Holding

The Supreme Court directed the Union, State governments and relevant agencies to implement comprehensive road‑safety measures—including pedestrian‑infrastructure audits, helmet enforcement, lane‑discipline controls, and regulation of vehicle lighting—pursuant to the Motor Vehicles Act and related rules.

Summary

Dr. S. Rajaseekaran filed a writ petition under Article 32 seeking comprehensive road‑safety measures, especially for pedestrians, helmet use, lane discipline and vehicle lighting. The Court examined the statutory framework under the Motor Vehicles Act, Road Regulations and related rules, and considered extensive data on pedestrian deaths and accidents. Relying on earlier judgments affirming the right to safe footpaths, the Court held that the Union, State governments and agencies must audit and upgrade footpaths and pedestrian crossings, enforce helmet wearing through e‑enforcement, improve lane discipline, and ban dazzling LED headlights, red‑blue strobes and illegal hooters. It also directed States to frame rules under Sections 138(1A) and 210‑D of the MV Act and to set up grievance redress mechanisms. The order issued detailed, time‑bound directions as an interim measure, and the matter was listed for compliance review after seven months.

Issues considered

Whether the Supreme Court can issue mandatory directions under Article 32 to enforce road‑safety measures.
Whether the Union and State authorities are obligated to audit and improve pedestrian footpaths and crossings in accordance with IRC guidelines.
Whether mandatory helmet wearing for two‑wheelers can be enforced through e‑enforcement mechanisms.
Whether lane‑discipline violations and wrong‑lane driving can be curbed by statutory rules and automated enforcement.
Whether the use of dazzling LED headlights, unauthorized red‑blue strobe lights and hooters can be prohibited under the Motor Vehicles Act.
Whether States must promulgate rules under Section 138(1A) and Section 210‑D of the Motor Vehicles Act for pedestrian and road‑design regulation.
Whether a grievance redressal system for footpath and pedestrian‑crossing complaints is required.

Legislation cited

Central Motor Vehicles (Eleventh Amendment) Rules, 2020s. 166
Constitution of India
Indian Penal Code, 1860s. 279, s. 337, s. 338
Motor Vehicles Act, 1988s. 128, s. 129, s. 138(1A), s. 198-A, s. 198A, s. 210-C, s. 210-D
Road Regulations 1989s. 11, s. 5, s. 8

Headnote

Issue for Consideration Matter pertains to issuance of directions relating to road safety, safety of pedestrians while walking on footpaths, wearing of helmets, wrong lane driving and unsafe overtaking, use of dazzling LED white lights to help in reduction of road accidents – Art. 32 – Road safety and pedestrian safety – Alarming increase in road accidents and fatalities, and pedestrian fatalities – Issuance of directions relating to safety of pedestrians while walking on footpaths, making pedestrian crossings safe, wearing of helmets, wrong

Subjects

Road safetySafety of pedestrians while walking on footpathsWearing of helmetsWrong lane driving and unsafe overtakingUse of dazzling LED white lightsReduction of road accidents and fatalitiesPedestrian fatalitiesGuidelines for Pedestrian Safety [Second Revision] June, 2022 IRC 103-2022Indian Roads Congress GuidelinesMOHUA Harmonised Guidelines (2021)Report on Road Accidents, 2023Road crossing at the Delhi High Court and the National Zoological Garden on Mathura RoadDistrict Road Safety CommitteesMinistry of Road Transport & HighwaysState Transport DepartmentsTraffic police authoritiesNational highways

Judgment

[2025] 10 S.C.R. 311 : 2025 INSC 1189

S. Rajaseekaran
v.
Union of India and Ors.
(Writ Petition (C) No. 295 of 2012)
07 October 2025
[J.B. Pardiwala* and K.V. Viswanathan,* JJ.]

Issue for Consideration
Matter pertains to issuance of directions relating to road safety,
safety of pedestrians while walking on footpaths, wearing of helmets,
wrong lane driving and unsafe overtaking, use of dazzling LED
white lights to help in reduction of road accidents and fatalities.

Headnotes†
Constitution of India – Art. 32 – Road safety and pedestrian
safety – Alarming increase in road accidents and fatalities, and
pedestrian fatalities – Issuance of directions relating to safety
of pedestrians while walking on footpaths, making pedestrian
crossings safe, wearing of helmets, wrong lane driving and
unsafe overtaking, and land discipline, and use of dazzling
LED white lights, unauthorized sale and misuse of red blue
strobe lights and hooters which would help in reduction of
road accidents and fatalities:
Held: As regards safety of pedestrians, NHAI to start audit of existing
footpaths, to identify the deficiencies in the existing footpaths,
including the width, height, surface of the said footpaths, decide
the remedial measures, including repair and road engineering
improvement of the facilities, and fix a timeline for addressing
the deficiencies – Existing pedestrian crossings to be carefully
audited to ensure that they are compliant with the IRC Guidelines
to the extent possible – Pedestrian subways and foot overbridges
(FOBs) are often unsafe, poorly maintained, or inaccessible – Thus,
direction for audit of existing pedestrian crossings-requirement of
traffic calming measures as per IRC:35- 2015 and IRC:67-2012;
signage to indicate the existence of pedestrian crossing, with
high-visibility zebra markings, illumination of pedestrian crossings
during night-time, road dividers to be placed in a manner to prevent

* Author
312 [2025] 10 S.C.R.

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pedestrians from crossing the road at any other place, condition
and safety of pedestrian subways and FOBs, with upgradation
measures including improved LED lighting, CCTV surveillance
linked to command centres, clearly demarcated entry and exit
points, panic buttons connected to local police stations – In school
zones and other vulnerable corridors, authorities to systematically
identify high-risk stretches using accident data, and implement
context specific measures - raised crossings, zebra markings,
traffic calming features, and deployment of trained crossing
guards – Road owning agencies in the 50 cities in the Report on
Road Accidents, 2023 and the NHAI to draw up an action plan and
start phase-wise survey to assess the requirement of additional
pedestrian crossing facilities – First priority be given to the road
crossing at the Delhi High Court and the National Zoological Garden
on the Mathura Road – State transport departments, municipal
authorities, NHAI, and traffic police to strengthen implementation
and monitoring of pedestrian safety measures – Simple and
effective grievance redressal mechanism put in place by the PWD
Department, Municipal Authorities and NHAI so that complaints
pertaining to lack of maintenance of footpaths and the requirement
of a pedestrian crossing, are addressed – State Governments/
Municipal Authorities/NHAI to create an online grievance redressal
mechanism – As regards wearing helmets, issuance of direction
to all the State Governments, UTs and the NHAI to strictly
implement the provisions of law relating to wearing helmets by
two-wheeler drivers and passengers using two wheelers – Strict
enforcement of these rules to be ensured through e-enforcement
mechanism, cameras installed at various places – As regards
unlawful and wrongful lane driving, State transport departments,
traffic police authorities, and urban local bodies to take measures
to enforce lane discipline by addressing unlawful or wrong-lane
driving, including the use of automated cameras, graduated fines,
coloured and textured lane markings for bus and cycle lanes,
dynamic lighting, rumble strips, and tyre killers at critical conflict
points – Development and publication of real-time dashboards on
lane violations be explored to build public awareness, enhance
compliance, and improve overall road safety – As regards white
LED dazzling lights, red-blue strobe lights and unauthorised
hooters, Ministry of Road Transport & Highways, State Transport
Departments, and traffic police authorities to prescribe maximum
permissible luminance and beam angles for vehicle headlights
[2025] 10 S.C.R. 313

