Legal Review and Analysis of MK Ranjitsinh & Ors vs Union of India & Ors 2025 INSC 1472

Case Synopsis

M.K. Ranjitsinh & Ors. vs. Union of India & Ors. (2025 INSC 1472)

Synopsis : The Supreme Court forged a jurisprudential equilibrium between safeguarding a critically endangered avian species, the Great Indian Bustard, and sustaining India's renewable energy transition, advocating for science-driven, zonal mitigation over absolute prohibitions.

1. Heading of the Judgment

Case Name: M.K. Ranjitsinh & Others vs Union of India & Others
Citation: 2025 INSC 1472
Court: Supreme Court of India
Judges: Justice Pamidighantam Sri Narasimha, Justice Atul S. Chandurkar
Date: December 19, 2025

2. Related Laws and Sections

The judgment interprets and applies the following legal provisions:

• Article 32 of the Constitution of India: Invoked for the enforcement of fundamental rights, specifically the right to a healthy environment under Article 21.

• Article 51A(g) of the Constitution: Fundamental duty of every citizen to protect and improve the natural environment.

• Sections 135 & 166 of the Companies Act, 2013: Pertaining to Corporate Social Responsibility (CSR) and the duty of directors to act in the best interests of the community and environment, establishing that "Corporate Social Responsibility" inherently includes "Corporate Environmental Responsibility."

• Section 68 of the Electricity Act, 2003: Concerning the installation and approval of overhead power lines.

• The Wildlife (Protection) Act, 1972: Provides the framework for the declaration of protected areas like sanctuaries and conservation reserves.

• The Environment (Protection) Act, 1986 & The Mines and Minerals (Development and Regulation) Act, 1957: Referenced in the context of regulatory oversight for mining activities.

3. Basic Judgment Details

Facts of the Case

The writ petition was filed in 2019 for the urgent conservation of the critically endangered Great Indian Bustard (GIB) and the Lesser Florican. The primary threat identified was bird mortality due to collisions with overhead power transmission lines, especially those associated with the rapid expansion of solar and wind energy infrastructure in Rajasthan and Gujarat. An interim order in April 2021 imposed a blanket prohibition on new overhead lines in a vast area (~99,000 sq km). Subsequently, the Union Government sought modification, arguing this hampered India's renewable energy goals and international climate commitments. The Court, in March 2024, acknowledged the need to balance species conservation with clean energy imperatives and constituted an Expert Committee to devise a nuanced solution.

Issues in the Judgment

1. How to reconcile the imperative of protecting the critically endangered Great Indian Bustard from extinction (primarily due to power line collisions) with the national and global imperative of transitioning to renewable energy to combat climate change.

2. The extent to which judicial directions should mandate specific technical solutions like undergrounding power lines or installing Bird Flight Diverters (BFDs).

3. Determining the specific geographical areas (Priority Areas) where stringent conservation measures must apply.

4. The role of corporate entities, particularly renewable energy generators, in bearing responsibility for environmental conservation.

Ratio Decidendi (Court's Reasoning)
The Supreme Court adopted a balanced, evidence-based approach, giving significant weight to the recommendations of a domain-specific Expert Committee. The Court reasoned that:

• A blanket, one-size-fits-all judicial order (like the 2021 direction for undergrounding) was unsustainable as it failed to account for technical feasibility, economic viability, and the broader environmental cost of foregoing renewable energy.

• Environmental adjudication in complex techno-ecological matters must rely on expert opinion and scientific data. The Court's role is to ensure a fair process and enforce reasoned outcomes, not to dictate engineering solutions.

• The principles of sustainable development and the precautionary principle must be applied harmoniously. Sacrificing a critically endangered species is unacceptable, but so is adopting a conservation strategy that inadvertently exacerbates the larger crisis of climate change.

• Corporate responsibility, under CSR mandates, must explicitly include environmental responsibility, especially when corporate operations impact fragile ecosystems and endangered species.

4. Core Principle of the Judgment

Title: Balancing Ecological Imperative with Sustainable Development: A Precautionary yet Pragmatic Approach

The Central Dilemma and the Court's Resolution:
The core issue was a conflict between two paramount public goods: preventing the extinction of a flagship species (the GIB) and advancing green energy to mitigate planetary climate change. The Supreme Court moved away from an absolutist position favoring one over the other.

The judgment establishes the core principle that in matters involving complex socio-ecological and techno-economic trade-offs, the judiciary must act as a facilitator of informed, science-based decision-making rather than as a primary decision-maker. It underscores that the goal of ecological protection and the goal of sustainable development are not to be seen as being in disjunctive silos; neither can be sacrificed at the altar of the other.

