From CSR to Corporate Environmental Responsibility:
Ecocentric Balancing of Wildlife Conservation and Renewable Energy in M.K. Ranjitsinh v. Union of India, 2025 INSC 1472

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1. Introduction

The judgment in M.K. Ranjitsinh & Others v. Union of India & Others, 2025 INSC 1472, is a significant development in Indian environmental and corporate law. It resolves a complex conflict between:

• The urgent need to conserve two critically endangered birds – the Great Indian Bustard (GIB, “Godawan”) and the Lesser Florican – whose last viable habitats are in Rajasthan and Gujarat; and
• India’s equally pressing obligation to rapidly expand renewable energy infrastructure (solar and wind) to mitigate climate change and transition away from fossil fuels.

The litigation, initiated under Article 32 of the Constitution in 2019, challenges the proliferation of overhead transmission lines in the GIB’s habitat, particularly in and around the Thar desert. An earlier interim order of the Court dated 19 April 2021 had imposed far‑reaching restrictions on overhead power lines across roughly 99,000 sq. km., vastly affecting solar and wind projects. Recognising the enormous implications of that order for India’s energy transition, the Court in a subsequent order dated 21 March 2024 partly recalled those directions and constituted a high‑level Expert Committee to propose a scientifically informed middle path.

The 19 December 2025 judgment considers:

• The Expert Committee’s reports for Rajasthan and Gujarat;
• Objections from:
  • Petitioners (conservationists) seeking stronger and broader protections; and
  • Renewable energy developers and industry associations seeking relaxation or modification; and
• The proper institutional role of the Supreme Court when technical choices (such as undergrounding vs overhead lines) have large economic, environmental, and safety implications.

Along the way, the Court articulates an important doctrinal advance: the transformation of “Corporate Social Responsibility” (CSR) into a broader, binding concept of “Corporate Environmental Responsibility”, linking statutory CSR obligations under the Companies Act, 2013 with constitutional duties to protect the environment and endangered species.

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2. Factual and Procedural Background

2.1 The Great Indian Bustard and its endangerment

The judgment begins with an evocative and almost literary portrayal of the GIB – or “Godawan” – integrating ecological science with cultural history:

• One of the heaviest flying birds in the world, a flagship species of India’s arid grasslands.
• Once found across large parts of India; now reduced to a tiny population, primarily in and around the Thar desert in Rajasthan, with remnant presence in Gujarat.
• Classified as “Critically Endangered” by the IUCN since 2011; only two categories (“Extinct in the Wild” and “Extinct”) represent a graver status.
• Rajasthan estimated ~125 GIBs in 2013; IUCN estimated between 50 and 249 mature individuals.

The Court highlights key threats:

• Extremely low fecundity (typically one egg, ground‑nesting, long incubation period).
• Predation on eggs and chicks; trampling by livestock.
• Habitat loss and fragmentation due to agriculture, roads, mining, settlements.
• Linear infrastructure, especially overhead power lines, causing fatal collisions.
• Climate change acting as a stress multiplier on already fragile ecosystems.

The judgment emphasises that the current biodiversity collapse is part of a “sixth mass extinction”, and characterises this case as one step in a larger project of regenerating populations of endangered animals, not just slowing their decline.

2.2 The petitions and interim orders

The principal Writ Petition (C) No. 838 of 2019 sought directions for:

• An emergency response plan for GIB and Lesser Florican conservation, including:
  • Immediate deployment of Bird Flight Diverters (BFDs);
  • Embargo on new infrastructure projects in critical and semi‑critical habitats; and
  • Other protective measures.
• Appointment of an Empowered Committee to supervise conservation actions and enforcement.

Two connected matters were tagged:

• A writ petition by renewable energy company ACME (W.P. (C) No. 549 of 2025); and
• Civil Appeal No. 3570 of 2022, arising from an NGT order on BFD deployment.

