Eco Intel Series · Case Analysis
Supreme Court of India 2024 Biodiversity · Climate

M K Ranjitsingh & Ors v Union of India & Ors

2024 INSC 280 · Decided March 21, 2024

By Swasthik Narayanan M S · Student, Government Law College, Ernakulam

Chief Justice Dr Dhananjaya Y Chandrachud, Justices J B Pardiawala & Manoj Misra

When protecting a critically endangered bird required dismantling India's solar and wind infrastructure, the Supreme Court faced a collision it had never seen before, not the familiar clash between development and nature, but between two forms of environmental imperative. The answer it reached reshaped how India understands the right to life.

Case Timeline

2011
IUCN classifies the Great Indian Bustard (GIB) as critically endangered. By 2013, Rajasthan estimates only 125 birds remain.
2019
Dr M K Ranjitsingh, a renowned conservationist, files Writ Petition (Civil) No. 838 of 2019 invoking the Supreme Court's original jurisdiction under Article 32.
Apr 2021
Court imposes restrictions on overhead transmission lines across over 99,000 sq km of GIB habitat in Rajasthan and Gujarat.
Nov 2021
Union of India files Interlocutory Application No. 149293 of 2021 seeking modification of the April 2021 directions.
Jan 2024
Court directs Union of India to submit a Comprehensive Status Report on GIB conservation and renewable energy plans.
Mar 2024
Final order: Court adjudicates the modification application , balancing conservation against India's Paris Agreement commitments.

Key Arguments

Petitioners
  • Emergency response plan for GIB protection and recovery
  • Installation of bird diverters; dismantling of power lines, wind turbines, and solar panels in critical GIB habitat
  • No-grazing zones around nesting areas
  • High-voltage overhead powerlines are a leading cause of bird mortality, mandatory undergrounding required
Union of India
  • The restricted area holds a large proportion of India's solar and wind energy potential
  • Undergrounding high-voltage lines is technically and financially impractical
  • A blanket direction would directly undermine India's Paris Agreement commitments, achieving 50% non-fossil installed capacity by 2030

The Court Held

Para 53
"Unlike the conventional notion of sustainable development... the dilemma here involves a nuanced interplay between safeguarding biodiversity and mitigating the impact of climate change... It is imperative to recognise the intricate interface between the conservation of an endangered species and the imperative of protecting against climate change."
Para 24
"Despite a plethora of decisions on the right to a clean environment... it is yet to be articulated that the people have a right against adverse effects of climate change... this right and the right to a clean environment are two sides of the same coin... it is recognised by Articles 14 and 21."
Para 58
"...the court must be alive to these obligations while adjudicating writ petitions which seek reliefs that may hinder these obligations from being fulfilled..."

The Court also emphasised India's extensive commitments under the Kyoto Protocol and Paris Agreement, treating them as reinforcing India's constitutional duty toward renewable energy transition, and acknowledged the existential threat that climate change poses to forest-dwelling, tribal, and indigenous communities whose way of life is inseparable from the land.

Relevance

A New Fundamental Right

The Court officially recognised a "right against the adverse effects of climate change" as part of the right to life (Article 21) and the right to equality (Article 14), the first such articulation in Indian constitutional jurisprudence.

International Commitments as Constitutional Duty

India's Paris Agreement NDCs were treated not merely as diplomatic obligations but as shaping what constitutional courts must weigh when adjudicating environmental writ petitions.

Beyond the Binary

The case refuses the familiar development-versus-environment framing, instead asking how two environmental imperatives, biodiversity and climate, can be balanced. That is the harder, more honest question.