Published On: July 16, 2026
Authored By: Srishna R
Christ Academy Institute of Law, Bengaluru
Abstract
Climate change is no longer solely an environmental concern — it has become a matter of constitutional law and human rights. In India, this shift was crystallized by the Supreme Court’s decision in M.K. Ranjitsinh & Others v. Union of India, in which the Court held that the Constitution guarantees citizens a right to be protected from the adverse effects of climate change, grounded in Articles 14 and 21. In the years following the decision, legislators, litigators, and scholars have continued to debate its implications. This article examines the relationship between climate justice and constitutional law in India, the significance of the Supreme Court’s recognition of climate rights, and the decision’s likely effects on environmental governance, climate litigation, and public policy. It argues that although India still lacks a dedicated, standalone climate change statute, the Court’s decision has established a constitutional framework capable of advancing climate justice and strengthening government accountability.
Introduction
Climate change is one of the most significant challenges faced by constitutional democracies in the current century. As global temperatures rise, extreme weather events become more frequent, biodiversity continues to decline, and environmental degradation accumulates, placing fundamental human rights — including the rights to life, health, livelihood, food, water, and shelter — increasingly at risk. India is especially exposed to these pressures given its large population, significant socio-economic disparities, heavy reliance on climate-sensitive livelihoods, and extensive coastline.[1]
Indian courts have historically taken an expansive approach to environmental protection, with the Supreme Court recognizing a right to a clean and unpolluted environment as part of the right to life. Until recently, however, climate change specifically had not been addressed directly as a constitutional or judicial issue; it was instead treated primarily through executive policy and international agreements. This changed with the Supreme Court’s decision in M.K. Ranjitsinh & Others v. Union of India,[2] a case that arose from a dispute concerning the Great Indian Bustard, an endangered bird species, and the threat posed to it by overhead power transmission lines. The Court held that individuals possess a right to be protected from the impacts of climate change — a decision that has meaningfully reshaped discourse on climate change in India. Since 2025, scholars and commentators have increasingly described the ruling as the starting point for a distinct body of climate constitutionalism in India. What the Court has affirmed, in essence, is that climate change is not merely a policy challenge but a matter that directly implicates the rights of Indian citizens.[3]
The Landmark Decision: M.K. Ranjitsinh v. Union of India
The M.K. Ranjitsinh case centered on efforts to protect the Great Indian Bustard, one of India’s most critically endangered bird species.[4] Petitioners argued that overhead power lines associated with renewable energy projects posed a serious threat to the species’ survival.[5] The Supreme Court was therefore required to balance two significant public interests: environmental and species conservation, and the expansion of renewable energy infrastructure.
In reaching its decision, the Court considered how climate change affects individuals and communities differently, recognizing that its impacts on health, employment, and general welfare fall disproportionately on certain groups. The Court also weighed the long-term survival of the Great Indian Bustard, concluding that the species requires meaningful protection from the risks posed by power infrastructure, and that renewable energy development should be pursued in a manner that does not undermine that protection. Rather than favoring one interest over the other, the Court sought a resolution that would accommodate both environmental and species conservation, and the continued growth of renewable energy.
Ultimately, the Court held that individuals have a right to be protected from the effects of climate change, grounding this right in Articles 14 and 21 of the Constitution.[6] It reasoned that environmental degradation and climate change directly affect people’s lives and can exacerbate existing social inequalities, and that the Constitution’s protections should therefore extend beyond conventional environmental harms to climate-specific harms as well. This marks the first instance in which the Supreme Court has explicitly characterized climate change as a matter of fundamental rights — situating it, alongside the right to life, squarely within the constitutional rights framework.
Constitutional Significance of the Judgment
The Supreme Court’s recognition of a right to be protected from the effects of climate change represents a significant development in Indian constitutional law. The Court has framed climate change not merely as a matter of executive policy discretion, but as an issue implicating citizens’ basic rights — meaning the government bears an affirmative obligation to take protective action. Where the government fails to meet that obligation, the judiciary is empowered to review its conduct and hold it accountable, using Articles 14 and 21 as the constitutional basis for that review.
Under this framework, the right to a safe and healthy environment — including access to clean air and water — is treated as part of the right to life under Article 21. The Court has effectively read Article 21 to encompass a right to a stable and non-damaging climate, extending the traditional right-to-life doctrine, first broadened in Maneka Gandhi v. Union of India,[7] into the climate context. The Court has also invoked the language of climate justice, recognizing that the effects of climate change are not evenly distributed: women, children, farmers, and economically disadvantaged communities bear a disproportionate share of the burden. By invoking Article 14’s guarantee of equal treatment, the Court has signaled that the government must take affirmative steps to safeguard the environment in a manner that gives all citizens, including the most vulnerable, an equal opportunity to thrive.