On 19 April 2021, the Supreme Court passed an interim order:

• Restricting new overhead transmission lines in an area of about 99,000 sq. km.;
• Directing that existing lines in “priority” and “potential” GIB areas be:
  • Converted to underground lines wherever feasible within one year; and
  • Fitted with BFDs pending undergrounding.
• Appointing a three‑member committee to assess feasibility of undergrounding on a case‑by‑case basis.

Government ministries – MoEFCC, Ministry of Power, and MNRE – later sought modification, stressing that:

• The blanket directions had vast adverse implications for the power sector and energy transition;
• The affected region contains a huge share of India’s solar and wind potential; only ~3% of this had been tapped, and imposing undergrounding would force additional coal consumption and emissions;
• High‑voltage undergrounding was technically challenging, costly, and had safety and reliability issues;
• GIB decline began well before electrification of the region, showing that power lines were not the sole or original driver of endangerment.

In its order dated 21 March 2024, the Court:

• Recognised the need to balance two non‑negotiable goals:
  • Conservation of the GIB (and associated species); and
  • Conservation of the environment as a whole, via climate mitigation and renewable energy.
• Held that a blanket requirement of undergrounding was scientifically and practically unsound, and risked increasing fossil fuel use and greenhouse gas emissions.
• Recalled the 2021 blanket prohibition and constituted a broad‑based Expert Committee to recommend nuanced, location‑specific measures.

2.3 The Expert Committee and its remit

The Expert Committee, constituted by the March 2024 order, included:

• Director, Wildlife Institute of India (WII);
• Members of the National Board for Wildlife and senior forest officers;
• An eminent NGO conservationist;
• Senior officials from MNRE and MoEFCC; and
• Power sector experts as special invitees: Member (Power Systems), CEA and COO, CTU of India Ltd.

Its remit was wide, including:

• Determining the scope and feasibility of overhead vs underground lines in “priority areas” in Rajasthan and Gujarat;
• Recommending conservation and protection measures for GIB and other fauna, including habitat restoration, anti‑poaching and community engagement;
• Evaluating climate change impacts on GIB habitats and designing adaptive strategies;
• Designing sustainable development options for future power lines that balance biodiversity with India’s international renewable energy commitments;
• Studying global comparators (e.g. Houbara bustard in the Middle East, Black Stilt in New Zealand);
• Proposing monitoring and research frameworks; and
• Assessing the scientific efficacy and practicality of BFDs and other technical measures.

The Committee submitted:

• A nearly unanimous report for Rajasthan (with one dissenting note on limited aspects); and
• A later report for Gujarat, after the Court insisted on a consolidated view for both States.

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3. Key Issues Before the Court

At the stage of final adjudication in December 2025, the primary issues were:

1. Rationalisation of GIB conservation areas
   Whether to accept:
   • The Committee’s revised “priority areas”:
     • Rajasthan: from 13,163 sq. km to 14,013 sq. km (with 850 sq. km added and 0.005 sq. km removed);
     • Gujarat: from 500 sq. km to 740 sq. km.
   • Petitioners’ demand to additionally include 657 sq. km in the Rasla–Degrai Oran region of Rajasthan as priority habitat, to avoid habitat fragmentation.
2. Regulation of power lines and renewable energy infrastructure
   How far to:
   • Prohibit new overhead lines in “revised priority areas”, permit them only through corridors, or require widespread undergrounding;
   • Accept or reject the Committee’s rejection of universal BFD deployment in favour of selective, evidence‑based measures;
   • Address developers’ objections that bans and restrictions would cripple India’s solar and wind potential and violate their rights.
3. Scope of judicial intervention vs expert discretion
   Whether the Court should:
   • Defer to the Expert Committee’s largely technical recommendations; or
   • Modify them in line with either petitioners’ more stringent demands or industry’s more relaxed suggestions.
4. CSR and Corporate Environmental Responsibility
   How to conceptualise the role of private corporations, especially power and extractive industries, in funding and supporting endangered species conservation through CSR obligations.
5. Specific contested matters
   Including:
   • Whether to prohibit all new overhead lines (above 11 kV) in revised priority areas, including within designated corridors;
   • Whether to ban mining (e.g. limestone) in priority/revised priority areas;
   • Whether to mandate aerial bunched cables for all low‑tension lines;
   • How to treat two 400 kV lines from Bhachunda–Varsana in Gujarat.

