The case of M.K. Ranjitsinh v. Union of India brought before the Supreme Court epitomizes the convergence of environmental conservation, climate policy, and human rights. The petitioners, advocating for the protection of endangered species like the Great Indian Bustard (GIB), highlighted the role of transmission lines in jeopardizing vulnerable avian populations. This article examines the case's arguments, judgments, and broader implications, particularly as they pertain to the intersection of renewable energy development, India's climate commitments, and constitutional rights. Through this analysis, we aim to unpack the nuanced balance the Court struck in its rulings and elucidate the evolving legal recognition of the "right to be free from adverse effects of climate change."

Introduction
In M.K. Ranjitsinh & Ors. v. Union of India & Ors., the Supreme Court of India addressed an unprecedented environmental dilemma: the conflict between safeguarding endangered species and advancing renewable energy initiatives critical to India's climate obligations. The case foregrounded not only India's commitment to environmental protection under Article 48A of the Indian Constitution but also recognized the constitutional mandate of Article 21 to uphold the right to life. This analysis seeks to contextualize the Court's ruling within the broader trajectory of climate change litigation, examining its implications for India's environmental policy and the advancement of a distinct right against climate change's adverse impacts.

Case Background
The petitioners, led by conservationist M.K. Ranjitsinh, sought the Court's intervention to protect the critically endangered Great Indian Bustard and the Lesser Florican, species threatened by the proliferation of power lines in their natural habitats. With only an estimated 125 GIBs left in Rajasthan, the petitioners contended that high-voltage power lines posed fatal threats to these ground-nesting birds. They invoked Article 32 to call for urgent measures, including relocating overhead transmission lines underground in critical habitats, installing bird diverters, and initiating a comprehensive conservation strategy.

The petitioners' demands underscored India's responsibility under the Wild Life (Protection) Act, 1972, which mandates the preservation of endangered species and their habitats. Additionally, the case highlighted India's international commitments under the United Nations Framework Convention on Climate Change (UNFCCC) and the Paris Agreement, both of which reinforce India's obligation to adopt renewable energy solutions to mitigate climate impacts.

Judicial Analysis and Observations
The Right to a Healthy Environment and Climate Justice
Justice D.Y. Chandrachud, in delivering the judgment, emphasized the foundational right to a clean and healthy environment under Article 21. The Court recognized that this right encompasses a broader "right to be free from adverse effects of climate change," thus advancing India's evolving jurisprudence on environmental and climate rights.

The Court's reliance on Articles 14 and 21 reflects its acknowledgment of the inherent link between environmental degradation and fundamental rights. Drawing from precedent in M.C. Mehta v. Kamal Nath (2000) and Virender Gaur v. State of Haryana (1995), Justice Chandrachud affirmed that environmental degradation, whether due to habitat encroachment or climate impacts, violates the right to life, dignified existence, and equality. The Court further referenced Article 48A, which mandates the State's proactive role in environmental protection, and Article 51A(g), which entrusts citizens with the duty to safeguard biodiversity and the natural environment.

International Law and India's Climate Obligations
The Court's observations also acknowledged India's international environmental obligations, specifically the UNFCCC, Kyoto Protocol, and Paris Agreement, which underscore India's commitment to reduce carbon emissions and promote sustainable energy sources. India's Intended Nationally Determined Contributions (INDC), submitted in 2015, set ambitious targets to transition from fossil fuels to renewable energy by 2030. These commitments resonate with Article 3 of the UNFCCC, which calls for equitable climate measures and emphasizes the importance of protecting vulnerable communities from climate change.

Justice Chandrachud underscored that the dual objective of conserving the GIB and promoting renewable energy should be approached as a symbiotic rather than adversarial undertaking. The Court's order to reconsider overhead power transmission in critical habitats sought to mitigate threats to the GIB while safeguarding India's renewable energy trajectory, which is crucial to its climate objectives.

The Ruling and Its Balancing Act
In its order, the Court noted the technical, environmental, and economic challenges posed by mandating the undergrounding of all power lines across the GIB's expansive habitat. It directed the establishment of an Expert Committee to examine viable conservation strategies, allowing experts to determine region-specific approaches to wildlife preservation while advancing renewable energy infrastructure.

The Directive and Role of the Expert Committee
The Committee, composed of conservation experts and representatives from India's renewable energy sector, was tasked with:

• Identifying areas where power lines could feasibly be relocated underground;
• Assessing the impact of bird diverters on existing power lines to mitigate avian mortality;
• Examining international conservation models, such as those for the Houbara Bustard, to adapt successful practices to the Indian context.

The Court's directive demonstrated judicial deference to scientific expertise, an approach that seeks to balance judicial intervention with environmental policy, underscoring the recognition of climate change as an existential threat demanding pragmatic responses.

Comparative Climate Change Litigation
The ruling in M.K. Ranjitsinh aligns with recent global trends in climate change litigation, where courts have increasingly acknowledged the nexus between human rights and climate action. Noteworthy cases include State of the Netherlands v. Urgenda Foundation and Sacchi v. Argentina, where courts recognized state obligations to reduce greenhouse emissions and protect citizens from climate change impacts. By invoking Articles 14 and 21 to assert a right to be free from climate harms, the Indian Supreme Court's judgment reflects a growing recognition of environmental justice and climate accountability.

Conclusion
The M.K. Ranjitsinh case exemplifies a legal milestone, embedding the right to a climate-stable environment within India's constitutional framework. By affirming the right to be free from adverse climate impacts, the Court underscored the State's duty to harmonize environmental conservation with sustainable development. This precedent extends beyond India's borders, contributing to the global movement toward environmental justice and affirming the judiciary's role as a steward of intergenerational equity.

The Court's approach acknowledges that combating climate change is not merely a policy objective but a legal imperative intrinsic to the protection of fundamental rights. As the adverse effects of climate change intensify, the judiciary's role in reinforcing the constitutional and moral imperatives of climate justice will remain pivotal.