 34, MPA Act): Boards may fix tariffs for:
- Services performed by the port (pilotage, towage, bunkering, cargo handling).
- Use of port assets (land leases, storage sheds, berths).
- Vessel-related and cargo-related charges (port dues, wharfage, berth hire).
2. Guiding Principles
- Must comply with policy directions from Central Govt.
- Tariffs must be non-discriminatory.
- Discounts and rebates permitted if transparent and non-preferential.
3. Procedure for Tariff Fixing
- Preparation of Draft Schedule: Finance and traffic departments prepare draft scales based on market benchmarks, costs, and competition analysis.
- Internal Committees: Many Boards constitute Tariff Committees including finance, traffic, and legal officers.
- Policy Compliance Check: Drafts compared with Ministry’s Tariff Guidelines (e.g., 2021 guidelines).
- Board Resolution: Final tariffs approved in a Board meeting.
- Publication: Tariffs published in the port gazette/website. Effective from a notified date.
- Review: Boards may review periodically (annually or bi-annually).
4. PPP Projects – Tariff Guidelines, 2021
- For new PPP concessions, tariffs are bid-discovered.
- Operator can offer discounts, but must comply with maximum ceilings set in the bid documents.
- Provides certainty for lenders: tariffs are linked to concession agreement, not administrative revision.
5. Land Tariffs
- Land is monetized via leases.
- Procedure: independent valuer → recommendation → Board approval → transparent bidding/allotment.
- Rentals revised periodically (usually every 5 years).
Dispute Resolution & Jurisdiction
- Adjudicatory Board: Exclusive forum for disputes between:
- Ports and PPP operators;
- Port users and authorities;
- Legacy TAMP disputes.
- Procedures:
- Complaint filed in writing;
- Notices issued to respondents;
- Hearings (oral/written);
- Reasoned order passed.
2. Appeal Process
- Appeals lie directly to the Supreme Court (Sec. 59).
- Limitation period: 60 days (extendable for sufficient cause).
- SC in Paradip Port Authority v. Paradeep Phosphates Ltd. (Aug 2025) recommended a special appellate tribunal due to technical complexity.
3. Bar of Civil Court Jurisdiction (Sec. 60)
- Civil courts barred from entertaining matters covered by Adjudicatory Board.
- High Courts may still exercise writ jurisdiction, but usually defer to statutory remedy.
Penalties & Offences
- General Penalty (Sec. 62): Contravention of Act/regulations punishable with fine; in certain cases, imprisonment.
- Corporate Offences (Sec. 63): Directors/managers liable if offence committed with their consent, connivance, or neglect. Defence: prove due diligence.
- Cognizance (Sec. 64): No court may take cognizance unless complaint is filed by an authorised officer of the Board.
- Good Faith Protection (Sec. 65): No suit or proceeding lies against Board members/employees for actions in good faith.
Illustrative Offences:
- Non-payment of tariffs.
- Obstruction of navigation/operations.
- Damage/misuse of port property.
- Violation of lease/licence terms.
Comparative Context
1. Non-Major Ports
- Regulated by State Maritime Boards (e.g., Gujarat, Maharashtra).
- Tariffs often market-driven, with only broad state oversight.
- Competitive pressure on major ports to remain efficient.
2. Global Landlord Port Models
- Singapore, Rotterdam: Port authority as regulator/landlord, operators set market tariffs subject to oversight.
- India’s MPA Act is a step toward this, though central policy directions remain strong.
Practical Implications
- For Concessionaires: Tariff predictability improved for new PPPs (bid-discovered). Need to negotiate change in law and termination clauses carefully.
- For Lenders: Must diligence applicable tariff regime (legacy TAMP vs MPA Act). Tariff regime directly impacts project cashflows and DSCR.
- For Users: Greater transparency (published tariffs). Right to approach Adjudicatory Board for grievances.
Challenges Ahead
- Appeal Bottleneck: SC as sole appellate body is unsustainable; industry pressing for an Appellate Tribunal.
- Policy Override: Central Government retains broad powers; may impact autonomy.
- Transition Issues: Legacy concessions require careful navigation.
- Uniformity vs Competition: Ensuring tariffs remain competitive against non-major ports.
Conclusion
The MPA Act, 2021 has shifted Indian ports into a new regulatory paradigm:
- Board-driven tariffs, subject to central policy;
- Adjudicatory Board as dispute forum;
- Penalties and offences codified;
- Appeals directly to Supreme Court, with calls for a new Appellate Tribunal.
For stakeholders, the priorities are:
- Understand the applicable tariff regime (legacy vs new).
- Draft concessions with strong risk allocation clauses.
- Monitor policy and judicial developments, especially regarding appeals.
India’s ports are at the cusp of a more autonomous, competitive, and investor-friendly environment—but success will depend on how effectively procedures are implemented, and whether an expert appellate mechanism emerges to handle technical disputes efficiently.
Contributed by : Amiy Kumar
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