Administrative Law

Great Indian Bustard: Supreme Court Balances Conservation with Renewable Energy Development

The Supreme Court modified its 2021 order and accepted Expert Committee recommendations to protect the critically endangered Great Indian Bustard while allowing renewable energy projects in a balanced manner

Case Reference: Writ Petition (C) No. 838 of 2019 with Civil Appeal No. 3570 of 2022 Decided by: Supreme Court of India Date: December 19, 2025

❓ Question

CAN INDIA DEVELOP RENEWABLE ENERGY INFRASTRUCTURE WHILE PROTECTING CRITICALLY ENDANGERED SPECIES LIKE THE GREAT INDIAN BUSTARD?

✅ Answer

YES, WITH BALANCED MEASURES. The Supreme Court has accepted the Expert Committee's recommendations to protect the critically endangered Great Indian Bustard (GIB) while allowing renewable energy development through designated power corridors, revised priority areas, and strict regulations in conservation zones. The Court emphasized corporate environmental responsibility under CSR provisions.

⚖️ Understanding the Legal Principles

🔹 Conservation Priority Areas

  • Rajasthan: 14,013 sq km revised priority area
  • Gujarat: 740 sq km revised priority area
  • No new overhead powerlines except through dedicated corridors
  • No new wind turbines in revised priority areas
  • Solar projects limited to 2MW capacity in priority zones

🔹 Power Line Corridors

  • Up to 5 km wide corridors in Rajasthan
  • 1-2 km wide corridors in Gujarat
  • All future lines to use common stretches where possible
  • Existing lines to be mitigated within 2 years
  • Priority given to re-routing over undergrounding

🔹 Corporate Environmental Responsibility

  • CSR includes environmental responsibility
  • Companies share environment with endangered species
  • Polluter pays principle for species recovery
  • Corporate profit partly owed to society
  • Funds for conservation not charity but duty

🔹 Mitigation Measures

  • 80 km of 33kV lines to be undergrounded immediately
  • Critical 66kV lines to be re-routed
  • Bird Flight Diverters (BFDs) effectiveness under study
  • Insulated cables for 11kV and below lines
  • All measures to be completed within 2 years

📜 Key Legal Timeline

April 19, 2021

Initial Supreme Court Order: Blanket prohibition on overhead transmission lines in 99,000 sq km area to protect GIB

November 2021

Government Application: Union Ministries seek modification citing renewable energy commitments and technical feasibility

March 21, 2024

Court Modifies Order: Supreme Court recalls blanket prohibition and constitutes Expert Committee

September 3, 2024

Committee Report (Rajasthan): Expert Committee submits recommendations for Rajasthan

November 7, 2024

Committee Report (Gujarat): Court directs Committee to submit Gujarat report

December 19, 2025

Final Judgment: Supreme Court accepts Committee recommendations with modifications

🧭 Your Action Plan: Environmental Compliance

📝 For Renewable Energy Developers

✅ Step 1: Check Project Location

  • Verify if project falls in revised priority area
  • Rajasthan: 14,013 sq km priority zone
  • Gujarat: 740 sq km priority zone
  • Check designated power corridors
  • Review existing infrastructure restrictions

✅ Step 2: Understand Restrictions

  • No new wind turbines in priority areas
  • Solar projects limited to 2MW in priority zones
  • No new overhead lines except through corridors
  • Existing wind turbine leases not to be renewed
  • Expansion of existing solar parks prohibited

⚖️ CSR Compliance Requirements

CSR Aspect Legal Requirement GIB Conservation Application
Environmental Sustainability Schedule VII, Companies Act 2013 Fund habitat restoration and GIB conservation
Ecological Balance Section 166(2), Companies Act Protect GIB habitats and grassland ecosystems
Polluter Pays Principle Environmental Law Precedent Companies must fund species recovery efforts
Fund Allocation Section 135, Companies Act Minimum 2% of average net profits for 3 years
Constitutional Duty Article 51A(g), Constitution Protect wildlife and have compassion for living creatures

📋 Compliance Checklist for Energy Projects

Essential Documentation

  • Project location vis-à-vis priority area maps
  • Environmental Impact Assessment report
  • Power line corridor alignment approvals
  • CSR commitment for conservation funding
  • Mitigation measures implementation plan
  • Wildlife clearance certificates

Legal References to Cite

  • Supreme Court order dated December 19, 2025
  • Expert Committee Reports for Rajasthan and Gujarat
  • Section 135, Companies Act 2013 (CSR)
  • Article 51A(g), Constitution of India
  • Wildlife Protection Act, 1972 provisions

📘 Key Legal Terms Explained

Great Indian Bustard (GIB)

Critically endangered bird species, one of the heaviest flying birds, found primarily in Rajasthan and Gujarat. Cultural symbol known as "Godawan" in Rajasthan, with population estimated at less than 150 individuals.

Revised Priority Area

Areas designated by Expert Committee for maximum conservation efforts: 14,013 sq km in Rajasthan and 740 sq km in Gujarat, where strictest regulations apply for renewable energy projects.

Power Line Corridor

Designated pathways (5 km wide in Rajasthan, 1-2 km in Gujarat) where power transmission lines can be concentrated to minimize habitat fragmentation and bird collision risks.

Bird Flight Diverters (BFDs)

Devices installed on power lines to make them more visible to birds and prevent collisions. Effectiveness for bustards still under scientific study as per Court directions.

🚨 What to Avoid in Environmental Compliance

❌ Don't Ignore Priority Area Restrictions

  • Don't propose new wind turbines in priority areas
  • Avoid solar projects above 2MW in restricted zones
  • Don't route power lines outside designated corridors
  • Avoid expanding existing projects in priority areas

❌ Don't Neglect CSR Obligations

  • Companies must include environmental responsibility in CSR
  • Avoid treating conservation funding as optional charity
  • Don't ignore corporate constitutional duty to protect wildlife
  • Avoid delaying mitigation measure implementation

💡 Core Takeaway from the Supreme Court

"The non-renewable power generators operating in the priority as well as non-priority areas in Rajasthan and Gujarat must always remember that they share the environment with the Godawan, the Great Indian Bustard and must undertake their activities as if they are guests in its abode."

This landmark judgment establishes a new paradigm for balancing environmental conservation with development needs. By accepting the Expert Committee's scientific recommendations and emphasizing corporate environmental responsibility, the Court has created a framework where renewable energy development can proceed while protecting critically endangered species through designated corridors, priority areas, and mandatory CSR contributions for conservation efforts.

📞 When to Seek Professional Help

👨‍⚖️ Environmental Lawyer Essential For

  • Projects in or near revised priority areas
  • Compliance with multiple environmental regulations
  • CSR planning for conservation funding
  • Navigating power corridor alignment approvals
  • Appeals against environmental clearance rejections

📝 You Can Handle With Support

  • Basic understanding of priority area maps
  • Initial project location assessment
  • Compliance with 2MW solar limit in priority zones
  • Understanding CSR allocation requirements
  • Basic environmental impact documentation

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

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This roadmap clarifies the balance between environmental conservation and renewable energy development, empowering citizens and corporations to understand their rights and responsibilities in protecting endangered species while pursuing sustainable development goals.