M.K. Ranjitsinh v. Union of India
(2025) INSC 1472
Key Issue / Question of Law
How should the conservation of the critically endangered Great Indian Bustard (GIB) and Lesser Florican be reconciled with the imperative of green energy generation to address climate change concerns, specifically regarding overhead transmission lines, wind turbines, and solar installations in priority habitats?
Ratio Decidendi
Environmental conservation and climate change mitigation are not competing silos but must be balanced holistically. Courts must rely on domain experts for complex environmental policy decisions rather than issuing sweeping directions in the absence of evidence. Corporate Social Responsibility (CSR) inherently includes 'Environmental Responsibility', and corporations share the fundamental duty under Article 51A(g) of the Constitution of India to protect wildlife. The 'Polluter Pays' principle applies to energy generators operating in endangered species habitats, requiring them to act as 'guests' and direct CSR funds toward in-situ and ex-situ conservation efforts. Blanket directions for mitigation measures like Bird Flight Diverters must await scientific validation of effectiveness, durability, and maintenance feasibility.
Holding / Decision
The Supreme Court accepted the Expert Committee's recommendations, approving revised priority areas of 14,013 sq. kms for Rajasthan and 740 sq. kms for Gujarat. The Court prohibited new overhead powerlines, wind turbines, and solar parks/plants within these priority areas subject to certain exceptions, and directed immediate rerouting and undergrounding of critical power lines within two years. The Court declined to issue a blanket direction for Bird Flight Diverters, directing further scientific studies. It held that corporations must direct CSR funds toward GIB conservation, applying the Polluter Pays principle.
Background & Facts
The Great Indian Bustard (GIB), the state bird of Rajasthan, is a critically endangered species facing extinction, with its population having declined by over 90% in recent decades. A writ petition under Article 32 of the Constitution of India was filed before the Supreme Court in 2019 seeking directions to conserve the bird. On 19 April 2021, the Supreme Court issued an interim order imposing restrictions on setting up overhead transmission lines across approximately 99,000 square kilometers and appointed a three-member committee to examine the feasibility of laying high-voltage underground power lines. The Court also directed installation of bird diverters on existing overhead lines in priority areas. In November 2021, the Union of India sought modification of this order, arguing it had severe adverse implications for India's power sector, transition away from fossil fuels, and international climate commitments. Recognizing these constraints, the Supreme Court modified its order on 21 March 2024, lifting the blanket ban and forming a multi-member Expert Committee to propose balanced conservation strategies. The Committee submitted comprehensive reports outlining specific mitigation measures for Rajasthan and Gujarat, which the Supreme Court largely accepted.
Statutes Involved
- Article 51A(g), Constitution of India — Fundamental duty of every citizen to protect and improve the natural environment including forests, lakes, rivers, and wildlife, and to have compassion for living creatures
- Article 32, Constitution of India — Right to constitutional remedies, including writ jurisdiction for enforcement of fundamental rights
- Wildlife Protection Act, 1972 — Provides for protection of wild animals, birds, and plants; Schedule I lists the Great Indian Bustard as a critically endangered species receiving the highest level of protection
- Section 135, Companies Act, 2013 — Mandates Corporate Social Responsibility (CSR) spending for companies meeting certain thresholds
Full Analysis
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Key Conditional Rule / Important Caveat
This judgment applies ONLY where there is a direct conflict between two environmental goods (e.g., species conservation vs. climate mitigation) AND an expert committee has conducted site-specific, evidence-based assessments. If there is no expert committee report, or if the environmental harm is purely localized without a competing global/ national environmental interest, the Court may revert to a more protective, precautionary approach favouring conservation. The balancing test does not apply to cases involving irreversible ecological damage or species extinction risk where no countervailing environmental benefit exists.
Courtroom Arguments
For Petitioner
Conservation Cannot Yield to Climate Mitigation — (2025) INSC 1472
The Great Indian Bustard is critically endangered with population below 200 individuals.
For Respondent
Balanced Expert Approach Required, Not Bans — (2025) INSC 1472
Blanket conservation bans would force a backslide to coal-powered generation, causing massive carbon emissions that ultimately harm the GIB's habitat through climate change.
Disclaimer: This summary is prepared by Agarawal Associates for informational purposes only. It does not constitute legal advice. For legal matters, consult a qualified advocate. © 2026 Agarawal Associates — apexdigest.in