Introduction
- M.K. Ranjitsinh v. Union of India is a significant Supreme Court of India judgment delivered on 21 March 2024 in the context of protecting the Great Indian Bustard (GIB) and the Lesser Florican, both extremely threatened bird species.
- The case became especially important because it dealt with the conflict between:
- species conservation
- renewable energy infrastructure
- and the broader issue of climate change and constitutional rights.
Background of the case
- The writ petition under Article 32 was filed to seek urgent protection for the Great Indian Bustard and the Lesser Florican, whose survival was threatened by habitat loss and especially by collisions with overhead transmission lines in parts of Rajasthan and Gujarat.
- In its earlier order dated 19 April 2021, the Supreme Court had imposed strong restrictions on overhead transmission lines in a very large area of about 99,000 sq. km., and had directed undergrounding in key habitats, subject to feasibility.
Why the case returned to the Court
- The Union of India later sought modification of the 2021 order, arguing that:
- the blanket restriction had serious consequences for the power sector
- undergrounding high-voltage transmission lines was often technically impractical
- the affected region had major potential for solar and wind energy
- and India’s renewable-energy commitments would be harmed.
- The Court therefore had to reconsider how to balance endangered species protection with India’s climate and energy commitments.
Main issue before the Court
- The central issue was whether the earlier blanket ban or near-ban on overhead transmission lines in the GIB landscape should continue, or whether a more nuanced approach was required.
- The case therefore became a major example of judicial balancing between:
- biodiversity conservation
- infrastructure development
- renewable energy expansion
- and climate justice.
Important constitutional holding
- One of the most discussed parts of the judgment is the Supreme Court’s observation that, reading Article 14 and Article 21 in light of constitutional principles, state action, and scientific consensus, there exists a right to be free from the adverse effects of climate change.
- This made the case important not only for wildlife law, but also for the emerging field of climate-change jurisprudence in India.
Climate change aspect
- The Court discussed India’s international commitments and the importance of renewable energy in combating climate change. It treated climate change as a serious constitutional and environmental concern rather than a purely policy matter.
- At the same time, it did not say that climate goals automatically override wildlife protection. Instead, it emphasized the need for a holistic balance.
Key reasoning of the Court
- The Court held that it was not proper to continue a blanket prohibition across the entire large notified zone, because such an approach lacked sufficient technical basis in all cases.
- It observed that a broad ban could undermine renewable-energy expansion without necessarily being the best or only way to protect the Great Indian Bustard.
Modification of the 2021 order
- The Supreme Court recalled the injunction imposed by the 19 April 2021 order over the priority and potential GIB areas.
- In place of the blanket direction, it decided that a more technically informed approach should be evolved through an Expert Committee.
Expert Committee
- The Court directed that the Expert Committee appointed by it would lay down suitable parameters for dealing with power infrastructure in the relevant GIB areas.
- This meant that future decisions on undergrounding, overhead lines, and mitigation would depend on a case-specific and expert-led approach, rather than a one-size-fits-all judicial ban.
Bird diverters
- Even while modifying the earlier blanket restriction, the Court continued to stress the importance of protective measures such as bird flight diverters for existing and relevant overhead lines.
- The judgment and later proceedings treated bird diverters as an important mitigation tool pending or in place of undergrounding where appropriate.
Great Indian Bustard aspect
- The Court recorded that the Great Indian Bustard is a critically endangered species with a very small remaining population, concentrated largely in Rajasthan.
- It accepted that overhead transmission lines were one important cause of mortality, though not the only threat; the judgment also noted habitat loss, predation, low reproductive rate, and other pressures.
Balancing approach
- The Court said it was necessary to balance two crucial goals:
- conservation of the Great Indian Bustard
- and protection of the environment more broadly through climate mitigation and renewable energy.
- It explicitly said that neither goal should be sacrificed at the altar of the other.
Why the judgment is important
- The case is important for environmental law because it moved beyond a simple conservation-versus-development formula and treated the matter as a complex constitutional balance between:
- biodiversity protection
- climate action
- energy transition
- scientific feasibility.
- It is also important because it is one of the clearest recent Indian judgments to recognize a constitutional dimension to climate harms.
What the judgment did not do
- The Court did not abandon the protection of the Great Indian Bustard.
- It also did not give a free hand to all renewable-energy projects. Instead, it replaced the previous blanket judicial direction with a more expert-driven regulatory approach.
Subsequent relevance
- The 2024 judgment remained highly relevant in later proceedings, and the 19 December 2025 Supreme Court decision in the same litigation built on the expert-committee process that the 2024 judgment had set in motion.
- So, for exam purposes, the 2024 decision is best understood as the judgment that:
- modified the 2021 blanket restriction
- recognised a climate-related right under Articles 14 and 21
- and shifted the matter to an expert-led balancing framework.
Key points to remember
- Decided on 21 March 2024.
- Concerned protection of the Great Indian Bustard and Lesser Florican.
- Modified the earlier 19 April 2021 blanket restriction on overhead transmission lines.
- Held that there is a right to be free from the adverse effects of climate change under the constitutional framework of Articles 14 and 21.
- Replaced blanket directions with an Expert Committee–based approach.
- Emphasised balance between species conservation and renewable energy / climate commitments.
Conclusion
- Ranjitsinh v. Union of India (2024) is a landmark Supreme Court judgment at the intersection of wildlife conservation, climate change, and constitutional law. Its lasting importance lies in recognising climate-related rights while insisting that biodiversity conservation and clean-energy transition must be pursued together, through a scientifically informed balance rather than an absolute ban.