S. Rajaseekaran v. Union of India and Ors.

and ensure compliance through checks during PUC testing and
vehicle fitness certification, while conducting targeted drives to
penalize non-compliant or modified headlights – Complete ban on
unauthorized red–blue strobe flashing lights and illegal hooters to
be enforced through seizure, market crackdowns, and penalties,
and, nationwide public awareness campaigns to be conducted to
sensitize drivers and pedestrians about the hazards posed – States
and UTs to formulate and notify Rules u/s.138(1A) of the MV Act for
regulating the activities and access of non-mechanically propelled
vehicles and pedestrians to public places and national highways –
States and UTs to formulate and notify Rules u/s.210-D of the
MV Act for design, construction and maintenance of standards for
roads other than national highways – Motor Vehicles Act, 1988.
[Paras 35-35.17]

Case Law Cited
Olga Tellis v. Bombay Municipal Corporation [1985] Supp. 2
SCR 51 : (1985) 3 SCC 545; Ahmedabad Municipal Corporation v.
Nawab Khan Gulab Khan [1996] Supp. 7 SCR 548 : (1997) 11
SCC 121; Sudhir Madan v. Municipal Corporation of Delhi [2007]
7 SCR 1 : (2009) 17 SCC 332; MC Mehta v. Union of India [2019]
11 SCR 1053 : (2019) 10 SCC 614 – referred to.

List of Acts
Constitution of India; Road Regulations 1989; Penal Code, 1860;
Motor Vehicles Act, 1988; Central Motor Vehicles (Eleventh
Amendment) Rules, 2020.

List of Keywords
Road safety; Safety of pedestrians while walking on footpaths;
Wearing of helmets; Wrong lane driving and unsafe overtaking;
Use of dazzling LED white lights; Reduction of road accidents
and fatalities; Pedestrian fatalities; Guidelines for Pedestrian
Safety [Second Revision] June, 2022 IRC 103-2022; Indian Roads
Congress Guidelines; MOHUA Harmonised Guidelines (2021);
Report on Road Accidents, 2023; Road crossing at the Delhi High
Court and the National Zoological Garden on the Mathura Road;
District Road Safety Committees; Ministry of Road Transport &
Highways; State Transport Departments; Traffic police authorities;
National highways.
314 [2025] 10 S.C.R.

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Case Arising From
CIVIL ORIGINAL JURISDICTION: Writ Petition (C) No. 295 of 2012
Under Article 32 of The Constitution of India

Appearances for Parties
Advs. for the Petitioner:
Krishna Kumar, Vinodh Kanna B.
Advs. for the Respondents:
Gaurav Agrawal, Sr. Adv./Amicus Curiae
Vikramjit Bannerjee, Ms. Aishwarya Bhati, A.S.Gs., Sharan Dev
Singh Thakur, Sr. A.A.G., Rajat Bhardwaj, A.A.G., Ms. Shirin
Khajuria, Mrs. Swarupama Chaturvedi, Sr. Advs., Raj Bahadur
Yadav, Mrs. Madhulika Upadhyay Sharath Nambiar, Sabrish
Subramanium, Debojit Borkakati, Ms. Tusharika Sharma, Sudarshan
Lamba, Swarupama Chaturvedi, Sharath Nambiar, B.K. Satija, T.S.
Sabarish, Debojit Borkakati, Viresh B. Saharya, Ms. Prerna Mehta,
Kuriakose Varghese, V. Shyamohan, Sanjay Jain, Kishan hand
Jain, Sachin Kumar Dubey, Haraprasad Sahu, Pranaya Kumar
Mohapatra, Satyajeet Kumar, Ms. Astha Sharma, Ms. Ankita M
Bhardwaj, Ms. Baani Khanna, Robin Singh, Kapil Balwani, Santosh
Kumar - I, Pradeep Misra, Shantanu Sagar, Anil Kumar, Mrs.
Divya Mishra, Shaurya Vardhan Singh, Ms. Niharika Rai, Ashish K
Singh, Sunny Choudhary, Nitin Lonkar, Siddharth Dharmadhikari,
Aaditya Aniruddha Pande, Shrirang B. Varma, Ms. Swati Ghildiyal,
Ms. Neha Singh, V. N. Raghupathy, Nishe Rajen Shonker, Ms. Anu
K Joy, Alim Anvar, Santhosh K, Mrs. Devika A.I., Guntur Pramod
Kumar, Ms. Prerna Singh, Dhruv Yadav, Dhananjay Dutta Shrimali,
M. P. Vinod, Kishan Chand Jain, Rajesh Kumar, Ashwini Kumar,
Sidhant Sahay, E. C. Agrawala, Mrinal Elkar Mazumdar, Neeraj
Kumar Sharma, Ms. Indira Bhakar, Mukesh Kumar Verma, Harish
Pandey, Shashwat Parihar, Kanu Agarwal, Varun Chugh, Bhuvan
Kapur, Vinayak Sharma, Piyush Beriwal, Rajesh Singh Chauhan,
Apoorv Kurup, Shreekant Neelappa Terdal, Krishna Kant Dubey,
Azmat Hayat Amanullah, Ms. Rebecca Mishra, Sameer Abhyankar,
Rahul Kumar, Aakash Thakur, Neeraj Shekhar, Rajesh Maurya,
Mrs. Kshama Sharma, Ms. Ruchira Gupta, Ms. Tulika Mukherjee,
Beenu Sharma, Venkat Narayan, Ms. Ruchira Goel, Sharanya
Sinha, Ms. Veera Mahuli, Ms. Ritika Rao, Vivek Kishore, Subhasish
Mohanty, Mrs. Ranjita Sahu, Manaj Sarkar, Ms. Swati Tiwari, Rajan
[2025] 10 S.C.R. 315

S. Rajaseekaran v. Union of India and Ors.

Narain, Ms. K. Enatoli Sema, Amit Kumar Singh, Ms. Chubalemla
Chang, Prang Newmai, Ms. Yanmi Phazang, Anando Mukherjee,
Shwetank Singh, Ms. Pooja Singh, Aravindh S., Aman Gautam,
Ms. Anika Bansal, Ravi Raghunath, Manan Daga, M/s. Arputham
Aruna And Co, Mukesh Kumar Maroria, Ms. Sunita Sharma,
Ishaan Sharma, Annirudh Sharma Ii, Jagdish Chandra Solanki,
Sabarish Subramanian, Sumit Gupta, Ms. Jaikriti S. Jadeja, Akshay
Tiwari, Ms. Tanya Shrotriya, Shivang Goel, Ms. Juhi Bhargava,
Ms. Rashmi Nandakumar, Ms. Yashmita Pandey, Kunal Mimani,
Parag Chaturvedi, D. K. Devesh, Shuvodeep Roy, Deepayan
Dutta, Saurabh Tripathi, Ms. Deepanwita Priyanka, Satyalipsu
Ray, Prashant Bhagwati, Ms. Priyal Sheth, Raghvendra Kumar,
Divyanshu Kumar Srivastava, Saurabh Pandey, Pukhrambam
Ramesh Kumar, Karun Sharma, Ms. Anupama Ngangom,
Ms. Rajkumari Divyasana, Ms. Ruchira Gupta, Shishir Deshpande,
Ms. Pooja Tripathi, Amit Kumar, Abhishek Verma, Ms. Devina
Sehgal, Yatharth Kansal.

