The Great Indian Bustard case exemplifies the conflict between climate action and biodiversity conservation. Critically examine how the Supreme Court has sought to balance the two.

The Great Indian Bustard (GIB) is a heavy grassland bird now confined mostly to the Thar. Many die by flying into overhead power lines, and those are the same lines that carry India's solar and wind power [1]. In M.K. Ranjitsinh v. Union of India, the Supreme Court has moved from a blanket ban towards zoned coexistence. The balance is sound in design but weak in enforcement.

Evolution of the Court's balancing

• 2021, conservation first: ordered overhead lines in GIB habitat to be put underground, where feasible, within one year, with bird diverters fitted in the meantime [1].
• 2024, climate recognised: found that undergrounding lines across about 99,000 sq km was technically and financially unworkable, and set up an expert committee. It also read a right against the adverse effects of climate change into Articles 14 and 21 [2].
• 2025, spatial compromise: cut the priority areas to about 14,013 sq km (Rajasthan) and 740 sq km (Gujarat). It banned new wind turbines and solar plants above 2 MW there and sent future lines through a dedicated corridor south of Desert National Park [3].

Strengths

• Not a binary choice: biodiversity and clean energy are both treated as constitutional values [2].
• Evidence-based: the final zoning follows the expert committee's recommendations, not judicial guesswork [3].
• Regulatory clarity: developers now know the no-go zones and the corridors, which protects India's renewable targets [3].

Weaknesses

• Compliance deficit: the 2021 one-year deadline was missed, and mitigation now runs to about 2027–28 [3]. Collisions continue meanwhile.
• Untested claims: the 2024 relaxation relied largely on government and industry claims about cost, not on an independent technical audit.
• Judicial policy-making: the Court itself noted that India has no umbrella climate law [2]. Judges are therefore deciding where projects can go, case by case, which raises separation-of-powers concerns.
• Narrow lens: the Court has acknowledged that low breeding rates, habitat loss and predators also drive the decline [3]. Mitigating power lines alone cannot save the species.

The Court has moved from prohibition to calibrated zoning, reconciling Article 48A and Article 51A(g) with the new climate right. Next steps should be:

• annual public compliance data;
• mitigation costs priced into renewable tenders;
• a parliamentary climate law;
• captive breeding paired with safe, restored grasslands.

That way India's clean-energy push (SDG 7) would not cost it a flagship species (SDG 15).