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4. Summary of the Judgment

4.1 Acceptance of Expert Committee’s framework

The Court largely endorses the Expert Committee’s recommendations for both Rajasthan and Gujarat, including:

• Revised priority areas:
  • Rajasthan: 14,013 sq. km;
  • Gujarat: 740 sq. km.
• Comprehensive in‑situ measures:
  • Enclosures; predator and weed management; grassland restoration; water and food management;
  • Stronger protection, including proposal of new Conservation/Community Reserves (e.g. Degray Oran, Rasla, Dholiya–Khetolai–Chacha);
  • Institutional steps such as Project Great Indian Bustard / Project Bustard on the lines of Project Tiger, with funding from National CAMPA.
• Long‑term monitoring of GIB and Lesser Florican populations and habitats, including climate change impacts.
• Creation of powerline corridors through revised priority areas in both States, restricting where new high‑voltage lines may be built.
• Targeted mitigation of existing lines:
  • Immediate undergrounding of specified 33 kV lines (80 km in Rajasthan; 79.2 km in Gujarat);
  • Re‑routing or undergrounding of identified 66 kV and above lines, especially those near enclosures and critical habitats; and
  • Use of insulated cables in horizontal configuration for 11 kV and below lines in revised priority areas.

4.2 Restrictions on future renewable energy projects

The Court approves a zone‑based regulatory approach:

• In revised priority areas (Rajasthan and Gujarat):
  • No new overhead lines above 11 kV except within specified powerline corridors (with technical mitigation);
  • No new wind turbines;
  • No new solar parks/plants above 2 MW, nor expansion of existing parks above that threshold;
  • Small (≤ 2 MW) solar plants by local communities permitted, as they are ineligible for ISTS connectivity and will not significantly fragment habitat.
• In potential areas (non‑priority areas): no blanket restrictions on power lines, but:
  • Lines from multiple RE pooling stations to the same grid station, or from multiple RE plants to the same pooling station, must be route‑optimised to share corridors to the greatest possible extent.

4.3 Bird Flight Diverters (BFDs) and technical measures

The Court:

• Declines to mandate universal BFD deployment on all existing and future lines, accepting the Committee’s concerns over:
  • Unproven efficacy for bustards in Indian conditions;
  • High installation and maintenance costs; and
  • The risk that large‑scale BFD programs may become financially and administratively unsustainable.
• Directs MoEFCC (Inspector General, Wildlife) to:
  • Ensure WII’s ongoing study on BFD effectiveness is completed; and
  • Have at least one additional agency independently assess BFD performance via pilot projects, before scaling up.

4.4 Rejection of certain petitioner demands and industry objections

The Court:

• Rejects petitioners’ demand to:
  • Include an additional 657 sq. km (Rasla region) as revised priority area;
  • Prohibit all new overhead lines (even in corridors) in revised priority areas;
  • Mandate that all existing and future lines be equipped with BFDs;
  • Mandate aerial bunched cables for all 11 kV and below lines (instead, any insulated configuration is permitted);
  • Impose an outright mining ban within priority or revised priority areas (relying instead on existing statutory regimes and regulators’ judgment).
• Rejects industry arguments that:
  • Expansion of priority areas is ultra vires the Committee’s remit, or lacks quantitative justification;
  • No ban should exist on solar projects above 2 MW in revised priority areas; or
  • Decision‑making on undergrounding should be shifted from the Expert Committee to the Central Electricity Authority on a case‑by‑case basis, thereby reopening and delaying the process.