Judgment / Order of the Supreme Court

Order

J.B. Pardiwala & K.V. Viswanathan, JJ.

1. Dr. S. Rajaseekaran, a leading orthopaedic surgeon and a
public-spirited citizen of this country has invoked the jurisdiction of
this Court under Article 32 of the Constitution of India praying for
the following reliefs in public interest:
“a) To issue a writ of mandamus or any other appropriate
writ, order or direction, directing the Respondent NO.5 to
be directly responsible for this ‘national emergency’ and to
form and head an apex body with all such powers so that
all stake holders directly or indirectly responsible for the
creation of safer roads, licensing of drivers and vehicles,
enforcement of road safety, treatment of accident victims
and provision of due compensation to the victim to be
brought under one umbrella.
b) To issue a writ of mandamus or any other appropriate
writ, order or direction, directing the Respondent No. 5
to constitute a core road group for implementation of the
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following by allocating fixed time bound responsibilities on
Respondent Nos 1 to 4 and 6 to 7:
- various recommendations as contained in the Reports of
the 4 Working Groups of the Respondent No.1 pertaining
to Engineering, Enforcement, Education and Emergency
Care;
- the National Road Safety Policy;
- the measures suggested by the erstwhile Hon’ble
Chairman of the Law Commission and
- the suggestions of the Petitioner as contained in
paragraph 15 above.
c) To issue a writ of mandamus or any other appropriate
writ, order or direction, directing the Respondent No.5 to
constitute a monitoring group to monitor the Respondent
Nos. 1 to 4 and 6 to 7 in the implementation of each of
the above contained in paragraph (b) above;
d) To issue a writ of mandamus or any other appropriate
writ, order or direction, directing the Respondent Nos 1 to
7 to file bi-annual reports with affidavits before this Hon’ble
Court regarding the status of the implementation by them;
e) To issue appropriate directions to the Insurance
Regulatory and Development Authority, the Respondent
No. 7 to suitably modify the rules and regulations of
compensation and disbursement of funds so that the
accident victim is not left wanting of appropriate medical
care on an emergency basis;
f) To issue a writ of mandamus or any other appropriate
writ or directions to the Respondent No. 5 so that the
Government becomes liable in all accidents where a
negligence of omission or commission by any of the
Governmental organizations can be pointed as the cause
of the accident;
g) To issue necessary orders to Respondent No.1 to
urgently include biometrics in licensing and enforce stricter
laws to prevent errant drivers;
[2025] 10 S.C.R. 317

S. Rajaseekaran v. Union of India and Ors.

h) To recommend modification of laws so that fatal
accidents due to drunken driving or over-speeding will
attract imprisonment and not merely a fine;
i) To direct the Respondent No.1 to seek amendment of
the Motor Vehicle Act to include accidents where a single
vehicle is involved due to defective road safety measures
on the part of Government;
j) Such further reliefs that this Honorable Court may deem
fit and proper to protect and save the plight of “not at fault
road traffic accident victim”.
2. The case put up by the petitioner in public interest is that he is
extremely anguished and distressed by the loss of life and limb
caused by ever increasing number of road accidents in the country
and utter callous and casual attitude of the States towards such
accidents despite there being various statutory enactments and
plethora of judgments/orders delivered by this Court and various
High Courts across the country. According to the petitioner the
quantum of loss of lives and limbs are akin to that which occur in
major national genocides.
3. This petition was filed way back in the year 2012. According to the
petitioner the United Nations had declared the decade of 2011-2020
as the decade of action on road safety. According to him it is high
time that the Government of India awakens to the magnitude of
the crisis and takes concrete steps which go beyond mere policies,
papers and recommendations on road safety.
4. According to the petitioner 90% (ninety per cent) of the problem is
on account of lack of strict enforcement of the safety rules on roads
and strict punishment for the drivers who do not obey the road rules.
Any traffic violation is a potential accident and every accident is a
potential road accident death.
5. It has been brought to our notice that the Ministry of Road Transport
and Highways [MoRTH] in its December 2011 publication captioned
“Road Accidents in India 2010” has stated as follows:
“Road accidents are a human tragedy. They involve high
human suffering and monetary costs in terms of untimely
deaths, injuries and loss of potential income. Although we
have undertaken many initiatives and are implementing
318 [2025] 10 S.C.R.

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various road safety improvement programmes, the overall
situation as revealed by data is far from satisfactory ...
The Government alone cannot tackle road safety problems.
There is a need for active involvement of all stakes holders
to promote policy reform and implementation of road safety
measures. Addressing road safety in a comprehensive
manner underscores the need to involve multiple agencies/
sectors like health, transport and police. The data and
analysis on road accidents presented in the document
is expected to create awareness and assist in informed
decision making on road safety.”
6. By this order today, we propose to issue directions on five important
aspects in the hope that compliance of said directions would help
in reduction of road accidents and fatalities. These directions relate
to (i) safety of pedestrians while walking on footpaths, (ii) making
pedestrian crossings safe (iii) wearing of helmets (iv) Wrong lane
driving and unsafe overtaking, and (v) Use of dazzling LED white
lights, unauthorized sale and misuse of red-blue strobe lights and
hooters. This Court has taken up these five issues in light of recent
official figures released by the Government of India which show that
(i) more than 35,000 pedestrians were killed in road accidents in the
year 2023, (ii) more than 54,000 riders/ passengers of two wheelers
had died due to non-wearing of helmets. We shall keep monitoring
the compliance of the directions that we propose to issue by way
of this order.

