The Great Indian Bustards (GIBs) are critically endangered species found in the grassland and arid regions of southern and western India, potentially spanning over around 90,000 square kilometres of Rajasthan, Maharashtra, Gujarat, and Karnataka. The Indian State of Rajasthan is the homeland of GIBs. Recent research reveals a sure extinction of GIBs due to expansion of overhead power line transmission and wind turbines in the region of GIBs habitat. This research paper examines the incorporation of environmental rule of law within the Indian environmental legal frameworks to explore the equilibrium between the human right to development and human rights of the environment informed by international environmental laws. This research paper finds that the expert reports are not in favour of converting overhead power line transmission into underground power line transmission for several reasons, as well as the geospatial capacity of the region for wind energy generation cannot be abandoned to shift from fossil-based energy. The solutions to protect GIBs are ex-situ incubation of GIBs, incentivizing civic engagement in the conservation of GIBs, banning cattle grazing over the GIBs habitat region, banning use of pesticides in agricultural fields near the GIB priority areas, and installation of bird diverters on the overhead power transmission lines.