4.5 Institutional oversight and timelines

The Court:

• Places overall responsibility for implementation of approved recommendations on the Inspector General, Wildlife Division, MoEFCC, as a “duty‑bearer”;
• Sets a two‑year outer limit for completing mitigation measures such as undergrounding, re‑routing, and corridor optimisation, including undergrounding 250 km of critical lines identified by WII in Rajasthan;
• Directs that all other Committee recommendations, not specifically modified by the Court, be implemented “as soon as possible”.

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5. Precedents and Authorities Cited

5.1 Centre For Environmental Law, World Wide Fund-India v. Union Of India, (2013) 8 SCC 234

This case, a landmark in wildlife jurisprudence, dealt with the reintroduction of the Asiatic lion and articulated the principle of “species best interest”. The Court held that the survival of endangered species often takes precedence over competing human and commercial interests, and that the State has a trusteeship duty towards wildlife.

In M.K. Ranjitsinh, the Court explicitly relies on this earlier precedent to:

• Re‑affirm that endangered species protection is a “paramount” obligation; and
• Extend the “species best interest” standard into the corporate context, holding that companies whose activities endanger species must bear the cost of mitigation and recovery under the Polluter Pays principle, and should channel CSR funds into such efforts.

5.2 T N Godavarman Thirumulpad v. Union of India (Red Sandalwood & Oran orders)

The Godavarman series is the backbone of Indian forest jurisprudence and the technique of “continuing mandamus”. Two strands are relevant here:

• The 2012 red sandalwood protection order, cited for the Court’s long‑standing practice of relying on expert committees in ecological matters.
• The 18 December 2024 order (in I.A. No. 41723/2022, W.P. (C) No. 202/1995), directing States to identify and notify Orans and sacred groves as forest land, recognising their cultural and ecological importance.

In the present case:

• Petitioners use the Oran order to argue that the Rasla–Degrai Oran region must be fully integrated into the priority area.
• The Court acknowledges the ecological-cultural importance of Orans and notes that areas around Rasla and Degrai should be designated as Community Reserves with strong protection, but ultimately defers to the Expert Committee’s decision not to classify the entire 657 sq. km as priority habitat.

5.3 U.P. Public Service Commission v. Rahul Singh, (2018) 7 SCC 254

In Rahul Singh, the Court held that courts should ordinarily not substitute their own opinions for those of expert bodies (there, a Public Service Commission) unless decisions are shown to be arbitrary or perverse.

This principle is extended here to environmental governance:

• The Court repeatedly emphasises that the question of overhead vs underground power lines, and the design of corridors and technical mitigation, is a matter of environmental policy and domain expertise, not judicial engineering.
• Accordingly, it defers to the Expert Committee’s scientifically reasoned choices on issues like:
  • Extent and location of priority areas;
  • Choice of corridors vs universal undergrounding;
  • Limited, cautious approach to BFD deployment.

5.4 Statutory framework

Several statutes are interwoven into the Court’s reasoning:

• Companies Act, 2013:
  • Section 135 (CSR) – mandates CSR spending by qualifying companies;
  • Section 166(2) – broadens directors’ fiduciary duties to include the “community” and “protection of environment”;
  • Schedule VII – explicitly includes “environmental sustainability, ecological balance, protection of flora and fauna, conservation of natural resources” as CSR activities.
• Electricity Act, 2003, Section 68 – regulates overhead lines and approvals. Developers invoked it to argue for case‑by‑case decisions by the CEA; the Court, however, keeps core control with the Expert Committee’s framework and MoEFCC oversight.
• Wildlife (Protection) Act, 1972 – forming the legal basis for:
  • Protected areas such as Desert National Park and enclosures;
  • Creation of Conservation / Community Reserves.
• Mines and Minerals (Development and Regulation) Act, 1957 and Environment (Protection) Act, 1986 – relevant to mining in GIB landscapes; the Court relies on these regimes rather than imposing an express judicial ban.

