M.K. Ranjitsinh v. Union of India (2024) [1]

COURT: SUPREME COURT OF INDIA.

BENCH: D.Y. Chandrachud (CJI), Justice Manoj Misra, Justice J.B. Pardiwala.

DATE OF JUDGEMENT: 21 March, 2024.

RELEVANT STATUTES: Articles 21 and 14 of the Indian Constitution.

BRIEF FACTS:

M.K. Ranjitsinh, an environmental enthusiast and ex- IAS officer, filed a writ petition in the Supreme Court of India under Article 32 regarding the conservation of two endangered species, the Great Indian Bustard and the Lesser Florican. The birds were dying after colliding with the high-voltage solar power cable in the regions of Gujarat and Rajasthan. He requested to lay the wires underground, and the Court ordered in his favour on 19.04.2021. The case reached the gates of the Supreme Court in 2024 to review the recommendation of the expert committee.

ISSUES INVOLVED:

• Did our constitution give any protection from the terrible impact of climate change?
• Is it feasible to lay a high-voltage power cable underground?
• How to balance between conservation efforts and sustainable energy production?

ARGUMENTS:

Petitioner’s argument:

M.K Ranjitsinh, an environmentalist, filed a PIL in the Supreme Court to protect the endangered species of the Great Indian Bustard and the Lesser Florican that were dying because of collisions with the overhead power cables in the regions where 90 per cent of their population resides. They argue that due to heavy weight and poor frontal vision, the birds can not spot the solar cable, especially in low light and collide with the cables and eventually die. He also mentioned that the majority of the whole population rests in the same region, and jeopardising the lives of birds of this area is like jeopardising the whole species. According to the Rajasthan government, only 125 GIBs are left [2]which makes each death critical to their existence. They argue that all power lines should be laid underground irrespective of their potential or priority criteria.

Respondent’s argument:

The government argues that the court’s previous mandate of laying all the cables underground is practically impossible due to their high-voltage characteristics and problems like insulation and heat dissipation. The respondent contends that the procedure is extremely expensive to perform, which makes an unreasonable financial burden on the government and ultimately on the consumer.

They contended that it has an important goal of achieving 500GW of renewable energy by 2030 under the Paris Agreement and NDCs. If they follow the petitioner’s advice, then they will lose the rare and important site of energy production in India.

They presented the past year’s data showing that the main reason for the extinction of these species is not the solar cables but the causes like loss of habitat, poaching, predators, naturally low productivity rate and the use of pesticides and insecticides in the field

JUDGEMENT:

The Court held that Article 21 not only includes the right to life but right to have a healthy life. It brought a new interpretation of A. 21 and A. 14, and also understood the practical impossibility of laying the high-voltage cables underground, and hence the Court revised its 2021 judgement. The Court lifted the ban on overhead power lines in potential GIB areas and mandated underground power lines in priority GIB areas if technically feasible. The Court also mandated the formation of a 7-member expert committee to look into the issues, such as identifying the priority and potential stretches for power lines, assessing the effectiveness of bird diverters and conserving the endangered species without stalling on India’s global commitment to reduce its carbon footprint.

RATIO DECIDENDI:

• Article 21 and its power to protect from the adverse effects of climate change.

The bench used this case as an opportunity to address the adverse effects of climate change and give its citizens protection from climate change under Article 21 because every individual needs a clean and pollution-free environment to live; without it, no right to life can be imagined. Without clean air to breathe, clean water to drink, a person cannot live; hence right to breathe in clean air and the right to drink clean water are some of the basic human rights covered in Article 21 of the Constitution. Protection of a species is also a step to protect the environment and in result, the right of an individual to a healthy and pollution-free life.

• Balance between conservation and sustainable energy.

 India is consistent in its environmental conservation efforts and strongly commits to treaties like the Paris Agreement, which demand countries to lower the global temperature to 1.5 degrees Celsius from the pre-industrial era. This arduous task demands that the nation shift from non-renewable energy resources to renewable energy resources. As the region is the major hub for solar energy generation, the cables are used for the transmission of solar power; halting the installation of the cables will also impede the progress of our nation in the generation of renewable energy. The Court held that though the conservation of an endangered species is important, a nation thrives on its energy resources and hampering these resources will jeopardise the energy requirement of the whole nation. The court seeks to harmonise both important interests and protect the birds in a way that does not thwart the energy requirements.

• Infeasible installation in a vast area

The Court admitted the fact that its 2021 judgment was negligent and acknowledged the technical infeasibility of installing the underground power cables in a vast terrain of 99,000 kilometres. The Court also admitted that they are not environmental specialist and they sometimes overlook the ground realities of the situation. Hence, the court removed the restriction on overhead power cables and only allowed it in potential areas that are not very critical to the Great Indian Bustards. The Court also mandated the installation of underground power cables in priority areas.

• Formation of an expert committee

The Court realised its mistake of overlooking the scientific reasoning and data in its previous judgement and hence ordered the formation of an expert-level committee to deeply inspect the matter and to come up with a solution balancing the conservation of the endangered species and reducing the carbon footprint.

OBITER DICTA:

      The obiter dicta of this judgment is considered significant as it deals with a major human crisis, that is, climate change.

Expansion of Article 21-

The Court observed that the right to life includes the right to a healthy life, which again means the right to a pollution-free environment, as this helps the whole nation grow. Although the core issue of this case dealt with the conservation of the Great Indian Bustard, the Court took it as an opportunity to widen the scope of Article 21 and give its citizens relief from climate change impacts. People should be free from the struggle of climate change so that they can work on their development. Take the example of a country like Chad, which is the worst affected by climate change. One of the reasons for its underdevelopment is that the citizens of the nation are busy struggling with climate change.

Balancing between green v. green-

The Court also observed that in situations like these, when there is a conflict between green v. green, the court has to harmonise both the interests as both of these interest serves the nation’s Green Goals.

Community Action-

The Court observed that this case also showcases the exigent need for community action towards wildlife conservation and reveals the fact that situations like these cannot be improved without the whole country coming together and working on this issue. The root cause of this problem lies within community apathy and ignorance towards environmental conservation. Article 51A (g) expects citizens to protect nature, and Article 48A mandates the state’s duty to protect the environment[3]. Though the environment received statutory protection, it will remain at risk until people are not empathetic towards nature.

Overwhelming impact of climate change on marginalised communities-

The court also observed that climate change has a more crippling impact on specific communities, which are marginalised due to their poor habitat, as they are closer to nature, because of which their right to equality is also violated. For example, the fishermen community, which comes under marginalised communities, face greater harm from the flood or tsunami than the common man because they live near the sea shore. So it is our duty to protect these people from the more demeaning impact of climate change by protecting nature.

FINAL DECISION-

The Court held that the conservation of the endangered species is important, but a nation’s commitment is equally important, which in turn has a great impact on a larger masses hence the court ordered for removing the restrictions on the overhead power cables and allowed it in potential areas. The court also ordered for bird diverters and more efficient conservation methods for these species and ordered the formation of an expert committee. Hence, the government won this case.

[1] MK Ranjitsinh v Union of India [2024] INSC 280

[2] Ministry of Environment, Forest and Climate Change, ‘The Great Indian Bustard’ (27/02/2026) https://forest.rajasthan.gov.in/content/raj/forest/en/footernav/department-wings/project-great-indian-bustard.html accessed 28 February 2026.

[3] EVS. Institute, ‘The Fundamental Duty to Protect the Environment: Article 51-A and Citizen Responsibility’ (22 October, 2025) https://evs.institute/environmental-legislations/fundamental-duty-protect-environment-article-51a/ accessed date 28 February 2026.