Introduction
For many decades, in the quiet grasslands of western India, the Great Indian Bustard (GIB) has been disappearing. The GIB is a large bird of the bustard family, also known as one of the heaviest flying birds in the world.
The GIBs are tall omnivorous birds with long legs and distinctively long necks that fly low. In 1996, it was listed under the ‘red’ category of species considered endangered by the Zoological Survey of India, with its population trends notably declining. Subsequently, they were reported as being critically endangered, with the Wildlife Institute of India (WII) Survey finding that there were fewer than 150 GIB left in the wild.
The survival of the Great Indian Bustard has been imperilled by multiple intersecting threats, including habitat loss due to land acquisition, hunting pressures, and egg collection, as well as large-scale development projects encroaching upon its remaining grassland ecosystems. Power projects caused severe habitat degradation for the big birds, who, due to their low and heavy flight, collide with power lines that are difficult for them to avoid. The WII research studies show that nearly 18 GIBs are estimated to be dying every year due to collisions with power lines in Thar, Rajasthan. As major solar power-producing states, Gujarat and Rajasthan, a conflict of interest between power firms & habitat conservation arose.
In 2016, WII and the Forest Department of Rajasthan initiated a joint project to enhance the habitat and conservation breeding of the GIB. The bird species also recently secured another crucial reprieve, with the Supreme Court of India affirming its commitment to protecting one of India’s most critically endangered birds through a landmark conservation-focused verdict. This decision now sets the stage for a deeper examination of the legal battle that has come to define the future of the bird, its habitat, and India’s development trajectory.
Legal Battle
The legal battle surrounding the Great Indian Bustard (GIB) epitomizes the complex intersection between biodiversity conservation and India’s push for a rapid renewable energy transition. At the heart of the dispute is the public interest litigation (PIL) filed by Dr. M.K. Ranjitsingh to protect the critically endangered GIB, which has become a flashpoint in discourse over how clean energy infrastructure must be developed within sensitive wildlife habitats.
In April 2021, the Supreme Court imposed sweeping restrictions on the installation of overhead electricity transmission lines across protected areas in Rajasthan and Gujarat, which constituted crucial habitats for the bustard. The SC demarcated a large swathe of territory approx 99,000 sq km, as priority and potential GIB habitats.
These directions sought to reduce the risk of bird collisions, which became a major threat to the species. However, the blanket nature of these restrictions triggered a strong push back from the renewable energy sector and the government, who argued that the order covered a much larger area than the actual habitat of the birds. They also cited major financial and practical difficulties in implementing the orders by the SC, stating that high-voltage underground lines were not feasible in the area.
Faced with competing imperatives of conservation and climate obligations, the Supreme Court, in its 2024 order, recalibrated its approach rather than enforcing a blanket ban on overhead lines the court constituted an expert committee to assess priority GIB areas and the feasibility of undergrounding transmission infrastructure on a Case by case basis it emphasized that conservation measures must be science-based proportionate and aligned with broader sustainable development goals.
In a major win for GIB conservation, the 2025 Supreme Court order reaffirmed these expert-guided directions, extending protections and endorsing measures to mitigate the impacts of climate change while offering clarity on renewable sector compliance. The legal battle marked a significant milestone in Indian environmental law, establishing a framework in which renewable energy expansion and conservation measures are balanced rather than pursued in isolation.
Balancing Resource Availability and Conservation Boundaries
Renewable energy plays an important role in India’s commitment to combat climate change. India has rapidly increased its renewable energy share in its energy mix due to optimal conditions for high solar insolation and vast open landscapes. However, these landscapes are also prime habitat for the GIB, whose fragmented grassland range overlaps with potential renewable energy zones.
This tension between resource availability and biodiversity protection is not unique to the GIB alone. It has been a central conversation, one often not given due consideration in large infrastructure projects, including the Great Nicobar project. Close to the conservation on the GIB in Rajasthan, local farming communities have been engaged in their own struggle to defend orans: traditional sacred groves that serve as community-managed forests and pasturelands, which also harbour rich biodiversity, including the GIB.
As Article 14 documents, in Rajasthan, farmers showed up to protest against the solar energy projects, which they feared would take over their traditional grazing and pasture lands. These lands are also habitats for the Indian gazelle and the Indian desert fox. The Supreme Court’s interventions in both the GIB power-line case and the orans dispute underscore the need for nuanced governance that goes beyond the binary choices between conservation and development. Yet, the government’s recent efforts to narrow and redefine what qualifies as a “forest” under Indian law amplifies an uncertainty around ecological protection, inadvertently pushing communities towards courtroom resolution.
The cumulative effect, however, risks making litigation rather than transparent policy-making or participatory governance.
Conclusion
The Supreme Court’s reassertion of the GIB habitat and protection has undoubtedly been welcomed as a landmark moment for wildlife conservation in India. It projects the image of a judiciary willing to step in, decisively, to protect one of the country’s most critically endangered species, reinforcing the idea that India is equally concerned with its ecological heritage.
However, the climate and development framework continues to be driven largely by mitigation metrics such as installed renewable energy capacity and emission reductions. Protecting its unique ecological heritage becomes an internal priority that India must not sideline in the face of international pressure. While court orders may temporarily shield specific species or habitats, they do not fundamentally recalibrate how environmental priorities are integrated into development planning. As a result, conservation continues to operate reactively, dependent on judicial intervention rather than being embedded within policy design from the outset.
Yet, this moment also reflects on a critical opportunity. The case of the GIB has forced a national conversation on how India defines sustainability, whose interests shape land-use decisions, and how ecological costs are accounted for in climate policy. Rather than relying on the SC as the primary arbiter of environmental governance, India can use this inflection point to reimagine a more participatory and transparent conservation framework.
