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Great Indian Bustard Conservation Measures: Supreme Court Orders New Safeguards

The Supreme Court of India has issued fresh directions aimed at protecting the critically endangered Great Indian Bustard, reinforcing its long-standing involvement in wildlife conservation through judicial oversight.

In M.K. Ranjitsinh v. Union of India, decided on December 19, 2025, the Court adopted expert recommendations to curb rising mortality among Great Indian Bustards. The bench directed the implementation of specific conservation measures, including the undergrounding of power transmission lines and a prohibition on new wind turbine installations in core bustard habitats in Rajasthan and Gujarat.

The ruling forms part of a broader eco-conservation framework that also covers other vulnerable species such as the Lesser Florican. It reflects the Court’s continued engagement with environmental protection, particularly where large infrastructure and energy projects intersect with fragile ecosystems.

A Species on the Brink of Extinction

The Great Indian Bustard is among the heaviest flying birds in the world and is listed as critically endangered. Once widespread across the Indian subcontinent, its population has dwindled dramatically over the decades due to habitat loss, hunting, and infrastructure-related threats.

Conservation authorities estimate that fewer than 150 individuals remain in the wild, with the largest surviving populations concentrated in parts of Rajasthan and Gujarat. These regions have also seen a rapid expansion of renewable energy infrastructure, particularly wind and solar projects.

The Great Indian Bustard conservation measures ordered by the Supreme Court seek to address this overlap between development and conservation, where high-voltage power lines and wind turbines have been identified as major causes of fatal collisions for the bird.

The Case Before the Court

The proceedings in M.K. Ranjitsinh v. Union of India arose from petitions highlighting the alarming decline of the Great Indian Bustard and the inadequacy of existing safeguards. Petitioners pointed to scientific studies and expert assessments that identified power transmission lines as one of the leading causes of bustard deaths.

During earlier hearings, the Court had sought inputs from expert committees and wildlife authorities to frame a practical conservation strategy. The December 19 decision builds on this consultative process, with the Court expressly relying on expert suggestions to shape its final directions.

By adopting these recommendations, the Court underscored that conservation policy must be grounded in scientific evidence rather than ad hoc measures.

Undergrounding Power Lines in Core Habitats

One of the most significant Great Indian Bustard conservation measures ordered by the Court is the undergrounding of overhead power transmission lines in identified core habitats.

Overhead lines pose a serious threat to bustards due to their limited frontal vision, making them particularly vulnerable to mid-air collisions. The Court accepted expert findings that underground cables substantially reduce this risk.

The directions require authorities to prioritise undergrounding in areas officially notified as core bustard habitats. These measures are intended to be implemented in a phased and structured manner, balancing ecological urgency with practical feasibility.

Restrictions on New Wind Energy Projects

The Court also directed that no new wind turbine installations should be permitted in core Great Indian Bustard habitats in Rajasthan and Gujarat.

Wind energy projects, while central to India’s renewable energy goals, involve tall turbine structures and associated transmission infrastructure that can disrupt flight paths and breeding grounds. Experts have consistently warned that unchecked expansion of such projects in sensitive areas could accelerate the species’ decline.

The restriction applies specifically to core habitats identified as critical for the bird’s survival. Existing installations are not automatically dismantled, but future expansion in these zones has now been curtailed under judicial directions.

A Broader Conservation Framework

The Supreme Court’s ruling is not limited to the Great Indian Bustard alone. The Court noted that similar conservation concerns exist for other grassland-dependent species, including the Lesser Florican.

By situating the bustard directions within a wider eco-conservation plan, the Court emphasised the need for ecosystem-level thinking rather than species-specific interventions in isolation.

This approach reflects an understanding that grassland ecosystems have historically received less policy attention compared to forests, despite supporting unique and threatened biodiversity.

Judicial Role in Environmental Protection

The decision once again highlights the Supreme Court’s role in enforcing environmental safeguards through judicial remedies. Over the years, the Court has intervened in several cases involving wildlife protection, forest conservation, and pollution control, often stepping in where administrative action was seen as insufficient.

In this case, the Court did not frame policy from scratch but relied on expert assessments and scientific inputs. The adoption of expert suggestions demonstrates a model of judicial intervention that seeks to complement, rather than replace, executive and scientific decision-making.

The Great Indian Bustard conservation measures ordered by the Court illustrate how judicial oversight can shape the implementation of environmental obligations already recognised under law.

Implications for Infrastructure and Energy Planning

While the ruling is rooted in wildlife protection, it has wider consequences for infrastructure and energy planning in ecologically sensitive zones.

Rajasthan and Gujarat are major hubs for renewable energy development, particularly wind and solar power. The Court’s directions require planners and developers to account for ecological constraints at the project design stage, especially in designated conservation areas.

The decision reinforces the principle that environmental considerations cannot be treated as secondary where endangered species are concerned. Infrastructure development, even in the renewable energy sector, must be aligned with conservation priorities in legally protected habitats.

Balancing Conservation and Development

The Supreme Court acknowledged the importance of renewable energy and infrastructure development, but stressed that such projects cannot proceed at the cost of irreversible ecological damage.

By limiting restrictions to core habitats and relying on expert mapping, the Court attempted to strike a balance between conservation needs and developmental objectives. The Great Indian Bustard conservation measures are therefore targeted rather than blanket prohibitions.

This calibrated approach reflects the Court’s broader environmental jurisprudence, which often seeks to harmonise development with ecological sustainability.

Monitoring and Implementation

The effectiveness of the Court’s directions will depend largely on their implementation by state authorities and project developers. Past conservation orders have sometimes faced challenges due to delays, cost concerns, and coordination issues among multiple agencies.

The Court has, in earlier hearings, emphasised the need for regular monitoring and compliance reporting. While the December 19 order focuses on substantive measures, it also signals continued judicial supervision to ensure that directions translate into on-ground action.

The success of the Great Indian Bustard conservation measures will therefore hinge on administrative follow-through as much as judicial intent.

A Signal to States and Regulators

The ruling sends a clear signal to state governments and regulatory bodies that conservation commitments must be taken seriously, particularly when dealing with species on the brink of extinction.

By intervening in land use and infrastructure decisions within specific habitats, the Court reaffirmed that environmental protection is a constitutional obligation that can justify restrictions on otherwise lawful activities.

The decision is likely to influence how future projects are evaluated in ecologically sensitive areas, especially where wildlife mortality risks are well documented.

Looking Ahead

As India balances ambitious development goals with pressing environmental challenges, the Supreme Court’s directions in the Great Indian Bustard case mark an important moment in wildlife protection jurisprudence.

The adoption of expert-backed conservation measures reflects a growing recognition that legal interventions must be informed by science and ecological realities. Whether these measures succeed in stabilising or reviving the Great Indian Bustard population will depend on sustained commitment from all stakeholders.

For now, the ruling stands as a reaffirmation of the judiciary’s role in safeguarding endangered species and preserving fragile ecosystems through enforceable legal directions.

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