A) ABSTRACT / HEADNOTE

The case of M.K. Ranjitsinh & Ors. v. Union of India & Ors. addresses the conservation of the critically endangered species, the Great Indian Bustard (GIB). The judgment evaluates the intersection of environmental conservation and renewable energy initiatives, with a specific focus on the impact of overhead power lines on the GIB population. The Court balanced the dual imperatives of preserving biodiversity and advancing renewable energy, crucial to combating climate change. The 2021 decision to underground all power lines in GIB habitats was revisited, given the technical infeasibility and policy considerations surrounding energy and environmental law. By appointing an expert committee, the Court emphasized the necessity of specialized inputs in balancing conservation and sustainable development. Additionally, the judgment underscores India’s constitutional and international obligations to protect the environment and mitigate climate change.

Keywords: Great Indian Bustard, Renewable Energy, Biodiversity Conservation, Climate Change, Environmental Policy

B) CASE DETAILS

i. Judgement Cause Title
M.K. Ranjitsinh & Ors. v. Union of India & Ors.

ii. Case Number
Writ Petition (Civil) No. 838 of 2019

iii. Judgement Date
21 March 2024

iv. Court
Supreme Court of India

v. Quorum
Dr. Dhananjaya Y. Chandrachud, CJI; J.B. Pardiwala, J.; Manoj Misra, J.

vi. Author
Chief Justice Dr. Dhananjaya Y. Chandrachud

vii. Citation
[2024] 3 S.C.R. 1320; 2024 INSC 280

viii. Legal Provisions Involved

• Wild Life (Protection) Act, 1972
• Environment (Protection) Act, 1986
• Electricity Act, 2003
• Articles 14, 21, 48A, and 51A(g) of the Constitution of India

ix. Judgments Overruled by the Case (if any)
Not explicitly mentioned.

x. Case is Related to Law Subjects
Environmental Law, Biodiversity Conservation, Constitutional Law, Renewable Energy Policy

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case stems from concerns over the rapid decline of the GIB population, exacerbated by habitat loss and anthropogenic activities, particularly the construction of overhead transmission lines in Rajasthan and Gujarat. The petition, filed under Article 32 of the Constitution, sought immediate measures for the GIB’s protection, including undergrounding power lines and halting harmful infrastructure projects. The 2021 judgment imposed stringent restrictions but was later challenged due to feasibility issues and implications for India’s renewable energy commitments.

D) FACTS OF THE CASE

1. The GIB population has seen a precipitous decline, with estimates in 2018 indicating fewer than 250 mature individuals.
2. Habitat fragmentation, predation, and fatalities caused by overhead power lines contribute significantly to their endangered status.
3. Rajasthan and Gujarat, home to the GIB, overlap with regions critical for solar and wind energy projects, creating a policy conflict.
4. The 2021 judgment directed undergrounding of all power lines in designated GIB habitats, which was later contested by government agencies citing technical and financial constraints.

E) LEGAL ISSUES RAISED

1. Can a general prohibition on overhead power lines balance environmental and renewable energy goals?
2. Are the measures directed by the Court in 2021 technically feasible and policy-compliant?
3. How should constitutional rights to a healthy environment and sustainable development be harmonized?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. The petitioners emphasized the constitutional duty under Articles 48A and 51A(g) to conserve wildlife and prevent environmental degradation.
2. They highlighted studies attributing significant GIB mortality to collisions with overhead power lines, advocating for underground alternatives.
3. Immediate and stringent measures, including creating predator-proof zones and halting infrastructure expansion, were proposed to avert the species’ extinction.

G) RESPONDENT’S ARGUMENTS

1. The respondents, including Union Ministries, argued that the 2021 directions were impractical and financially unsustainable.
2. They emphasized India’s international climate obligations, such as the Paris Agreement, which necessitate an aggressive transition to renewable energy.
3. Alternative measures, such as installing bird diverters and promoting captive breeding, were presented as feasible conservation strategies.

H) JUDGEMENT

a. Ratio Decidendi
The Supreme Court held that a blanket prohibition on overhead power lines was infeasible. It acknowledged the criticality of GIB conservation while affirming that environmental policy decisions should balance biodiversity preservation with sustainable development and renewable energy goals.

b. Obiter Dicta
The judgment stressed judicial reliance on domain experts for complex environmental adjudication and the necessity of integrated, science-backed approaches in policymaking.

c. Guidelines Issued

1. Formation of an expert committee to evaluate case-specific feasibility of undergrounding power lines.
2. Immediate implementation of bird diverters in priority and potential GIB habitats.
3. Ongoing monitoring of GIB populations and habitats, with periodic reports to the Court.

I) CONCLUSION & COMMENTS

This landmark judgment highlights the Supreme Court’s nuanced approach to environmental jurisprudence, aligning legal directives with practical constraints and broader policy goals. By revisiting the 2021 order, the Court reaffirmed its commitment to safeguarding endangered species without derailing India’s renewable energy transition.

J) REFERENCES

a. Important Cases Referred

1. M.C. Mehta v. Kamal Nath [2000] Supp. 1 SCR 389
2. Virender Gaur v. State of Haryana [1995] 2 SCC 577
3. Karnataka Industrial Areas Development Board v. C. Kenchappa [2006] 6 SCC 371

b. Important Statutes Referred

1. Wild Life (Protection) Act, 1972
2. Environment (Protection) Act, 1986
3. Electricity Act, 2003