Impact on Climate Litigation in India
The recognition of climate rights is likely to have a substantial effect on climate litigation in India. It strengthens the foundation for Public Interest Litigation by giving individuals and environmental organizations clearer legal grounds to challenge government climate policy, environmentally harmful projects, or inadequate climate preparedness.[8] Courts are likely to scrutinize government action more closely to determine whether it adequately protects citizens from climate-related harms — an approach with precedent in comparative climate litigation, such as the Dutch Supreme Court’s decision in Urgenda Foundation v. State of the Netherlands[9] — and the judgment increases the degree of accountability the government faces for its environmental decisions.
Because climate protection is now understood as a constitutional matter, citizens can reasonably expect government decision-making to reflect environmental considerations and comply with constitutional standards. This is also likely to change how government agencies approach decision-making more broadly: agencies will need to more carefully assess the climate implications of infrastructure approvals, development projects, and national policy, rather than treating environmental impact as a secondary consideration.
Challenges and Limitations
Despite the significance of this recognition, meaningful challenges remain — and international scholarship on rights-based approaches to climate change cautions that constitutional recognition alone does not guarantee effective implementation.[10] Chief among the domestic challenges is that India still lacks a dedicated, standalone statute addressing climate change; existing environmental protections are instead distributed across a range of separate laws and regulations. While constitutional recognition of climate rights is an important development, translating that recognition into enforceable outcomes will likely require clear, comprehensive legislation that is both accessible to the public and consistently enforced.
The judiciary also faces practical difficulties in implementing this right. Courts must determine what individuals and companies can and cannot do in relation to climate change — for example, permissible pollution levels or required adaptation measures — questions that often turn on complex scientific and technical evidence. Courts must therefore proceed cautiously to avoid overstepping the proper role of government agencies and technical experts, consistent with the restraint the Supreme Court has shown in other environmental matters, such as Narmada Bachao Andolan v. Union of India.[11] India also faces the broader challenge of pursuing continued economic growth while protecting the environment, since infrastructure development, renewable energy expansion, and biodiversity conservation can sometimes conflict with one another — tensions that existing policy instruments, such as the National Action Plan on Climate Change, have long sought to manage but have not fully resolved.[12] Balancing these competing interests will require courts to make difficult decisions in the years ahead, guided by the twin goals of environmental protection and human welfare.
Conclusion
The Supreme Court’s decision in M.K. Ranjitsinh v. Union of India marks a significant milestone for climate rights in India. By grounding climate protection in Articles 14 and 21, the Court has established that safeguarding the climate is not a distant policy aspiration but a fundamental right belonging to the people.
The decision represents a meaningful step forward for climate justice and signals a heightened expectation that government will act responsibly in protecting the environment. It also gives individuals a clearer avenue to seek judicial relief where they are harmed by climate change. Significant gaps remain — most notably, the continued absence of a dedicated climate change statute — but the Court’s decision lays the groundwork for a new constitutional approach to climate change in India, one grounded in the recognition that citizens possess rights that must be actively protected. The decision in M.K. Ranjitsinh v. Union of India stands as a milestone in the development of climate rights jurisprudence in India.
References
[1] United Nations Development Programme, Human Development Report 2023/24 (UNDP 2024).
[2] M.K. Ranjitsinh v Union of India (2024) SCC OnLine SC 321.
[3] Shibani Ghosh, ‘Climate Litigation in India: Opportunities and Challenges’ (2023) 15 NUJS Law Review 1.
[4] M.K. Ranjitsinh v Union of India (2024) SCC OnLine SC 321.
[5] ibid.
[6] Constitution of India 1950, arts 14 and 21.
[7] Maneka Gandhi v Union of India (1978) 1 SCC 248.
[8] Shibani Ghosh, ‘Climate Litigation in India: Opportunities and Challenges’ (2023) 15 NUJS Law Review 1.
[9] Urgenda Foundation v State of the Netherlands [2019] ECLI:NL:HR:2019:2007.
[10] Lavanya Rajamani, ‘The Increasing Currency and Relevance of Rights-Based Perspectives in the International Negotiations on Climate Change’ (2010) 22 Journal of Environmental Law 391.
[11] Narmada Bachao Andolan v Union of India (2000) 10 SCC 664.
[12] Ministry of Environment, Forest and Climate Change, National Action Plan on Climate Change (Government of India 2008).