ROAD ACCIDENTS IN INDIA 2023
7. The publication “Road Accidents in India 2023” by the Ministry of
Road Transport and Highways [MoRTH] indicates that there have
been 1,72,890 deaths in road accidents in India in the year 2023,
out of which 35,221 are pedestrian deaths, which is an increase of
7.30% from the year 2022. Thus, 20.40% of deaths on Indian roads
were of pedestrians.
8. The applicant Mr. Kishan Chand Jain in his submissions has pointed
out the alarming increase in pedestrian fatalities as a percentage of
total road accident deaths in India over the past eight years (2016–
2023) which highlights a growing crisis that demands immediate
attention. Pedestrians, being the most vulnerable road users, are
increasingly at risk. The data of the past eight years is as follows:
[2025] 10 S.C.R. 319

S. Rajaseekaran v. Union of India and Ors.

% Share of Pedestrian Killed in Total Road Accident
for the years 2016 to 2023

Year Total number Total number % share of
of Persons of Pedestrian Pedestrian
killed in road Killed in road killed in
accidents accidents total road
accident
2016 1,50,785 15,746 10.44%
2017 1,47,913 20,457 13.83%
2018 1,51,417 22,656 14.96%
2019 1,51,113 25,858 17.11%
2020 1,31,714 23,483 17.83%
2021 1,53,972 29,124 18.9%
2022 1,68,491 32,825 19.5%
2023 1,72,890 35,221 20.4%

9. The Road Accidents in India Report 2023 highlights the dangers
pedestrians face daily from all kinds of vehicles. The breakdown of
pedestrian fatalities by the type of impacting vehicles during 2023
as per Table 4.5 of the 2023 Report is as follows:

SL. Name of Impacting Pedestrians %
NO. Vehicles Killed
1 Bicycles 54 0.15%
2 Two-Wheelers 9951 28.26%
3 Auto Rickshaws 1377 3.91%
4 Cars, Taxis Vans & 8724 24.78%
LMV
5 Trucks/Lorries 5361 15.23%
6 Buses 2124 6.03%
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7 Other Non- 337 0.96%
Motorized Vehicles-
rickshaw etc.
8 Others 7275 20.67%
9 Total 35,203 100%

10. The applicant has also drawn our attention to other key features
relating to pedestrian deaths, as reflected in the 2023 Report, which
are as follows:
“i) A gender-wise comparison of pedestrian fatalities in 2023
reveals that 27,847 males (79.1%) and 7,374 females
(20.9%) lost their lives in road accidents (Annexure 33
of the Report).
ii) Chart 4.11 of the Report highlights that 14,761 males
(41.9%) and 3,222 females (9.1%) were killed in the young
age group of 18–45 years, indicating the severe impact on
the most productive segment of the population.
iii) Annexure 13B of the Report further shows that pedestrian
fatalities on National Highways were significant: 8,805
deaths occurred on NHs under NHAI, 1,986 deaths on
NHs under State PWDs, and 389 deaths on NHs under
other departments, bringing the total number of pedestrian
deaths on National Highways to 11,180.”
11. Therefore, it is of urgent necessity that the authorities ensure that
pedestrians in our country are able to walk safely on our streets
and more importantly are able to cross the roads safely. The deaths
of pedestrians may be attributed to lack of sufficient pedestrian
infrastructure, namely footpaths which force the pedestrians to walk
on the streets, which is unsafe as they run the risk of being hit and/
or run over by vehicles. Furthermore, there is a dire need to ensure
that the pedestrian crossings, whether at traffic intersections or
otherwise on roads, are safe so that pedestrians are not run over
by vehicles while crossing the roads.
12. Footpaths and pedestrian infrastructure are frequently unlawfully
encroached upon and misused, forcing pedestrians onto carriageways
[2025] 10 S.C.R. 321

S. Rajaseekaran v. Union of India and Ors.

and exposing them to grave risks. Sections 201 and 210B of the
Motor Vehicles Act, 1988 [“MV Act”] empower authorities to prohibit
and penalise vehicular use of footpaths, pedestrian zones, illegal
parking, vending, and other forms of encroachment. In practice,
however, footpaths are often converted into carriageways, occupied
by vendors or construction activity, and enforcement is inadequate
and inconsistent.
13. Universal accessibility features are also often missing, excluding
vulnerable users and increasing their exposure to danger. Many
footpaths and crossings lack ramps, tactile pavers, and handrails.
New facilities frequently fail to comply with national accessibility
standards, and poor coordination between implementing agencies
delays retrofitting. As a result, persons with disabilities, senior citizens,
and other vulnerable groups face significant mobility barriers. The
integration of pedestrian infrastructure with public transport nodes
remains similarly deficient. Bus terminals, metro stations, and
railway stations frequently lack safe access and dispersal facilities.
Standards prescribed under IRC:103-2012 and IRC:110-2017 are
not consistently applied, resulting in pedestrian spillover onto busy
carriageways and unsafe walking conditions around major transit
hubs.
14. Pedestrian crossings too suffer from serious deficiencies. Rule 11
of the Road Regulations 1989 gives pedestrians the right of way
at uncontrolled zebra crossings, while Rule 8 requires drivers to
exercise caution and avoid overtaking near crossings. Section 177
of the MV Act provides for penalties, and Sections 279, 337, and
338 of the Indian Penal Code impose criminal liability for rash or
negligent driving causing injury. Yet, in practice, zebra crossings are
often faded or poorly located, signalisation is lacking at busy sites,
public awareness of pedestrian priority remains low, and enforcement
is weak.
15. The amicus has drawn our attention to Annexure 46 of the Report
on Road Accidents in India 2023 which mentions the accident data
in 50 cities having million plus population. An extract of the said data
shows that 4,604 pedestrians were killed in the said 50 cities in the
year 2023. It is also relevant to mention that Format-9 of the same
report collects data regarding location of pedestrian accidents. The
said Format-9 is extracted below:-
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Format-9
Location of pedestrian accidents according to whether at Pedestrian
Infrastructures

Pedestri- Number of accidents Number of persons Com-
an infra- ments
structure if any

Fatal Griev- Minimum Non Total Fatal Griev- Minimum
ous injury injury ous injury
injury (not injury
(not
(need needing (need
needing
hospi- hospitali- hospi-
hospital-
taliza- zation) taliza-
ization)
tion) tion)

1. Zebra
Crossing

2. Foot
bridge/
subway

3. foot-
path

4. Others Provide
(where chainage
there is where
no pe- pedes-
destrian trians
infra- in this
structure) category
are dying

Total

STATUTORY PROVISIONS WHICH HAVE A BEARING ON SAFETY
OF PEDESTRIANS
16. Our attention has been drawn to some of the statutory provisions
under the MV Act which inter alia are as follows:
“138. Power of State Government to make rules.-
…
[2025] 10 S.C.R. 323

S. Rajaseekaran v. Union of India and Ors.

(1A) The State Government may, in the interest of road
safety, make rules for the purposes of regulating the
activities and access of non-mechanically propelled
vehicles and pedestrians to public places and national
highways;
Provided that in the case of national highways, such rules
shall be framed in consultation with the National Highways
Authority of India.”
(2) Without prejudice to the generality of the foregoing
power, such rules may provide for:
…
(h) prohibiting the use of foot-paths or pavements by
motor vehicles;
(i) generally, the prevention of danger, injury or annoyance
to the public or any person, or of danger or injury to property
or of obstruction to traffic; and
(j) any other matter which is to be, or may be, prescribed.

