Corporate Social Responsibility Must Include Environmental Responsibility, Says Supreme Court In Great Indian Bustard Case
The Supreme Court of India ruled on December 18, 2025, that Corporate Social Responsibility (CSR) under the Companies Act, 2013, must encompass environmental responsibility, particularly in the context of protecting the critically endangered Great Indian Bustard (GIB). This landmark decision arose from a 2019 petition highlighting threats to GIB and Lesser Florican from overhead power lines in Rajasthan and Gujarat.
The bench, comprising Justices P.S. Narasimha and Atul S. Chandurkar, held that corporations, as legal persons, share the fundamental duty under Article 51A(g) of the Constitution to protect wildlife and ecosystems. CSR funds represent fulfillment of this duty, not voluntary charity, and must address habitat threats from corporate activities via the Polluter Pays principle. Companies operating in GIB areas were urged to act as “guests” in the bird’s abode.
The litigation addressed GIB extinction risks from power infrastructure collisions and habitat loss. The Court approved revised priority conservation areas: 14,013 sq km in Rajasthan and 740 sq km in Gujarat, while mandating undergrounding of 250 km of critical lines within two years. It deferred bird flight diverters pending scientific validation and emphasized in-situ conservation like grassland restoration.
This expands Schedule VII of the Companies Act to explicitly link CSR with ecological balance and species protection. Non-renewable power generators must allocate CSR for conservation, blending social welfare with environmental mandates and reinforcing ecocentrism over anthropocentrism.
