Judgement Briefs

Environmental Law

M.K. Ranjitsinh v. Union of India - Great Indian Bustard Case III

2025 INSC 1472

Citation
2025 INSC 1472
Court
Supreme Court of India
Date
19 Dec 2025
Bench
P.S. Narasimha & Atul S. Chandurkar, JJ.

Facts

  • Following the 2024 judgment, the Supreme Court-appointed expert committee studied:
  • Great Indian Bustard habitat;
  • bird movement;
  • transmission lines;
  • wind and solar infrastructure;
  • undergrounding feasibility;
  • conservation requirements.
  • The committee identified revised priority areas in Rajasthan and Gujarat.
  • It recommended differentiated measures rather than a single rule for every project.
  • The Court considered objections from:
  • conservationists;
  • the Union Government;
  • State authorities;
  • renewable-energy developers;
  • transmission agencies.
  • The principal task was to convert the 2024 balancing exercise into a final and enforceable operational regime.

Issue

  • What geographical areas required the highest level of protection.
  • Which new energy projects and transmission lines should be prohibited or restricted.
  • How existing infrastructure should be treated.
  • Whether project-specific mitigation should replace blanket undergrounding.

Rule

  • The survival of a critically endangered species requires landscape-level protection, not merely protection of individual birds.
  • The precautionary principle permits strong restrictions where future development may cause irreversible habitat loss.
  • Sustainable development requires scientifically differentiated regulation rather than either:
  • unrestricted construction; or
  • technically impossible universal prohibition.
  • Expert recommendations should receive substantial weight where they result from multidisciplinary study and transparent evaluation.
  • Existing projects do not obtain immunity from necessary mitigation merely because investment has already occurred.

Application

  • The Court accepted that the Great Indian Bustard required clearly protected priority landscapes.
  • It relied upon the expert committee’s field-based identification rather than retaining earlier boundaries without scientific revision.
  • Within the revised priority areas, the Court treated further fragmentation as a serious survival threat.
  • Power lines were not the only concern.
  • Wind turbines, solar parks, roads and associated infrastructure could:
  • disturb breeding;
  • fragment movement corridors;
  • increase collision risks;
  • reduce usable habitat.
  • The Court therefore applied different controls to different activities.
  • New overhead lines were heavily restricted and generally had to use approved corridors or mitigation.
  • Lower-voltage local systems could be treated differently where appropriate safeguards were available.
  • New wind turbines were prohibited in the revised priority area because of both collision and habitat concerns.
  • New large solar developments and expansion of existing solar parks were also restricted.
  • For existing lines, the Court avoided automatic closure of all infrastructure.
  • It required project-specific examination of:
  • undergrounding;
  • rerouting;
  • line marking;
  • bird diverters;
  • removal of dangerous segments;
  • habitat restoration.
  • This recognised that some existing systems served essential public functions but still had to reduce their ecological impact.
  • The Court accepted the committee’s approach because it connected each measure with:
  • actual habitat use;
  • bird behaviour;
  • engineering feasibility;
  • conservation urgency.
  • It also emphasised that energy companies and public authorities share responsibility for biodiversity protection.
  • Environmental responsibility cannot be limited to carbon reduction while ignoring species extinction.

Conclusion

  • The Supreme Court substantially accepted the expert committee’s recommendations and issued final binding directions.
  • Revised priority areas were recognised in Rajasthan and Gujarat.
  • Within those areas:
  • new overhead transmission was substantially restricted;
  • dedicated routing and mitigation were required;
  • new wind turbines were prohibited;
  • new large solar projects and expansion of existing solar parks were restricted.
  • Existing high-risk infrastructure had to undergo project-specific mitigation, including undergrounding, rerouting or bird-protection measures where recommended.
  • The Court replaced the broad 2021 formula with a detailed, expert-led and landscape-specific regime.
  • This 2025 judgment represents the current final stage of the three Great Indian Bustard decisions in the index.
  • It demonstrates that renewable energy must itself be planned in an ecologically responsible manner.
  • Use this case for: the final location-specific framework governing energy infrastructure in Great Indian Bustard habitat.