198-A Failure to comply with standards for road design,
construction and maintenance.–
(1) Any designated authority, contractor, consultant
or concessionaire responsible for the design or
construction or maintenance of the safety standards
of the road shall follow such design, construction and
maintenance standards, as may be prescribed by the
Central Government from time to time.
(2) Where failure on the part of the designated authority,
contractor, consultant or concessionaire responsible
under sub-section (1) to comply with standards for
road design, construction and maintenance, results
in death or disability, such authority or contractor or
concessionaire shall be punishable with a fine which
may extend to one lakh rupees and the same shall
be paid to the Fund constituted under section 164B.
(3) …………..”
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210-C Power of Central Government to make rules.
The Central Government may make rules for-
(a) design, construction and maintenance standards for
National highways;
(b) such other factors as may be taken into account by
the Court under sub-section (3) of section 198-A;
(c) any other matter which is, or has to be, prescribed
by the Central Government.”

210-D Power of State Government to make rules.
The State Government may make rules for design,
construction and maintenance standards for roads other
than national highways, and for any other matter which is,
or may be, prescribed by the State Government.”
17. The Central Government in exercise of its powers under Section 210-C
of the MV Act, has framed the Central Motor Vehicles (Eleventh
Amendment) Rules, 2020 vide the Notification dated 25.09.2020
issued by the Ministry of Road Transport & Highways, Government
of India (MoRTH), which came in force w.e.f. 01.10.2020. Rule 166
reads thus:
“166. Road Design, Construction and Maintenance
Standards.-
(1) The design, construction and maintenance of national
highways shall be in accordance with the standards
and specifications of the Indian Road Congress
as may be applicable, or any other instructions or
guidelines issued by the Central Government from
time to time.
(2) The design, construction and maintenance of roads
other than national highways shall be in accordance
with the standards and specifications of the Indian
Road Congress as may be applicable, or any
other instructions or guidelines issued by the State
Government from time to time.;
[2025] 10 S.C.R. 325

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(3) Subject to the previous approval of the Central
Government or State Government, as the case
may be, deviations from applicable standards,
specifications, instructions and guidelines issued
under sub-rule (1) or (2), may be made due to local
conditions including but not limited to site constraints
or built-up area or land acquisition, and a copy of
the said approval shall be annexed as part of the
relevant contract.
(4) The contract shall clearly define the terms designated
authority, consultant and concessionaire.”

GUIDELINES FOR PEDESTRIAN SAFETY [SECOND REVISION]
JUNE, 2022 PUBLISHED BY INDIAN ROADS CONGRESS (IRC
103-2022)
18. Pursuant to the directions passed by this Court, the Government of
India has filed an affidavit dated 27.08.2025 stating that comprehensive
guidelines have been framed by the Indian Roads Congress [IRC], a
technical body under the aegis of the MoRTH, called Guidelines for
Pedestrian Safety [Second Revision] June, 2022 IRC 103-2022.
These Guidelines provide detailed specifications/ standards for the
design and construction of pedestrian facilities, including footpaths
that are accessible by all, including Persons with Disabilities. The
said Guidelines also prescribe the standards required for safe
pedestrian crossings.
19. By virtue of Rule 166 of the Rules, the above Guidelines are binding
in so far as National Highways are concerned and perhaps on States,
unless specified to the contrary. Though the Guidelines are very
detailed, some of the salient features of the said Guidelines, which
deal with footpaths, are as follows:-
a) Minimum width of footpaths in different zones, viz. Residential,
Neighborhood level commercial street, City level commercial
street and High street shopping level. The relevant part of the
said Guidelines is extracted herein below [pg.8 of Guidelines]:-
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Table 2 Minimum Clear Widths of different Zones on
Footpaths as per adjoining Landuse:

Adjoining a)Minimum b)Minimum c) Minimum Minimum
landuse walking/ dead/ multi-utility total
pedestrian frontage zone width footpath
zone width (mtrs) width (mtrs)
Zone width
(mtrs) (a+b+c)
(mtrs)
Residential 2.0 0.5 1.5 4.0 (for a
(Fig.8) 15m wide
street
with 6m
undivided
carriageway)
Neighbour- 2.5 1.0 1.5 5.0 (for a
hood level 18m wide
commercial street
street, with 7m
(Fig.9) undivided
carriageway)
City-level 4.0 1.0 1.5
6.5 (for a
commercial
21m wide
street,
street
high-street
with 7m
shopping
undivided
street
carriageway)
(Fig.10)

b) The Guidelines also provide as follows [pg.9 of Guidelines]:-
“Walking zone of minimum 2.5m should be considered
for streets with schools, hospitals, markets, bus
stops, public parks and gardens (recreation) at the
neighborhood level.”
c) Height: [pg.10 of Guidelines]- The height of the footpath should
be 150mm above the adjoining finished carriageway level to
ensure comfortable access to all pedestrians, especially the
elderly and children, and prevent illegal parking by not allowing
vehicles to mount over the footpath.
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d) Surface: Footpath surface should be even, firm, free from
cracks and well-drained. Surface should be of anti-skid material
to ensure usability and safety in all-weather conditions. Vitrified
tiles should be used for tactile pavers as they have high load
bearing capacity and are durable. Footpath surface should have
gradient (slope) to prevent accumulation of water.
e) For Persons with Disability, Clause 6.5 of the Guidelines
provide as follows:-
“6.5 Tactile Pavers:
Visually impaired pedestrians need guidance
while walking to find their way, overcome
obstacles, and cross safely. Two types of tactile
tiles are used- guiding and warning tiles as
shown in Figs.29 and 30. Detail specification
of tile design can be referred in IRC:SP:117.
Guiding tiles have straight continuous lines
that indicate the route. They are helpful in large
areas such as transport terminals, public spaces
and wide footpaths (more than 4m) for easy
navigation, as the usual guidance given by the
edge of the footpath or compound wall is not
within the reach of stick used by visually impaired
to navigate. Only warning tiles are recommended
on footpaths with width less than 4m. Warning
tiles helps to warn against level difference
and obstacles, and further informs on how to
navigate. It should be placed at the beginning
and end of the ramps and stairs. Warning tiles
should be provided at property entrances,
intersections and pedestrian crossings. Two sets
of pedestrian warning tiles should be provided
so that the pedestrian does not miss it.”
f) At this stage, it may also be relevant to mention that the Ministry
of Housing and Urban Affairs have issued the Harmonised
Guidelines and Space Standards for Barrier Free Built
Environment for Persons with Disability and Elderly Persons
in 2021. Section 3.7 provides detailed guidelines for use of
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kerb ramps on pathways and sideways for convenience of
persons with disabilities, wheelchair users and elderly persons;
Section 3.8 provides for specific guidelines to create safe and
accessible pedestrian crossings for mobility for all, including
wheelchair users, baby prams and people with luggage trolleys,
etc. Section 39 provides for Tactile Guiding Surface Indicators to
provide warning and guidance to people with visual difficulties.
g) Use of Bollards: To prevent illegal parking of vehicles on the
footpaths, the Guidelines recommend use of bollards. Bollards
should be provided at locations on footpath where illegal vehicle
encroachment is possible, such as around property entrance
access ramps, raised pedestrian crossings or kerb edge of
footpath. Bollards should be 0.5-0.7m high with a clear spacing
of 0.6m between them and one with 1m clear width to ensure
movement of wheelchair users, caregivers with pram and
persons with luggage.
20. The IRC Guidelines also deal with pedestrian crossings. Pedestrians
of all age groups and abilities should be able to cross the streets
safely and conveniently. Pedestrians mostly cross at mid-block and
at intersections. Frequent opportunities for at grade crossings should
be available on urban streets. Crossings that are located far apart
increases the walking distance which leads pedestrians to cross
randomly. Similarly, if the waiting time to cross increases, pedestrians
tend to become impatient and cross in an unsafe condition, subjecting
themselves to the risk of road crash. [Pg.22 of the Guidelines]
21. Pedestrian crossings are of two kinds: at grade and grade-separated.
‘At grade pedestrian crossings’1 provide crossing at the street level,
whereas grade separated infrastructure provide crossing above or

