What was the main risk to the Great Indian Bustard?

Collisions with overhead power lines in priority habitats. The bird’s poor frontal vision makes detection hard, causing fatal strikes.

What directions did the Supreme Court issue?

Underground low-voltage lines in priority habitats; convert high-voltage lines underground where feasible; install bird diverters where not feasible; fence breeding areas; set up an expert committee.

Which legal ideas guided the decision?

Ecocentric approach, public trust doctrine, sustainable development, and Article 21’s protection of biodiversity.

Do costs block conservation steps?

No. Financial limits cannot justify inaction. Funds like CAMPA and CSR should support conservation.

Who filed the case and why?

Environmentalists led by M.K. Ranjitsinh filed a PIL to save the Great Indian Bustard and Lesser Florican from deadly power-line collisions.

M.K. Ranjitsinh v. Union of India (2021)

Supreme Court steps to save the Great Indian Bustard and Lesser Florican: safer power lines, science-led mitigation, and strict monitoring.

Supreme Court of India 19 Apr 2021 AIR ONLINE 2021 SC 209 Wildlife & Biodiversity ~7 min read

Author: Gulzar Hashmi · India · Published: 31 Oct 2025

CASE_TITLE: M.K. Ranjitsinh v. Union of India PRIMARY_KEYWORDS: Great Indian Bustard, power lines, underground cables SECONDARY_KEYWORDS: bird diverters, ecocentric approach, public trust doctrine, Article 21 PUBLISH_DATE: 31-10-2025 AUTHOR_NAME: Gulzar Hashmi LOCATION: India slug: mk-ranjitsinh-v-union-of-india-2021

Quick Summary

The Court treated wildlife protection as a duty to nature itself. Power lines in priority habitats are deadly for the Great Indian Bustard (GIB) and Lesser Florican. So, the Court ordered undergrounding of low-voltage lines, feasibility-based undergrounding of high-voltage lines, and bird diverters where undergrounding is not possible—plus fencing, monitoring, and an expert committee.

Issues

Do overhead power lines in GIB/Lesser Florican habitats pose a critical survival threat requiring urgent mitigation?
Should power lines be placed underground in priority areas, and if not feasible, what immediate alternatives must be used?

Rules

Ecocentric Approach: Species have intrinsic value; conservation can trump development needs.

Public Trust Doctrine: The State is a trustee of natural resources and must guard endangered species for future generations.

Sustainable Development: Projects must avoid irreversible harm; workable mitigation is mandatory.

Article 21 & Biodiversity: Right to life includes protecting ecosystems and preventing species extinction.

Facts (Timeline)

PIL Filed: Environmentalists led by M.K. Ranjitsinh seek urgent GIB and Lesser Florican protection.

Key Risk: Overhead lines cause collisions; GIB’s poor frontal vision increases deaths.

Evidence: WII (2018) flags power lines as the biggest threat; MoP affidavit accepts GIB’s detection limits.

Relief Sought: Ban new overhead lines, underground existing/future lines, install diverters, fence breeding areas, manage predators/grazing.

Opposition: States/utilities cite costs, repair downtime, cable limits; propose diverters instead for some corridors.

Arguments

Petitioners

Overhead lines are the main cause of mortality; urgent fixes save a near-extinct species.
Undergrounding is feasible in many places (shown in other projects).
Ecocentric and trust doctrines demand strong, immediate action.

Respondents (States/Utilities)

High-voltage undergrounding is costly and technically hard on some routes.
Repair times and material availability affect reliability.
Bird diverters can reduce collisions on overhead spans.

Judgment

Held: The Court reaffirmed ecocentric and public trust duties. It ordered undergrounding of all low-voltage lines in priority GIB habitats; convert high-voltage lines underground where feasible; and install bird diverters immediately where undergrounding is not feasible.

Set up a technical expert committee to test feasibility and guide works.
Fence priority breeding areas to protect nests and eggs.
Use CAMPA/CSR funds and finish works within set timelines with periodic review.

Article 21 includes biodiversity protection. Cost cannot excuse inaction.

Ratio (Core Legal Principle)

When infrastructure endangers a critically endangered species, the State must take workable, immediate mitigation. Biodiversity protection under Article 21, the public trust duty, and ecocentric values require undergrounding or proven alternatives.

Why It Matters

Sets a national model for species-first planning in power corridors.
Combines engineering fixes (undergrounding/diverters) with habitat management.
Shows how courts balance reliability, cost, and urgent conservation.

Key Takeaways

Low-voltage lines in priority GIB habitats must go underground.
High-voltage lines: underground where feasible; otherwise install certified bird diverters fast.
Article 21 + public trust = proactive biodiversity protection with real timelines.

Mnemonic + 3-Step Hook

Mnemonic: “B-U-S-T-A-R-D” → Bird at risk • Underground low-voltage • Shift HV where feasible • Tags (diverters) else • Areas fenced • Review by experts • Deadlines enforced.

Map priority habitats and lines.
Mitigate with undergrounding/diverters + fencing.
Monitor via expert committee and periodic audits.

IRAC

Issue	Rule	Application	Conclusion
Do overhead power lines threaten GIB survival and demand urgent mitigation?	Ecocentric, public trust, sustainable development, Article 21 biodiversity duty.	Evidence shows frequent collisions; agencies acknowledge detection limits; feasible fixes exist.	Order undergrounding/diverters, fence breeding areas, create expert oversight with timelines.

Glossary

Bird Diverter: A device fixed on wires to make them visible to birds and reduce collisions.
Priority Habitat: High-use breeding/feeding zones identified for urgent protection.
CAMPA Funds: Compensatory afforestation funds used for ecological restoration and conservation.