M.K. RANJITSINH v. UNION OF INDIA
Balancing Endangered Species Conservation with Renewable Energy Development: Supreme Court Adopts Expert Committee Recommendations for Great Indian Bustard Protection.
Court: Supreme Court of India
Citation: 2025 INSC 1472
Decision Date: 19-12-2025
List of Laws
Article 32 of the Constitution of India; The Electricity Act, 2003; The Companies Act, 2013; The Mines and Minerals (Development and Regulation) Act, 1957; The Environment Protection Act, 1986; The Wildlife (Protection) Act, 1972; Corporate Social Responsibility (CSR); Polluter Pays Principle; Sustainable Development; Environmental Conservation
- Facts: A writ petition was filed in 2019 under Article 32 of the Constitution concerning the conservation of the Great Indian Bustard (GIB) and Lesser Florican, both endangered species. This was tagged with another writ petition and a civil appeal arising from an NGT order. The primary concern was balancing the conservation of these species with the development of renewable energy, particularly regarding overhead power lines. The court had previously issued orders in 2021 and 2024 directing certain measures.
- Procedural Posture: The Supreme Court is hearing the writ petitions and civil appeal, reviewing the recommendations of an Expert Committee formed to address the issues and objections raised by various stakeholders, including renewable energy developers. The court is considering modifications to its earlier orders based on the committee's report and the need to balance environmental conservation with sustainable development.
- Issue: How to balance the conservation of the critically endangered Great Indian Bustard and Lesser Florican with the imperative of promoting renewable energy and sustainable development, particularly concerning the impact of power lines on these species' habitats; and whether the recommendations of the Expert Committee provide a suitable framework for achieving this balance.
- Holding: The Court largely accepts the recommendations of the Expert Committee, directing their implementation with specific timelines. This includes revising priority areas for conservation, implementing mitigation measures for power lines, and conducting further studies on the effectiveness of bird flight diverters. The Court emphasizes the need for a balanced approach that does not sacrifice either environmental conservation or sustainable development.
- Reasoning: The Court relies on the expertise of the Expert Committee, which conducted field visits, stakeholder consultations, and scientific analysis to arrive at its recommendations. The Court emphasizes the importance of a holistic approach that considers the diverse factors affecting the GIB population, including habitat loss, climate change, and power line collisions. The Court also acknowledges India's international commitments to renewable energy and the need to balance conservation efforts with sustainable development goals. The Court rejects arguments for a blanket ban on power lines, favoring nuanced, site-specific recommendations. The Court also highlights the constitutional duty to protect the environment and the role of Corporate Social Responsibility (CSR) in funding conservation efforts.
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