1 “6.7.1 At-Grade Pedestrian Crossings [at pg.23 of Guidelines]- At grade pedestrian crossings are mainly
of two kinds- tabletop/ raised crossing and painted zebra crossing. Tabletop or raised crossings are
recommended at all unsignalized crossings as it provides comfortable and safe crossing to all road
users including persons on wheelchair, elderly and caregivers with pram. It allows pedestrians to cross
at the same level as the footpath. It also acts as a traffic claiming measure that ensures road safety to
both pedestrians and motorists. Crossing is raised at the same level as the adjacent footpath finished
level. Ramps of 1:8 slope is provided for vehicle access. Crossing should be minimum 2m wide. Bollards
should be provided at both ends of the crossing and at median to prevent vehicles from (especially two-
wheelers) taking U-turns and entering the footpath. Atleast one bollard spacing should ensure access to
wheelchair users. It is recommended to provide traffic calming measure (speed hump) 10-20m before
the crossing. This will help to slow down the vehicle in advance and ensure pedestrian safety. Tactile
pavers should be provided to guide visually impaired persons. Provision for storm water drainage before
the ramp should be provided. Asphalt concrete may be used for the table top surface.”
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below the street level. Foot over bridges and subways are grade
separated pedestrian crossings. ‘At grade’ pedestrian crossings are
recommended over grade separated ones, as they provide quick,
short and comfortable crossing. 4m wide crossings are recommended
in streets with high pedestrian volumes such as schools, transit
stations, shopping complex etc. Pedestrian crossings should be
clearly visible to all road users by appropriate markings.
22. Accidents frequently occur in school zones and other vulnerable
corridors with high numbers of children and elderly pedestrians.
Although IRC Guidelines Part 11 prescribe measures such as raised
crossings, zebra markings, and traffic calming, these are often
not implemented. Vulnerable corridors are also not systematically
identified using accident data, which leads to weak prioritisation of
safety interventions and exposes pedestrians to unnecessary risks.
23. Annexure-2 of the IRC Guidelines lays down the nomographs for
planning pedestrian crossings which gives a scientific manner in
which pedestrian crossing can be planned, depending upon the
pedestrian volume. The IRC Guidelines also lay down standards
for signalized crossings for pedestrians and traffic signals with
pedestrians’ phases. Part 7 of the IRC Guidelines deal with pedestrian
facilities at intersections, Part 11 deals with pedestrian facilities
around school zones; and Part 12 deals with pedestrian facilities
around transit stations.

PROPER AND WELL-MAINTAINED FOOTPATH(S) IS A
JUDICIALLY RECOGNIZED RIGHT
24. This Court has recognized that safe and encroachment free footpaths
are very vital for movement of pedestrians. Therefore, NHAI, State
Governments and Municipal authorities have a duty to ensure that
footpaths are built in a proper manner and pedestrians are provided
safe opportunities to cross the streets. Some of the judgments of
this Court which deal with the rights of pedestrians, inter alia are:-
(i) In Olga Tellis v. Bombay Municipal Corporation, reported in
(1985) 3 SCC 545, this Court was dealing with a case of removal
of encroachments from footpaths. This Court observed that:
“57. To summarise, we hold that no person has the
right to encroach, by erecting a structure or otherwise,
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on footpaths, pavements or any other place reserved
or earmarked for a public purpose like, for example,
a garden or a playground; ……..”
(ii) In Ahmedabad Municipal Corporation v. Nawab Khan Gulab
Khan, reported in (1997) 11 SCC 121, this Court observed as
under:
“8. …..Footpath, street or pavement are public
property which are intended to serve the convenience
of the general public. They are not laid for private use
and indeed, their use for a private purpose frustrates
the very object for which they are carved out from
portions of public roads. The main reason for laying
out pavements is to ensure that the pedestrians are
able to go about their daily affairs with a reasonable
measure of safety and security. That facility, which
has matured into a right of the pedestrians, cannot
be set at naught by allowing encroachments to be
made on the pavements. The claim of the pavement-
dwellers to construct huts on the pavement or road
is a permanent obstruction to free passage of traffic
and pedestrians’ safety and security. Therefore, it
would be impermissible to permit or to make use of
the pavement for private purpose. They should allow
passing and repassing by the pedestrians. No one
has a right to make use of a public property for their
private purpose without the requisite authorisation
from the competent authority. It would, therefore, be
but the duty of the competent authority to remove
encroachments on the pavement or footpath of the
public street obstructing free flow of traffic or passing
or repassing by the pedestrians.”
(iii) In Sudhir Madan v. Municipal Corporation of Delhi, reported
in (2009) 17 SCC 332, this Court observed as under:
“3. We have also to keep in mind the principle that the
right to use the pathway, footpath, etc. is that of the
citizens. No hawker can claim a right to defeat the rights
of other citizens. The hawkers are large in number,
but the population of citizens is many times more than
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that of hawkers and, therefore, the fundamental rights
of the citizens cannot be put in jeopardy by permitting
hawkers and squatters to block roads, footpaths, public
parks, etc. etc. The authority, which frames a scheme,
has to keep this paramount consideration in mind.
Consistent with the rights of citizens, if it is possible
to provide any space to hawkers, squatters, etc. that
may be done consistent with the policy to be framed
by the authority concerned.

xxx xxx xxx
5. We do not wish to give the authorities an impression
that the streets, lanes, footpaths and the parks exist
only for hawkers. The reality is that they exist for
the benefit of the ordinary people living in those
localities…..

xxx xxx xxx

9. While we undertake this exercise, we direct the
authorities to see to it that those persons, who are
carrying on hawking activities or who are squatting
on public land without any authority, even in
accordance with the present day scheme in force,
are removed forthwith. This includes unauthorised
hawking, squatting on public streets, footpaths and
public parks, including playgrounds. We direct the
Delhi Administration to take steps immediately in
collaboration with MCD and NDMC with necessary
assistance from Delhi Police to clear the roads,
streets, footpaths, parks, etc. by unauthorised
occupants/squatters/hawkers. We expect that in the
next two weeks steps will be taken by the authorities
concerned to remove the unauthorised hawkers,
squatters, occupants from the public roads, streets,
footpaths, parks, etc. Let a compliance report be
submitted to this Court within four weeks from today.”