The Court achieved this balance by

1. Deferring to Expertise: It constituted and largely upheld the recommendations of a multidisciplinary Expert Committee comprising wildlife ecologists, forest officials, and power transmission engineers.

2. Adopting a Nuanced, Zonal Approach: It approved the Committee's recommendation to define smaller, scientifically identified "Revised Priority Areas" (14,013 sq km in Rajasthan, 740 sq km in Gujarat) for intensive conservation, as opposed to the earlier vast area of 99,000 sq km.

3. Promoting Strategic Mitigation over Blanket Bans: Instead of a universal order for undergrounding, it endorsed a mix of solutions—targeted undergrounding of critical lines, rerouting of others through designated power corridors, and the use of insulated cables—specific to the voltage and location of the power lines.

4. Emphasizing Holistic Conservation: The judgment linked infrastructure mitigation with parallel measures like habitat restoration, predator management, community engagement, and declaring conservation reserves, recognizing that power lines are only one of multiple threats.

5. Analysis and Supreme Court's Directions

The Court meticulously analyzed objections from both conservationists (petitioners) and renewable energy developers, ultimately issuing the following key directions based on the Expert Committee's report:

A. On Conservation Zones:

• The Revised Priority Areas (14,013 sq km in Rajasthan, 740 sq km in Gujarat) are formally approved. No further addition of the 657 sq km Rasia region is ordered, as the Committee's rationale regarding existing dense power infrastructure was accepted.

B. On Power Infrastructure in Priority Areas:

• Future Projects: No new wind turbines or new solar plants above 2 MW capacity are permitted within Revised Priority Areas. New overhead power lines can only be laid through dedicated power line corridors identified by the Committee.

• Existing Lines:
  33 kV lines: 80 km in Rajasthan and 79.2 km in Gujarat must be undergrounded immediately.
  66 kV and above lines: Specific identified lines must be rerouted or placed in horizontal configuration within a time-bound manner.
  11 kV and below lines: Must be mitigated using insulated cables (horizontal configuration or bunched). No mitigation is required within a 100-meter buffer of settlement boundaries.

• Undergrounding of Critical Lines: The Inspector General, Wildlife Division, MoEFCC is made responsible for ensuring the undergrounding of approximately 250 km of critical power lines identified by the Wildlife Institute of India (WII) within two years.

C. On Bird Flight Diverters (BFDs):

• The Court did not mandate the universal installation of BFDs, agreeing with the Committee that their efficacy for bustards is unproven and maintenance is challenging.

• Directed the MoEFCC to ensure further scientific studies and pilot projects to assess BFD effectiveness before considering wider deployment.

D. On Corporate Responsibility:

• Held that Corporate Social Responsibility (CSR) under the Companies Act inherently includes Corporate Environmental Responsibility. Companies, especially in the renewable sector, must fund conservation efforts as part of their statutory and fundamental duty.

E. On Optimization of Lines:

• Directed that routes of new power lines from multiple renewable plants to common pooling stations should be optimized to share a maximum common stretch, minimizing the spread of linear infrastructure.

6. Final Outcome

The writ petition and connected civil appeal were disposed of. The Supreme Court's order dated April 19, 2021, was modified. The directions of the Court, largely endorsing the Expert Committee's plan, aim to create a implementable framework that seeks to ensure the survival of the Great Indian Bustard while allowing for the responsible expansion of renewable energy infrastructure in the ecologically sensitive regions of Rajasthan and Gujarat.

7. MCQ Questions Based on the Judgment

Question 1: In the M.K. Ranjitsinh vs Union of India (2025) judgment, what was the Supreme Court's primary reason for not mandating the universal installation of Bird Flight Diverters (BFDs) on power lines in the Great Indian Bustard habitat?
A) BFDs are prohibitively expensive for the government to install.
B) Their efficacy in preventing bustard collisions is scientifically unproven in the Indian context, and maintenance is a major concern.
C) The Expert Committee found that BFDs actively harm the bustard's breeding patterns.
D) Renewable energy companies refused to bear the cost of installation.

Question 2: The Supreme Court, in the above judgment, interpreted the Corporate Social Responsibility (CSR) mandate under the Companies Act, 2013, to explicitly include which of the following responsibilities?
A) Responsibility to maximize shareholder profits in renewable energy projects.
B) Responsibility to provide employment to local communities in Rajasthan and Gujarat.
C) Corporate Environmental Responsibility, making it obligatory for companies to fund species conservation.
D) Responsibility to subsidize electricity tariffs for domestic consumers.