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6. The Court’s Legal Reasoning

6.1 Ecocentric vs anthropocentric approaches

The judgment is explicitly grounded in an ecocentric worldview, as opposed to a purely anthropocentric one. Drawing on the Bishnoi community’s ethos, the Court endorses the perspective that:

This manifests doctrinally in several ways:

• Recognition that other species have intrinsic value, not merely instrumental value for humans;
• Reliance on Article 51A(g) – the fundamental duty of citizens (and by extension corporate persons) to protect the environment and have compassion for living creatures;
• Viewing the GIB as a cultural, ecological, and moral stakeholder, whose survival is central to the identity and integrity of the desert ecosystem and communities.

6.2 Balancing biodiversity conservation and climate mitigation

The Court’s core reasoning is a sophisticated balancing of two environmental imperatives:

1. Preventing the extinction of critically endangered species (GIB, Lesser Florican); and
2. Avoiding climate catastrophe by enabling rapid scaling up of renewable energy, thereby reducing dependence on coal and other fossil fuels.

Relying on its 21 March 2024 order (quoted extensively), the Court notes that:

• A blanket undergrounding mandate would:
  • Be technically unfeasible or unsafe in many desert conditions (e.g., flag markers buried by sand, high jointing, AC transmission losses, risk of fires);
  • Make a vast area of high solar and wind potential effectively unusable for renewable projects;
  • Force India to meet future demand through an additional ~93,000 MW of coal capacity, emitting about 623 billion kg of CO₂.
• Extinction of the GIB cannot be prevented solely through power infrastructure prescriptions; multiple drivers need to be addressed simultaneously: habitat restoration, predator control, breeding programs, and climate adaptation.

The Court therefore rejects zero‑sum thinking. Rather than sacrificing climate goals to species conservation or vice versa, it adopts a layered and spatially differentiated strategy:

• Highly restrictive protection in scientifically defined revised priority areas: no new wind, no large solar parks, constrained overhead lines via corridors, and intensive habitat management;
• Moderated regulation in potential areas, focusing on corridor optimisation rather than bans;
• Targeted engineering solutions (undergrounding, insulated cables, re‑routing) where collision risks are highest.

This is a textbook application of the principle of sustainable development, updated to reflect:

• The dual character of climate mitigation projects as both solutions and potential local drivers of biodiversity harm; and
• The need to view the “environment” as a single system where greenhouse gas reductions and species conservation must be integrated, not traded off.

6.3 Judicial deference to expert committees

A notable feature is the Court’s clear articulation of its own institutional limits:

• It acknowledges that passing sweeping, technology‑specific orders (e.g., universal undergrounding, mandatory BFDs everywhere) without a “full understanding” of technical issues risks unintended harm.
• It emphasises that expert committees, not the Court, are best placed to calibrate such measures, with inputs from power engineers, ecologists, and local communities.
• Accordingly, the Court refuses to:
  • Second‑guess the Committee’s revised boundaries of priority areas;
  • Re‑open technical feasibility assessments by delegating afresh to CEA;
  • Impose petitioners’ preferred numerical thresholds or universal BFD obligations.

At the same time, this is not blind deference. The Court:

• Subjects the Committee’s work to reasoned scrutiny (e.g. over Rasla, potential areas, BFD);
• Explicitly resolves conflicts between majority recommendations and dissenting notes;
• Adds binding timelines and identifies a clear institutional duty‑bearer (IG Wildlife, MoEFCC) to avoid implementation drift.

6.4 Treatment of the Rasla–Degrai Oran controversy

Petitioners, relying partly on the dissenting note, argued that:

• The 657 sq. km area between Rasla enclosure and the existing priority area is crucial as:
  • A corridor linking GIB sub‑populations between Desert National Park (DNP) / Pokhran and Rasla;
  • A wintering and stop‑over site during movements between safer zones; and
  • A region rich in Orans and sacred groves with ongoing GIB sightings.
• Excluding this area from priority status would create an “island” Rasla priority area, undermining connectivity and protections.

