Environmental Law

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

AIR Online 2021 SC 209

Facts

The Great Indian Bustard is a critically endangered bird found mainly in Rajasthan and Gujarat.
Its population had declined because of:
habitat loss;
fragmentation;
agriculture and development;
predators;
collisions with overhead electricity lines.
The bird has limited frontal vision and may fail to detect power lines while flying.
Collisions frequently caused immediate death.
Conservationists approached the Supreme Court seeking protection of the bird’s habitat from overhead transmission infrastructure.
The dispute also involved large renewable-energy projects because solar and wind installations required extensive transmission networks in the same landscape.

Whether overhead power lines in Great Indian Bustard habitat had to be placed underground.
Whether renewable-energy development could continue without species-specific safeguards.
What immediate measures were required to prevent further bird deaths.

The Wildlife (Protection) Act, 1972 requires effective protection of threatened species and their habitats.
Articles 48A and 51A(g) impose duties to preserve wildlife and the environment.
The precautionary principle supports preventive action where further delay may cause irreversible species loss.
Development activity must adopt available measures to avoid or reduce wildlife mortality.
The State must protect an endangered species before its population reaches a point from which recovery is impossible.

The Court treated each collision death as serious because the surviving population was extremely small.
A mortality rate that might appear numerically minor for a common species could be catastrophic for a critically endangered bird.
Scientific material showed that overhead power lines were a significant and preventable cause of death.
The Court therefore rejected the approach of waiting for complete data on every collision.
It applied the precautionary principle because:
extinction is irreversible;
the species reproduced slowly;
transmission expansion was continuing.
The Court distinguished between low-voltage and high-voltage lines.
Low-voltage lines were generally considered more capable of being placed underground.
High-voltage undergrounding involved:
technical difficulty;
cost;
maintenance concerns;
terrain-related limitations.
A committee was therefore required to examine feasibility where undergrounding of high-voltage lines was disputed.
Pending undergrounding, bird diverters had to be installed so that lines became more visible.
The Court extended protection not only to existing priority habitat but also to areas identified as potential habitat.
It also called for:
restrictions on new lines;
conservation breeding;
habitat improvement;
predator control;
scientific monitoring.
Renewable energy was environmentally valuable, but the Court held that one environmental objective could not be pursued by causing extinction of another protected species.

The Supreme Court directed that overhead power lines in identified priority and potential Great Indian Bustard areas be placed underground wherever feasible.
Low-voltage lines were to be undergrounded.
Feasibility of high-voltage undergrounding was to be assessed through an expert committee.
Bird diverters had to be installed immediately on lines awaiting undergrounding.
New transmission infrastructure was subjected to conservation scrutiny.
The order adopted a strongly species-protective and precautionary approach.
However, its broad undergrounding directions were later reconsidered and modified by the Supreme Court in 2024, and a final operational framework was issued in 2025.
It must therefore be read as the first stage of the Great Indian Bustard litigation rather than the current final position.
Use this case for: precautionary undergrounding and bird-diverter measures to prevent extinction-causing power-line collisions.