1. M.K. Ranjitsinh v. Union of India & Others
Citation: 2025 INSC 1472
Strategic Context and Importance
This judgment marks a transformative era in environmental law, navigating the precarious "Green vs. Green" dilemma. The Court was confronted with a zero-sum conflict: the localized protection of the critically endangered Great Indian Bustard (GIB), known as the Godawan, and the Lesser Florican (LF), against the national imperative of expanding renewable energy infrastructure to meet global climate commitments. This case emphasizes that the "Right to a Clean Environment" under Article 21 is not merely anthropocentric but carries an ecocentric fiduciary duty to prevent the irreversible extinction of flagship species.
Case Details and Factual Matrix
The factual matrix centers on the precipitous decline of the GIB and LF populations in the Thar Desert, primarily due to habitat fragmentation and fatal collisions with high-tension power lines. Following an April 2021 interim order that imposed a blanket ban on overhead lines across 99,000 sq. km, the Union sought modifications, citing technical impossibilities in undergrounding high-voltage lines and the risk of derailing India's transition to non-fossil fuels.
Judicial Reasoning and Thematic Analysis
The central legal tension involved balancing the "Species Best Interest" standard with the national energy transition. The Court transitioned from a rigid prohibition to a nuanced, expert-led mitigation framework. Utilizing an Expert Committee, the Court acknowledged that "departmentalism" and technical constraints made a blanket ban unfeasible. However, it reinforced "Eco-veneration"—the intrinsic value of the species—by prioritizing survival in core habitats. The ruling replaces broad geography with scientific precision, identifying specific "powerline corridors" and adopting the "Polluter Pays" principle.
Ultimate Ruling and Specific Directives
- Geographical Rationalization: Rajasthan Priority Area refined to 14,013 sq. km; Gujarat Revised Priority Area established at 740 sq. km.
- Technical Mandates: 11kV and below require mandatory Aerial Bunched Cables. 33kV requires immediate undergrounding of 80 km in Rajasthan and 79.2 km in Gujarat. 66kV and above require re-routing through dedicated 5 km wide corridors.
- Corporate Mandate: Invoked Sec 135 and 166(2) of the Companies Act, ruling that Corporate Social Responsibility (CSR) inherently includes Corporate Environmental Responsibility (CER).