The majority Committee, however, considered:

• The presence of dense existing high‑voltage infrastructure (including 765 kV Fatehgarh substations and multiple lines), which is very difficult to reconfigure;
• The crucial role of this zone in evacuating renewable power from western Rajasthan;
• That ~20 sq. km around Rasla has already been included as revised priority area, and the adjoining Desert National Park has strong protection; and
• That the combined effect of revised priority area and additionally proposed conservation measures (including community reserves, Eco Task Force deployment) sufficiently secures GIB habitat.

The Court:

• Finds no irrationality in the Committee’s holistic judgment, especially given:
  • Field visits and stakeholder consultations; and
  • The existing, highly complex transmission network already entrenched in the 657 sq. km area.
• Notes that Orans such as Degrai and Rasla are to be declared and managed as community reserves, with enhanced protection and community participation.
• Concludes that Petitioners’ concerns can be effectively addressed through stronger conservation zoning and management without re‑drawing the priority area boundary as requested.

6.5 Bird Flight Diverters: evidence‑based caution

The Committee, supported by scientific literature, observed:

• BFDs significantly reduce bird collisions in many species, but their effectiveness for bustards is lower and not yet well‑proven in Indian conditions;
• BFD programs are cost‑intensive, require robust maintenance, and address only one threat (collisions), not broader habitat issues;
• More than 50% of lines in revised priority areas already have BFDs, offering an opportunity to rigorously assess impact before further roll‑out.

The Court goes further, adding institutional insight:

• Maintenance of a vast BFD network would demand a high and sustained level of administrative discipline and resources, which is often a weak point in public systems;
• Before making BFDs a universal mandate, both durability and near maintenance‑free operation should be demonstrated.

Instead of mandating BFDs everywhere, the Court:

• Accepts the Committee’s decision not to treat them as a default solution;
• Directs MoEFCC to:
  • Oversee WII’s ongoing BFD efficacy study; and
  • Commission at least one other agency to run pilot projects and independently evaluate performance.

This is a move from technology mandates by courts to evidence‑based regulatory experimentation under expert supervision.

6.6 CSR as Corporate Environmental Responsibility

Perhaps the most doctrinally innovative portion of the judgment lies in paragraphs 35–40, where the Court re‑conceptualises the legal nature of CSR:

• CSR is characterised as a statutory obligation and constitutional duty, not voluntary philanthropy.
• Drawing on Section 166(2) of the Companies Act, the Court emphasises that directors owe duties not only to shareholders but also to the community and the environment.
• The term “community” is explicitly interpreted to include the natural world and non‑human beings, not just humans.

The Court articulates several key propositions:

1. Corporate Profit as Social Trust
   Profit is not solely the private property of shareholders; a portion is “owed to the society that enables its generation.” The “magic of legitimacy” lies in viewing private property as a trust.
2. Environmental Responsibility as an Inseparable Part of Social Responsibility
   Because the environment is integral to human welfare, “Corporate Social Responsibility” must necessarily subsume Corporate Environmental Responsibility. A company cannot claim to be socially responsible while ignoring environmental claims and the interests of other beings.
3. Constitutionalisation of CSR
   Article 51A(g) is read as a fundamental duty that applies not only to individual citizens but to corporations as juridical persons. CSR funds are described as the “tangible expression” of this duty.
4. Polluter Pays and Species Best Interest
   Referring again to Centre for Environmental Law, WWF, the Court holds that where corporate activities threaten endangered species, the Polluter Pays principle requires that:
   • The company bear the full cost of mitigation, recovery and conservation, including ex‑situ and in‑situ measures; and
   • CSR allocations should be directed accordingly, particularly in cases such as GIB conservation.

