Why in News ?
- Justice P.S. Narasimha of the Supreme Court remarked that several environmental law principles imported from the West, such as “inter-generational equity”, are anthropocentric (human-centered) and inadequate for protecting endangered species.
- The observation came during a hearing on a petition for conservation of the Great Indian Bustard (GIB) and Lesser Florican, both critically endangered bird species.
Relevance:
GS 3 – Environment & Biodiversity Conservation
• Ecocentrism vs anthropocentrism in wildlife protection
• Constitutional provisions – Articles 48A & 51A(g)
• Landmark judgments – T.N. Godavarman (2012), Animal Welfare Board (2014)
• Laws – Wildlife (Protection) Act, 1972 and Biodiversity Act, 2002
• Conservation of endangered species – Great Indian Bustard, Florican
GS 2 – Polity & Judiciary
• Judicial philosophy on environmental protection
• Role of Supreme Court in expanding environmental jurisprudence
• Integration of traditional Indian ecological ethics in legal reasoning
Case Context
- Petitioner: M.K. Ranjitsinh (noted wildlife conservationist).
- Concern: Rapid decline of Great Indian Bustard and Lesser Florican populations.
- GIB: ~150 in wild, ~70 in captivity.
- Lesser Florican: ~70 individuals.
- Issue: Captive breeding showing limited success; extinction risk imminent.
- Respondent: Union and State governments, on conservation failures.
Key Observation by Justice Narasimha
- Critique: Western-origin doctrines like inter-generational equity treat nature’s value through the lens of human utility — “Biblical roots” placing man atop creation.
- Argument: Such human-centered frameworks fail to protect non-human species whose value isn’t tied to human benefit.
- Emphasis: Courts and laws should adopt an ecocentric approach — valuing all life forms intrinsically, not just for human welfare.
- Reference: Supreme Court’s earlier Red Sanders (2011) case, where the Court acknowledged the “intrinsic worth of all species” over their instrumental value.
Conceptual Background
(a) Anthropocentrism
- Human-centered worldview; nature valued for its utility to humans.
- Example: Inter-generational equity → focuses on fair use of resources for present and future human generations.
- Critique: Ignores intrinsic rights of nature and species.
(b) Ecocentrism
- Nature-centered ethics; ecosystems and species possess intrinsic rights.
- Every species has a moral and legal right to exist, irrespective of human needs.
- Rooted in Indian ecological philosophy (e.g., Vasudhaiva Kutumbakam, Ahimsa, Pancha Mahabhutas).
Key Environmental Principles Discussed
| Principle | Origin | Focus | Criticism/Observation |
| Inter-generational Equity | Western (Weiss, 1989) | Resource fairness across generations | Anthropocentric — prioritizes human needs |
| Sustainable Development | Brundtland Report (1987) | Development meeting human needs | Human welfare–oriented |
| Precautionary Principle | Western | Preventive approach to harm | Often framed around human safety |
| Ecocentric Approach | Indigenous & global ecological ethics | Rights of nature, intrinsic worth | Favoured by Indian jurisprudence (SC, 2012–23) |
Evolution of Environmental Jurisprudence in India
| Phase | Landmark Cases | Key Principle |
| 1980s–90s: Anthropocentric | Rural Litigation and Entitlement Kendra (1985), Vellore Citizens (1996) | Sustainable development, inter-generational equity |
| 2000s–2010s: Shift to Ecocentrism | T.N. Godavarman (2012), Animal Welfare Board v. A. Nagaraja (2014) | Rights of species, compassion for all life |
| 2020s: Constitutional deepening | Great Indian Bustard case (2021–25) | Ecocentrism over anthropocentrism reaffirmed |
Key Precedent Cases Referenced
- Red Sanders Case (2011):
- Amicus Curiae urged focus on “intrinsic worth” of species.
- SC accepted ecocentric argument — human interests not the only measure of environmental protection.
- T.N. Godavarman Thirumulpad v. Union of India (2012):
- Recognized “ecocentric jurisprudence”; emphasized duty to protect all species.
- Animal Welfare Board v. A. Nagaraja (2014):
- Declared animals have right to live with dignity; introduced “compassion for all living creatures” (Art. 51A(g)).
- Great Indian Bustard case (2021–present):
- SC directed undergrounding of power lines in bustard habitats.
- 2025 hearing focuses on broader moral and philosophical underpinnings of conservation law.
Constitutional and Legal Basis for Ecocentrism
- Article 48A: State to protect and improve the environment.
- Article 51A(g): Duty of every citizen to protect and show compassion for living creatures.
- Biological Diversity Act, 2002: Recognizes need to conserve species and ecosystems.
- Wildlife (Protection) Act, 1972: Provides statutory protection for endangered species.
- Judicial Trend: Interprets constitutional duties as moral-ecological imperatives.
Broader Philosophical Debate
| Approach | Focus | Legal Implication |
| Anthropocentric | Humans as central agents | Environmental protection only when human welfare is affected |
| Ecocentric | Nature as a self-existent entity | Extends rights and compassion to all life forms |
| Biocentric | Life-centric (every organism matters) | Balances between human and non-human life |
Justice Narasimha’s critique reflects India’s shift from anthropocentrism → ecocentrism, aligning law with Indian civilizational ethos and biodiversity ethics.
