Author: Dr. Manini Syali, Assistant Professor, TERI School of Advanced Studies, New Delhi.

On 19 December 2025, the Supreme Court of India decided M.K. Ranjitsinh & Ors. v. Union of India & Ors. (2025 INSC 1472), a case that began as a conflict between wildlife conservation and energy infrastructure, but ends up speaking in a deeper constitutional idiom: ecocentrism. In doing so, the Apex Court does not merely protect a critically endangered species; it invites us to rethink what “sustainability” means in a constitutional order that must face both biodiversity collapse and climate change.

The factual setting

The litigation concerns the Great Indian Bustard (GIB), known by the locals as “Godawan”, a flagship species of India’s arid and semi-arid grasslands. The Court records a dramatic population decline: the IUCN estimated 50–249 mature individuals, and the species was categorised as “critically endangered” in 2011, whereas the Indian state of Rajasthan estimated around 125 birds in 2013 [para 8].

The decline is not mysterious. Habitat loss and fragmentation matter, but so do concrete, everyday causes and, mortality linked to overhead transmission lines that cut across the bird’s habitat [para 8 (v)] The Indian state, however, also sees these landscapes as zones of immense solar and wind potential [para 12]. That is the structural tension implicit within the case: the very geography suitable for large-scale renewables is also the geography in which a species is being pushed towards extinction.

Filed in 2019 under Article 32, the petition sought emergency measures for recovery, including bird diverters, restrictions on new projects in critical habitats, and an empowered committee to ensure implementation [para 9].

What makes the judgment distinctive

The Court is candid about the “contestation” between conserving an endangered species and generating green energy to address climate change [para 6]. Yet it does not accept the framing that biodiversity must be the inevitable “cost” of development, green or otherwise. Instead, it treats the dispute as an opportunity “to rethink environmental conservation… in our pursuit of sustainability and mutual coexistence with other living beings” [para 6].

This is where ecocentrism enters. In actuality, it is not rhetoric, but a method. The Court is not only asking whether mitigation is technically possible; it is asking what constitutional responsibility demands when the consequence of error is extinction.

The Supreme Court’s Ecocentrism in action

First, the Court grounds ecocentrism in India’s own ethical traditions and community practices. It refers to ways of living that “honour the intrinsic value of every living being” [para 3]. This matters because ecocentrism is often dismissed as an imported, idealistic theory. In this case, the Court reads it as part of a constitutional culture in which nature is not a mere resource, but a co-inhabitant of a shared ecological home.

Second, the Court leans on a “species best interest” approach, which is an important doctrinal signal [para 39]. Under this standard, the survival of an endangered species is not one factor in a cost-benefit spreadsheet; it is the organising priority, capable of constraining commercial convenience. In other words, the Court treats biodiversity loss as irreversible harm which is the kind of harm constitutional remedies are meant to prevent.

Third, and most significantly, the judgment pushes beyond penalties and speaks the language of restoration. The Court applies the polluter pays principle (PPP) in a way that assigns the burden of recovery to those whose activities contribute to habitat and species decline [para 39]. By doing so, the court appears to explicitly link corporate action to duties towards species survival. This is a decisive move because wildlife law in practice often remains predominantly penal, for instance, through offences, prosecutions, fines; without building a robust architecture of ecological repair. The Court, by contrast, insists on recovery as a matter of responsibility.

Corporate responsibility: expanding “community” to include nature

The judgment’s discussion of Corporate Social Responsibility (CSR) is not ornamental. It recognises that CSR in India has moved from voluntary philanthropy to statutory obligation, and then develops the idea further: the “definition of ‘community’… has been expanded to explicitly include the natural world,” so that “social welfare” cannot be detached from “environmental health” [para 37].

The Court then constitutionalises this point by stating, in effect, that directing corporate resources towards environmental protection is not charity but the fulfilment of constitutional obligation [para 38]. When read together, these passages tighten the accountability loop as the beneficiaries of ecological exploitation cannot outsource the costs of repair to the public exchequer or future generations.

The larger implication: a constitutional vocabulary for the climate–biodiversity nexus

Importantly, the Court does not deny India’s climate imperatives. It situates the controversy within green energy generation and climate change concerns, but insists that the path to decarbonisation cannot be paved with biodiversity extinction. This is, ultimately, what makes the judgment “eco-centric”: development must be redesigned around ecological limits, not merely justified against them.

The Godawan judgment therefore marks a jurisprudential moment. It nudges Indian environmental constitutionalism away from the familiar language of “balancing” and towards a more demanding ethic: coexistence, intrinsic value, and species survival as a constitutional priority. If this approach is carried forward consistently, it may reshape how Indian courts evaluate infrastructure, especially “green” infrastructure, by asking not only whether a project is efficient, but whether it is ecologically just.