Though framed in the context of non‑renewable generators in GIB landscapes, these principles have wide implications across sectors: mining, infrastructure, heavy industry, and even large renewable projects that impact sensitive habitats. The Court signals that CSR‑related environmental under‑spending is no longer a mere reputational issue; it may be read as a failure to discharge a statutory-constitutional duty.

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7. Impact on Law and Policy

7.1 For wildlife and habitat conservation

• The judgment provides a replicable template for balancing species conservation with linear infrastructure:
  • Identification of scientifically grounded priority and potential areas;
  • Use of corridors to localise infrastructure impacts;
  • Mix of in‑situ habitat management and targeted engineering mitigation, rather than a single universal fix.
• The move to institutionalise Project Great Indian Bustard / Project Bustard with CAMPA funding elevates GIB protection to the level of flagship programs like Project Tiger and Project Elephant.
• The recognition of Orans, community reserves, and involvement of Eco Task Force reinforces the trend towards community‑centred, culturally anchored conservation.

7.2 For renewable energy and power sector planning

• Renewable energy developers must now factor in:
  • Hard “no‑go” zones for large projects (revised priority areas), and no new wind or large solar parks there;
  • Obligations to use corridors, route optimisation, and sometimes undergrounding or re‑routing of lines near critical habitats.
• Approvals under Section 68 of the Electricity Act can no longer ignore wildlife considerations; they must be consistent with the Committee’s framework and this judgment’s directions.
• Arguments that particular judicial orders constitute a “change in law” for tariff or risk allocation purposes will have to be evaluated against this background of anticipatable environmental regulation in sensitive habitats.

7.3 For corporate governance and CSR practice

• Boards and CSR committees of companies, especially in energy, mining, infrastructure and large manufacturing, must now treat environmental conservation – including endangered species recovery – as a core, obligatory element of CSR strategy.
• Regulators such as MCA, SEBI, and sectoral regulators may invoke this judgment to:
  • Encourage or require CSR reporting to separately disclose environmental and biodiversity‑related spending;
  • Link ESG disclosures more tightly with actual conservation outcomes.
• Litigation may increasingly test whether CSR non‑compliance in environmental contexts constitutes not just statutory breach but a violation of constitutional duties, with potential implications for director responsibility under Section 166.

7.4 For judicial methodology in environmental cases

• This judgment consolidates a trend: courts will increasingly rely on multidisciplinary expert committees for technically complex environmental decisions, particularly where infrastructure and climate policy intersect.
• Extreme remedies (blanket bans, technological mandates) are likely to be replaced with:
  • Spatially nuanced regulation (priority vs potential areas);
  • Stronger monitoring, timelines, and accountable institutional actors (here, IG Wildlife, MoEFCC).
• At the same time, the Court retains a robust role in:
  • Defining normative baselines (ecocentrism, species best interest, corporate environmental duty);
  • Ensuring that policy choices are supported by evidence and stakeholder consultation;
  • Guarding against both regulatory abdication and overreach.

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8. Simplifying Core Concepts and Technical Terms

8.1 Priority area, revised priority area, potential area

• Priority area: A scientifically defined landscape where GIB presence, breeding, and habitat suitability are highest. Conservation restrictions here are strongest.
• Revised priority area: The updated version of the priority area after the Expert Committee’s rationalisation, reflecting latest data and infrastructure realities.
• Potential area: Surrounding landscapes where GIB may move or have lower‑density presence; more flexible for development but still subject to some mitigation (e.g., route optimisation).

8.2 Powerline corridor

A powerline corridor is a designated strip of land within or near sensitive habitat where high‑voltage transmission lines are concentrated. Instead of scattering lines across the landscape, they are bundled into this corridor, reducing:

• Habitat fragmentation; and
• Collision risk by leaving other parts of the habitat free of high masts and wires.

