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M.K. Ranjitsinh v. Union of India (2024): Right Against Climate Change

In M.K. Ranjitsinh v. Union of India (21 March 2024) the Supreme Court recognised a right to be free from the adverse effects of climate change under Articles 14 and 21.

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A Right Against Climate Change? M. K. Ranjitsinh Case Explained

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Quick answer

Yes. In M.K. Ranjitsinh v. Union of India, decided on 21 March 2024, the Supreme Court held that Articles 14 and 21 together give people a right to be free from the adverse effects of climate change. The Court treated this right and the right to a clean environment as two sides of the same coin. The case arose from the conflict between protecting the critically endangered great Indian bustard and building transmission lines for solar and wind power in Rajasthan and Gujarat.

The leading case

Case

M.K. Ranjitsinh v. Union of India, 2024 INSC 280, Supreme Court of India, decided 21 March 2024 (D.Y. Chandrachud, CJI, J.B. Pardiwala and Manoj Misra, JJ.), in Writ Petition (Civil) No. 838 of 2019 with Civil Appeal No. 3570 of 2022. An order of 19 April 2021 had restricted overhead transmission lines across about 99,000 sq km of great Indian bustard habitat and required many lines to be laid underground. The Court found that the blanket direction had broad implications, including for India's renewable energy commitments. The Court recalled the blanket direction, referred the question of protective measures to an expert committee, and in doing so recognised a right against the adverse effects of climate change under Articles 14 and 21.

How the Court reached the right

  • Articles 48A and 51A(g): these are not enforceable by themselves, but they show the value the Constitution places on the environment, which becomes a right through Articles 21 and 14.
  • Article 21: earlier cases already held that a clean, hygienic environment is part of the right to life. Climate effects such as air pollution, disease, droughts and food shortages threaten the right to health.
  • Article 14: climate change hits poorer and vulnerable groups (island populations, forest dwellers, tribal communities) hardest; their inability to adapt can violate the right to equality as well as the right to life.
  • No umbrella law: the Court noted that India has no single umbrella legislation on climate change, but said this does not mean people lack a right against its adverse effects.
  • International commitments: the Court referred to the Paris Agreement and India's Nationally Determined Contributions, including the goal of about 50 per cent non-fossil electric capacity by 2030.

The 2021 order and the 2024 judgment compared

PointOrder of 19 April 2021Judgment of 21 March 2024
ApproachBlanket restriction on overhead lines in about 99,000 sq kmBlanket direction recalled; measures to be set by experts
Power linesUndergrounding required for many linesFeasibility left to an expert committee
Climate changeNot the focusRight against adverse effects of climate change recognised under Articles 14 and 21

Example

Example

Neha is a small farmer facing repeated heatwaves and failing groundwater. After Ranjitsinh, climate harm to people like her has constitutional weight, and courts must consider it when judging State action. This does not mean every heatwave automatically gives Neha a claim for compensation; a particular case still needs a legal basis and evidence linking the harm to an act or failure of the State.

Current-law note

The expert committee reported, and on 19 December 2025 (2025 INSC 1472) a bench of P.S. Narasimha and Atul S. Chandurkar, JJ. disposed of the matter. It accepted revised priority areas of 14,013 sq km in Rajasthan and 740 sq km in Gujarat, barred new wind turbines, new solar parks above 2 MW and new overhead lines (except through dedicated power corridors) in the revised priority areas, and directed undergrounding of specified critical lines within time limits. The 2024 recognition of the climate right has not been overruled. Earlier environmental rights under Article 21 trace back to cases such as Subhash Kumar v. State of Bihar (1991); see Environmental Law Case Law.

Exam point

Exam point

M.K. Ranjitsinh v. Union of India (21 March 2024): Articles 14 and 21 recognise a right to be free from the adverse effects of climate change.

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Frequently asked questions

Is there a right against climate change in India?

Yes. In M.K. Ranjitsinh v. Union of India (21 March 2024) the Supreme Court held that Articles 14 and 21 recognise a right to be free from the adverse effects of climate change, closely linked to the right to a clean environment.

What was the great Indian bustard case about?

A 2021 order had restricted overhead transmission lines over about 99,000 sq km of bustard habitat in Rajasthan and Gujarat. In 2024 the Court recalled that blanket direction, set up an expert committee to balance conservation with renewable energy, and recognised the climate right.

What happened after the 2024 judgment?

On 19 December 2025 (2025 INSC 1472) the Supreme Court accepted the expert committee's revised priority areas of 14,013 sq km in Rajasthan and 740 sq km in Gujarat, barred new wind turbines and solar parks above 2 MW there, and ordered undergrounding of critical lines.

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