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Case Commentary: M.K. Ranjitsinh & Ors. V. Union Of India




E. Subbu Lakshmi, B.B.A. LL.B. (Hons) LL.M, Advocate


Writ Petition (Civil) No. 838 of 2019 with Civil Appeal No. 3570 of 2022 2024 INSC 280 (Order dated 21 March 2024); 2025 INSC 1472 (Final Judgment dated 19 December 2025) Supreme Court of India.


Bench (Justice P.S. Narasimha and Justice A.S. Chandurkar).


E. Subbu Lakshmi B.B.A LL.B. (Hons) LL.M., Advocate


INTRODUCTION


In the 21st century, Environmental governance gradually facing a multilayered situation that any developmental strategies used to mitigate climate change often result in ecological harms that endangers fragile ecosystems and biodiversity.The judgment in M.K.Ranjitsinh & Ors. v. Union of India marks as a landmark judgment in the Indian environmental jurisprudence. In this verdict the Supreme Court of India addressed the constitutional conflict between renewable energy scaling and wildlife conservation, specifically regarding the gravely endangered Great Indian Bustard (GIB). This is the first time Supreme Court explicitly recognized “right against the adverse effects of climate change” as a fundamental right under Articles 14 and 21 of the Constitution of India. The court developed a jurisprudential framework to balance between the preservation and climate mitigation objectives, while modifying its own mandate sweeping underground transmission lines. However, the verdict raises significant priorities concerning ecological emphasis, judicial balancing, technocratic administration and precautionary environmental protections by establishing a framework that will regulate renewable energy development along with ecological conservation. This case comprises of four major judicial actions: an interim order in April 2021, a landmark judgment on 21 March 2024 (2024 INSC 280), subsequent proceedings in December 2025 after obtaining the Expert Committee's report, and a final verdict on 19 December 2025 (2025 INSC 1472). This commentary critically analyses the judgment in the dimension of climate justice and environmental constitutionalism.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

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