8.3 Undergrounding vs overhead lines

• Overhead lines:
  • Commonly used, cheaper, easy to repair;
  • But pose collision risks to large, low‑flying birds like GIBs;
  • Involve tall pylons and multiple conductors, especially at higher voltages (e.g., 66 kV, 220 kV, 400 kV).
• Underground lines:
  • Buried underground, eliminating collision risk;
  • Technically complex and expensive at high voltages, with more joints (potential points of failure), higher AC losses, thermal management issues;
  • In desert conditions, can be hard to locate precisely once markers are lost in sand, raising safety concerns for farmers and maintenance crews.

8.4 Bird Flight Diverters (BFDs)

BFDs are devices attached to overhead wires (often reflective, spiral, or swinging elements) that:

• Make power lines more visible to birds, especially in poor light conditions;
• Reduce collisions by alerting birds to the presence of wires;
• Require initial installation and regular maintenance (e.g., replacement of damaged or lost diverters).

Their effectiveness is well‑documented for many species but remains scientifically uncertain for bustards, which have specific flight and vision patterns.

8.5 Aerial Bunched Cables and insulated cables

• Aerial Bunched Cables (ABC):
  • Bundles of insulated conductors twisted together and strung overhead;
  • Reduce risk of electrocution and short circuits if contacted by trees or animals;
  • However, not always necessary if individual cables are sufficiently insulated and arranged safely.
• The Court accepts the Committee’s view that for 11 kV and below lines in revised priority areas:
  • Any insulated configuration (horizontal or bunched) that prevents electrocution is acceptable;
  • There is no need to mandate ABC everywhere, leaving room for cost‑effective designs.

8.6 In-situ vs ex-situ conservation

• In-situ: Conservation within the natural habitat (e.g., protecting grasslands, managing predators, creating enclosures in DNP or Naliya).
• Ex-situ: Conservation outside natural habitat (e.g., captive breeding centres, artificial incubation, “jump start” with egg swaps).

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9. Conclusion: Key Takeaways

The judgment in M.K. Ranjitsinh v. Union of India is a landmark in several respects:

1. Ecocentric Constitutionalism
   It deepens India’s ecocentric orientation, recognising that endangered species like the GIB are co‑inhabitants with intrinsic value, not mere resources for human use. This perspective is explicitly tied to Article 51A(g) and traditional eco‑venerating communities.
2. Integrated Environmental Governance
   The Court expressly rejects a trade‑off between biodiversity and climate mitigation. It creates an integrated framework that:
   • Strongly protects core habitats;
   • Allows renewable energy expansion in appropriate zones; and
   • Uses corridors, targeted undergrounding and insulation as fine‑grained tools rather than blunt bans.
3. Judicial Deference with Accountability
   The Court affirms that complex environmental engineering choices must rest with expert committees, not direct judicial micromanagement, while still imposing:
   • Concrete timelines; and
   • Clear oversight responsibility on MoEFCC’s Wildlife Division to implement and monitor the recommendations.
4. Corporate Environmental Responsibility as Law
   The judgment makes an important doctrinal move by reading CSR as inherently including Corporate Environmental Responsibility, grounded in:
   • Sections 135 and 166 of the Companies Act;
   • Schedule VII’s environmental focus; and
   • Constitutional duties and the Polluter Pays principle.
   Companies, especially those operating in ecologically sensitive areas, are thus under a statutory-constitutional obligation to fund and support species and habitat conservation.
5. Operational Roadmap for GIB and Lesser Florican
   Finally, this judgment provides a detailed, actionable roadmap for:
   • Defining and managing priority habitats in Rajasthan and Gujarat;
   • Re‑structuring existing power networks and constraining future expansion in these zones;
   • Launching and funding Project Bustard across range States; and
   • Monitoring the results and adapting regulatory strategies, including evidence‑based decisions on technologies like BFDs.

In sum, the decision stands as a model of how a constitutional court can navigate high‑stakes trade‑offs in the Anthropocene — not by choosing between “nature” and “development”, but by insisting that both climate stability and biodiversity survival are non‑negotiable pillars of India’s environmental rule of law.