(iv) In MC Mehta v. Union of India, reported in (2019) 10 SCC
614, it was held as follows:
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“19…….. Parking on footpaths is strictly prohibited.
There can be no violation of this and it cannot be
permitted under any circumstances. Footpaths are
meant for pedestrians. Many houses encroach
footpaths for many reasons such as extending the
garden, making security guard cabins, etc. All these
are encroachments of public space. We direct that all
security guard cabins should be built within the plot
area and not on the footpaths. In any colony where
the footpath is found to be encroached upon, strict
action should be taken against the owner and the
encroachment should be removed from the footpath.
In case such house owners after removal of the
encroachment again encroach upon the footpath
then rules may be framed to discontinue municipal
services like water, electricity, sewage, etc. to the
residence of the encroachers.”

IMPLEMENTATION OF THE IRC GUIDELINES
25. In light of the above statutory provisions and judicial decisions, the
applicant and the amicus have submitted before us that there is an
urgent need to implement the IRC Guidelines, to the extent possible,
to ensure safety of pedestrians. The IRC Guidelines, if implemented
in letter and spirit, would reduce chances of pedestrian accidents.
However, the implementation of the above Guidelines is a big
challenge. Considering the space and other planning constraints,
perhaps it may not be possible that all the above Guidelines can be
implemented at all the places, but a sincere effort should be made
to bring all footpaths and pedestrian crossings in conformity with the
above Guidelines, especially at places where there is heavy footfall
like markets, hospitals, transit stations, schools and also high-risk/
vulnerable places where there is documented history of road accidents
resulting in deaths/injuries to pedestrians.
26. Since the data regarding death and/or injuries to pedestrians
are already available with the authorities, namely the Municipal
authorities, State Governments and NHAI, they are broadly aware
of the vulnerable spots where deaths/injuries have been caused to
pedestrians in the last 2-3 years. This data can be the beginning
point for taking remedial steps in the attempt to reduce injuries and
[2025] 10 S.C.R. 333

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death of pedestrians on roads.
27. After considering the submissions made by the applicant, Mr. Kishan
Chand Jain, Mr. Vikramjit Banerjee, Ld. ASG and the amicus, we have,
at the end of this Order, issued certain directions for implementation
of the statutory provisions and IRC Guidelines. We have issued
these directions as an interim measure and we would expect that
the authorities would take serious efforts to implement the Guidelines
laid down by the Central Government itself.

REQUIREMENT OF WEARING HELMETS
28. The amicus in his report has also drawn the attention of this Court
to the relevant parts of the report ‘Road Accidents in India 2023’,
which shows that around 45% [77,455] were drivers or passengers
of two wheelers and 70% of this number [54,568] were deaths due
to not wearing helmets. These deaths could have been avoided, if
not all, then a majority of them. It is difficult to understand the non-
implementation of the rules relating to wearing helmets. The relevant
provisions of the MV Act are as follows:-
“128. Safety measures for drivers and pillion riders.-
(1) No driver of a two-wheeled motorcycle shall carry
more than one person in addition to himself on the
motorcycle and no such person shall be carried
otherwise than sitting on a proper seat security
fixed to the motorcycle behind the driver’s seat with
appropriate safety measures.
(2) In addition to the safety measures mentioned in
sub-section (1), the Central Government may,
prescribe other safety measures for the drivers of
two-wheeled motorcycles and pillion riders thereon.

129. Wearing of protective headgear.-
Every person, above four years of age, driving or riding or
being carried on a motorcycle of any class or description
shall, while in a public place, wear protective headgear
conforming to such standards as may be prescribed by
the Central Government:
Provided that the provisions of this section shall not apply
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to a person who is a Sikh, if, while driving or riding on
the motorcycle, in a public place, he is wearing a turban:
Provided further that the Central Government may by rules
provide for measures for the safety of children below four
years of age riding or being carried on a motorcycle.

xxx xxx xxx

194-D Penalty for not wearing protective headgear.-
Whoever drivers a motor cycle or causes or allows a motor
cycle to be driven in contravention of the provisions of
section 129 or the rules or regulations made thereunder
shall be punishable with a fine of one thousand rupees
and he shall be disqualified for holding licence for a period
of three months.”
29. In light of the above, we have issued directions regarding wearing
of helmets at the end of this Order.

Wrong-Lane Driving, Unsafe Overtaking, and Lane Discipline
30. Wrong-lane driving and unsafe overtaking remain rampant, especially
near intersections and pedestrian crossings, despite penal provisions
under Sections 184 and 206 of the MV Act. Such violations create
unpredictable vehicle movements, reducing reaction time for both
drivers and pedestrians, and directly increase the risk of collisions,
particularly for those attempting to cross roads at grade. Pedestrians
are exposed to sudden vehicular approaches, often without warning,
which can result in serious injuries or fatalities.
31. Lane discipline violations are widespread. Rule 5 of the Road
Regulations 1989 requires vehicles to keep left, overtake from the
right, and mandates specific lane usage for slow and heavy vehicles.
Sections 184 and 206 of the MV Act penalise lane indiscipline and
dangerous driving. Common violations, such as wrong-lane driving,
weaving without indication, misuse of bus and cycle lanes, and
blocking crossings, create chaotic traffic patterns. These unpredictable
movements make it difficult for pedestrians to judge safe gaps,
especially children, the elderly, and persons with disabilities, thereby
substantially increasing the likelihood of mid-block accidents.
[2025] 10 S.C.R. 335

S. Rajaseekaran v. Union of India and Ors.

32. Pedestrian safety is intrinsically linked to broader policy goals,
including accident prevention, inclusive mobility, walkability, and
environmental objectives. The systematic failure of lane discipline
compromises the predictability of vehicle flows, undermining
safe pedestrian crossings and increasing exposure to high-risk
interactions. Effective reform requires convergence of Engineering
(infrastructure), Education (awareness), and Enforcement (law) —
the “3E Framework” — to achieve systematic and sustained safety
outcomes, ensuring that pedestrian movements are anticipated,
protected, and prioritized.

