Supreme Court in M.K. Ranjithsinh Others vs Union of India & Others by upholding the biocentric principles of
coexistence has given new life to biocentrism over anthropocentrism.
What was the need for the Judgment?
This case was filed for the protection of Great Indian Bustard in the state of Gujarat and Rajasthan which is “Critically
Endangered” as per IUCN Red List. In the states of Gujarat and Rajasthan overhead power lines have become a threat to
the life of these species as these birds frequently tend to collide with these power lines and get killed. Even the Ministry
of Power in an Affidavit had stated that the Great Indian Bustard (“GIB”) lacks frontal vision. Due to this, they cannot
detect powerlines ahead of them from far. As they are heavy birds, they are unable to manoeuvre across power lines
within close distances. Thus, they are vulnerable to collision with power lines.
What did Supreme Court decide?
The Court held that in all cases where the overhead lines in power projects exist, the governments of Rajasthan and
Gujarat shall take steps to install bird diverters pending consideration of the conversion of overhead cables into
underground power lines. In protecting the birds, the Court has affirmed and emphasised the biocentric values of eco-
The philosophy of biocentrism holds that all life deserves equal moral consideration and has equal moral standing and
extends inherent value to all living things. It is an understanding of how the earth works, particularly as it relates to its
biosphere or biodiversity. Thus, biocentric ethics calls for a rethinking of the relationship between humans and nature.
This perspective is very much contrary to Anthropocentricism which is a human-centred system.
Biocentrism consists of at least two qualitatively distinct attitudes: First, biocentrism can stem from a desire to avoid
hurting sentient beings (e.g., harboring concerns about killing animals). Second, biocentrism can stem from a desire
to uphold purity in nature (e.g., harboring concerns about violating the sanctity of nature). Avoiding harm and preserving purity have been identified as two separate forms of moral concern that rely on functionally distinct systems of cognitive
and emotional processing. Therefore, the concept of biocentrism potentially obscures a psychologically important
distinction in environmentalist attitudes.
Anthropocentrism versus Biocentrism
Anthropocentric concerns for the environment are narrowly aimed at preserving the welfare of humans, while biocentric
concerns are oriented toward protecting non-human organisms and nature as a whole. While anthropocentrism can
sometimes lead to pro-environmental attitudes and actions, biocentrism is more reliably and robustly related to
environmentalism, both for abstract values and for concrete behaviors. So, we can say that anthropocentrism promotes
the preservation of the environment as a means to an end rather than an end in itself. However, biocentrism treats
environmentalism as a moral imperative independently of its impact on human flourishing.
Supreme Court’s Biocentric Interpretation of Article 21 in the Past
Supreme Court in the case of T.N. Godavarman Thirumalpad v Union of India (2002) has pointed out two salutary
principles governing environment. They are:
1. Principle of Sustainable Development
2. Precautionary Principle –governments and concerned authorities must anticipate, prevent and attack causes for
The Court held that Convention on Biological Diversity having been acceded to by India, the government should in the
absence of compelling reasons keep in view the international obligations while exercising its discretionary powers under
The Forest (Conservation) Act.
Supreme Court has also taken cognizance in number of cases of various environmental problems and has given necessary
direction to state for preservation of environment. In giving such directions, the Court has relied on Directive Principles as
those contained in Article 47 and Article 48A along with Fundamental Duties under Article 51A(g).
Article 47 – Duty of the State to raise the level of nutrition and the standard of living and to improve public
health – The State shall regard the raising of the level of nutrition and the standard of living of its people and the
improvement of public health as among its primary duties and, in particular, the State shall endeavour to bring
about prohibition of the consumption except for medicinal purposes of intoxicating drinks and of drugs which are
injurious to health.
Article 48A – Protection and improvement of environment and safeguarding of forests and wild life — The State
shall endeavour to protect and improve the environment and to safeguard the forests and wild life of the country.
Article 51A(g) – It shall be the duty of every citizen of India to protect and improve the natural environment
including forests, lakes, rivers and wild life, and to have compassion for living creatures.
Supreme Court’s judgment in M.K. Ranjithsinh upholding the biocentric principles of coexistence is a shot in the arm for
nature conservation. One does hope that the respective governments implement the judgment of the Court for better
protection of Great Indian Bustard. Further, government must also ponder to bestow NATURE their due “constitutional
rights” which cannot be taken away without reasonable purpose.