M.K. Ranjitsinh & Ors. v. Union of India & Ors.

M.K. Ranjitsinh & Ors. v. Union of India & Ors.

Case nameM.K. Ranjitsinh & Ors. v. Union of India & Ors.
Case numberW.P.(C) No. 838/2019
Court typeSupreme Court of India
Judgment date21 March 2024
BenchD.Y. Chandrachud, C.J.; J.B. Pardiwala and Manoj Misra, JJ.

Case Background

Parties and roles: M.K. Ranjitsinh & Ors. is the petitioner who initiated or carried the matter to the Supreme Court. Union of India & Ors. is the respondent opposing the relief or defending the challenged action, decision, law or proceeding. The labels “plaintiff” and “defendant” are generally not used here because this is a constitutional writ proceeding. The Great Indian Bustard frequently collided with overhead transmission lines across Rajasthan and Gujarat, while the same region is central to India's solar and wind expansion. A blanket undergrounding order protected the species but created engineering, safety, cost and energy-transition problems. The Court therefore had to balance biodiversity protection with renewable-energy infrastructure and India's climate obligations. The dispute became a vehicle for explaining how climate change affects life, health, equality and vulnerable communities. Procedural setting: 2019: Petition sought urgent protection of the endangered Great Indian Bustard. | Apr 2021: Supreme Court broadly required undergrounding of power lines in priority and potential habitats. | 2022-2024: Governments and renewable-energy developers sought modification on feasibility grounds. | 21 Mar 2024: Court created an expert process and articulated climate-related constitutional rights. The central problem before the Court was how should the Court reconcile conservation of a critically endangered species with renewable-energy development? Do Articles 14 and 21 protect people against the adverse effects of climate change? What expert mechanism should replace a uniform undergrounding rule? The controversy was considered in the framework of Wild Life (Protection) Act, 1972; Electricity Act, 2003; Environment (Protection) Act, 1986; international climate and biodiversity instruments, together with Constitution arts.14, 21, 48A and 51A(g). The wider importance of the case lies in climate justice; environmental rule of law; intergenerational equity; proportionality; precautionary principle; sustainable development.

Key Arguments

Conservationists sought strict undergrounding and habitat safeguards to prevent extinction. The Union and energy entities argued that high-voltage undergrounding was often technically infeasible and that slowing renewable energy would itself worsen climate harms. All sides sought a scientifically workable solution. Competing positions in context: M.K. Ranjitsinh & Ors.'s position: as the petitioner, M.K. Ranjitsinh & Ors. sought the relief indicated by the questions of law and challenged the opposing action or interpretation. The claim was that the Court should apply the governing provisions consistently with Climate justice; environmental rule of law; intergenerational equity; proportionality; precautionary principle; sustainable development. Union of India & Ors.'s position: as respondent, Union of India & Ors. resisted that relief, defended the impugned measure or decision, or proposed a narrower interpretation of the Court's power and the applicable law. The Court therefore had to test these submissions against Wild Life (Protection) Act, 1972; Electricity Act, 2003; Environment (Protection) Act, 1986; international climate and biodiversity instruments and Constitution arts.14, 21, 48A and 51A(g), the record of the proceedings and binding precedent. This summary states the principal controversy in accessible language; the official judgment remains authoritative for counsel-specific submissions and paragraph references.

Case timeline

2019: Petition sought urgent protection of the endangered Great Indian Bustard.

Apr 2021: Supreme Court broadly required undergrounding of power lines in priority and potential habitats.

2022-2024: Governments and renewable-energy developers sought modification on feasibility grounds.

21 Mar 2024: Court created an expert process and articulated climate-related constitutional rights.

Questions of Law

How should the Court reconcile conservation of a critically endangered species with renewable-energy development?

Do Articles 14 and 21 protect people against the adverse effects of climate change?

What expert mechanism should replace a uniform undergrounding rule?

Judgment

The Court recognised a constitutional right to be free from the adverse effects of climate change under Articles 14 and 21. It modified the blanket approach, constituted an expert committee to identify species-sensitive measures, and required a context-specific balance among biodiversity, energy security and climate mitigation. Existing priority-area protections remained subject to expert review and further orders. Effect of the decision: the ruling explains or applies Climate justice; environmental rule of law; intergenerational equity; proportionality; precautionary principle; sustainable development and binds the parties to the operative directions made in W.P.(C) No. 838/2019. It also guides lower courts and public authorities on materially similar questions under Wild Life (Protection) Act, 1972; Electricity Act, 2003; Environment (Protection) Act, 1986; international climate and biodiversity instruments. Scope and caution: only the ratio decidendi and operative directions of the signed judgment are binding; summaries should not be treated as substitutes for the judgment, separate opinions, later review orders or subsequent precedent.

Statutory Provisions / Acts Involved

Wild Life (Protection) Act, 1972; Electricity Act, 2003; Environment (Protection) Act, 1986; international climate and biodiversity instruments

Articles of the Constitution of India Involved

Constitution arts.14, 21, 48A and 51A(g)

Legal Principles

Climate justice; environmental rule of law; intergenerational equity; proportionality; precautionary principle; sustainable development

Neutral Citation

2024 INSC 280

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