S. Rajaseekaran v. Union of India & Ors., 2025
The Court took a holistic view of pedestrian and non-motorised road user safety, previously under-emphasised in urban planning.

Judgement Details
Court
Supreme Court of India
Date of Decision
7 October 2025
Judges
Justice J.B. Pardiwala and Justice K.V. Viswanathan
Citation
Acts / Provisions
Facts of the Case
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A long-standing public interest litigation (PIL) filed in 2012 by Dr. S. Rajaseekaran, focusing on road safety, especially pedestrian safety.
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The Court has been monitoring the case over years, issuing multiple orders to improve road infrastructure, enforce helmet laws, and ensure pedestrian-friendly public spaces.
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On October 7, 2025, the Supreme Court issued a final set of comprehensive directions to States, UTs, and road-owning agencies.
Issues
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Whether States and UTs have taken adequate steps to ensure pedestrian safety in light of increasing road accidents?
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Whether the lack of proper footpaths, crossings, and enforcement of helmet/lane rules violates Article 21?
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What rules and guidelines should be implemented under Sections 138(1A) & 210D of the MV Act to improve safety for non-motorised road users?
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Whether lack of grievance redressal mechanisms and infra audits leads to systemic negligence?
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How can technological enforcement tools (e-cameras, real-time dashboards, AI monitoring) be leveraged for safer roads?
Judgement
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The Supreme Court directed the road-owning agencies in 50 major cities (as listed in the Road Accidents Report 2023) and the National Highways Authority of India (NHAI) to conduct an audit of all existing footpaths. This audit must assess the width, height, surface condition, and overall safety and usability of footpaths. Based on these findings, authorities must formulate a time-bound action plan to implement repairs and engineering improvements.
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The Court ordered a detailed audit of all existing pedestrian crossings to ensure they conform to the Indian Roads Congress (IRC) Guidelines, particularly IRC:35-2015 and IRC:67-2012. These audits must identify deficiencies and recommend remedial, time-bound measures. Focus must be placed on installing high-visibility zebra markings, night-time illumination, raised pedestrian crossings, and traffic calming features.
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The judgment emphasized the upgradation of pedestrian subways and foot overbridges (FOBs). These must be equipped with LED lighting, CCTV cameras linked to command centers, clearly marked entry and exit points, and panic buttons that connect directly to the local police stations for enhanced safety and surveillance.
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The Court highlighted the urgent need for additional pedestrian crossing infrastructure at critical locations, particularly around Delhi High Court and the National Zoological Park on Mathura Road, New Delhi.
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Authorities must identify school zones and high-risk pedestrian corridors using accident data. In such areas, they are required to implement context-specific safety interventions, including zebra crossings, raised crossings, traffic calming devices, and the deployment of trained crossing guards to protect vulnerable road users such as children.
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All bus terminals, metro stations, and railway stations must be evaluated for the availability and adequacy of pedestrian facilities. These assessments should confirm whether the infrastructure aligns with IRC safety standards.
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The Court instructed State Governments, Municipal Authorities, and NHAI to establish a dedicated online grievance redressal system. This platform should allow citizens to register complaints regarding encroachments, damaged or unsafe footpaths, and lack of pedestrian crossings, as well as to submit suggestions for infrastructure improvement.
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All State Governments, Union Territories, and NHAI have been directed to strictly enforce helmet-wearing laws for both two-wheeler riders and pillion passengers. This enforcement must involve e-surveillance using traffic cameras, and data on the number of violations, fines collected, and licenses suspended must be regularly submitted to the Court.
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The State Transport Departments, Urban Local Bodies, and Traffic Police must take steps to curb unlawful lane driving, including the deployment of automated enforcement mechanisms. The Court recommended the use of graduated fines, textured lane markings, rumble strips, and tyre killers at vulnerable points. Authorities may also create real-time public dashboards to display lane violations, thereby raising public awareness.
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The Court directed the Ministry of Road Transport and Highways (MoRTH) and relevant enforcement bodies to set permissible luminance levels and beam angles for vehicle headlights and to check for compliance during PUC (Pollution Under Control) tests and vehicle fitness certification. A complete ban on unauthorized red-blue strobe lights and illegal hooters has also been ordered. Enforcement must include seizures, penalties, and market crackdowns, along with public awareness campaigns to educate drivers about the hazards associated with such modifications.
Held
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The right to safe footpaths and roads is part of Article 21.
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All directions are binding, and implementation must begin within six months.
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States/UTs are mandated to formulate necessary rules under the MV Act, specifically:
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Section 138(1A): Access rules for pedestrians and NMVs
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Section 210D: Road design and maintenance rules
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Analysis
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The Court took a holistic view of pedestrian and non-motorised road user safety, previously under-emphasised in urban planning.
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It recognised the interlinkage between infrastructure, enforcement, and public awareness.
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The judgment enforces accountability on multiple agencies: PWD, NHAI, traffic police, municipal bodies, and MoRTH.
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It balances enforcement with accessibility, particularly for vulnerable groups like children and persons with disabilities.
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By calling for data submission, e-monitoring, and structured audits, the Court pushes for institutional reform in road safety governance.