Hazards from Dazzling LED Headlights, Red–Blue Strobe Lights,
and Unauthorised Emergency Hooters
33. This Court notes with particular concern the widespread use of
dazzling white LED headlights, unauthorised red–blue strobe lights,
and hooters that mimic emergency sirens. High-intensity headlights,
including those fitted in two-wheelers, cause temporary visual
disorientation and glare for oncoming drivers, as well as pedestrians.
Pedestrians face momentary loss of spatial awareness, increasing
the risk of being hit or tripping into roadside drains, pits, or other
hazards. Drivers experience reduced reaction time, difficulty judging
distances, and impaired lane discipline, particularly on narrow streets
and highways, which heightens the likelihood of collisions.
34. Red–blue strobes, intended exclusively for authorised emergency
vehicles, are increasingly misused by private vehicles and are freely
available in the market. Similarly, hooters that imitate emergency
sirens are illegally installed on private vehicles. Such misuse
creates a false sense of authority, intimidation, and panic among
pedestrians and other road users. Drivers may react abruptly, slow
down unnecessarily, or make erratic manoeuvres, creating traffic
disruptions and raising accident risk. Pedestrians may freeze, retreat,
or take unsafe evasive actions, increasing their exposure to injury.
The unauthorised use of these lights and siren-like hooters also
undermines respect for genuine emergency services, diluting the
authority and effectiveness of legitimate responders during critical
situations.
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DIRECTIONS
35. Directions in relation to safety of pedestrians, i.e., pavements
and pedestrian crossings
35.1 Footpaths: The road owning agencies in 50 cities [as mentioned
in Annexure 46 of the Report on Road Accidents, 2023] and the
NHAI are hereby directed to start audit of existing footpaths.
They shall begin with those stretches which are more crowded
like markets, railway stations, bus stands, religious institutions,
educational institutions, etc., where there is a heavy footfall of
pedestrians. While doing the audit, the authorities shall also
prioritize those areas, at least 15-20 such spots, where there
have been pedestrian injuries/ deaths as per Format-9 in the
last 2-3 years. The said audit inter alia ought to identify the
deficiencies in the existing footpaths, including the width,
height, surface of the said footpaths, decide the remedial
measures, including repair and road engineering improvement
of the facilities, and fix a timeline for addressing the deficiencies.
35.2 The existing pedestrian crossings must be carefully audited
to ensure that they are compliant with the IRC Guidelines
to the extent possible. The audit may begin with crowded
intersections and thereafter other pedestrian crossings can be
taken up. The deficiencies and the shortcomings in the said
pedestrian crossings should be identified and remedial time
bound measures be undertaken.
35.3 Authorities shall undertake a structured assessment of
footpath and pedestrian zone encroachments, identifying
chronic hotspots. They may consider the phased deployment
of automated, camera-based monitoring systems, the use of
physical deterrents such as bollards and guardrails, and regular
clearance drives supported by GIS mapping and photographic
records, to ensure continuous protection of pedestrian spaces.
35.4 There are a number of places where the existing pedestrian
crossings by way of foot over bridge or under passes are not
being used for the reason that they are not being well maintained
or they are unsafe. It is also seen that at number of places,
pedestrians cross the streets, despite underpasses or foot over
bridge, because there are no barriers at the median to prevent
the pedestrians from crossing the street. This Court notes that
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pedestrian subways and foot overbridges (FOBs) are often
unsafe, poorly maintained, or inaccessible. Inadequate lighting,
absence of CCTV surveillance, lack of panic alert systems, and
failure to comply with the MOHUA Harmonised Guidelines (2021)
and IRC:103-2012 contribute to both the perception and reality
of insecurity for users, particularly women, children, and elderly
persons. This situation has fostered behavioral inertia, with
many pedestrians choosing to cross at grade even where such
facilities exist, highlighting the urgent need for a combination
of design improvements, public awareness initiatives, and
enforcement measures to ensure better utilization and safer
pedestrian movement. Therefore, we direct that audit of existing
pedestrian crossings should additionally focus on:
i) Requirement of traffic calming measures as per IRC:35-
2015 and IRC:67-2012.
ii) Signage to indicate the existence of pedestrian crossing,
with high-visibility zebra markings which may be
supplemented with reflective materials.
iii) Illumination of pedestrian crossings during night-time.
iv) Road dividers should be placed in a manner to prevent
pedestrians from crossing the road at any other place.
v) The condition and safety of pedestrian subways and
FOBs, with upgradation measures including improved
LED lighting, CCTV surveillance linked to command
centres, clearly demarcated entry and exit points, panic
buttons connected to local police stations, and enforceable
operation and maintenance standards through contracts.
35.5 Authorities shall review existing pedestrian infrastructure
for compliance with MOHUA and IRC standards, prioritising
high-footfall and accident-prone areas for retrofitting. The
establishment of dedicated Accessibility and Pedestrian Cells
may be considered to coordinate implementation, monitoring,
and grievance redress mechanisms. In school zones and
other vulnerable corridors, authorities shall systematically
identify high-risk stretches using accident data, and implement
context-specific measures such as raised crossings, zebra
markings, traffic calming features, and deployment of trained
crossing guards.
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35.6 The amicus has also submitted that there is a need to assess
the requirement of further pedestrian crossings, especially
where there is high pedestrian volume crossing the streets.
One can give example of the road crossing at the Delhi High
Court and the National Zoological Garden on Mathura Road
where every day thousands of employees/ litigants/ lawyers/
children/ families cross the road, without any red light or foot
over bridge or any traffic calming measure, putting their lives
at risk. We, therefore, direct the road owning agencies in the
50 cities mentioned in Annexure 46 of the Report on Road
Accidents, 2023 and the NHAI to draw up an action plan and
start phase-wise survey to assess the requirement of additional
pedestrian crossing facilities. The NHAI/road owning agencies
can begin with crowded streets and where there is recorded
data on accidents. We would expect that over the next 1 year,
at least 20 percent of the roads in the above cities can be taken
up for survey and wherever required, pedestrian crossings can
be created. Similarly, NHAI can also take up those portions
of National Highways which pass through cities and villages
where they may be a need for more pedestrian crossings.
We direct that first priority be given to the road crossing at
the Delhi High Court and the National Zoological Garden on
the Mathura Road. Let the needful be done at the earliest
and the work be completed within seven months from today.
35.7 The amicus has provided us with a guide-book by SaveLife
Foundation, namely, “Guide to Redesign High Fatality
Zones” for road owning agencies to undertake standardized,
low-cost solutions for the most dangerous pedestrian conflict
points, particularly focusing on assessment of public spaces,
development of intersection safety measures and management
of median gaps, where warranted by traffic and pedestrian
volumes. An addendum to the said guidebook is the “Guide
for the Implementation of Intersection Design Standards for
Pedestrian Safety” that collates various IRC guidelines and
provides both short-term and long-term solutions for recurring
safety issues. This can also be referred to by the authorities
if they so deem fit.
35.8 Authorities shall examine pedestrian infrastructure at public
transport nodes, including bus terminals, metro and railway
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stations, for conformity with IRC standards. Interventions
such as shaded holding areas, tactile paving, and conflict-
point redesign may be considered, supported by joint audits
between transport and municipal agencies.
35.9 With respect to pedestrian crossings, authorities may assess
busy intersections for the feasibility of installing signalised
crossings with pedestrian actuated signals, audible cues, and
improved signage. Awareness campaigns may be conducted
to reinforce pedestrian priority, and integration of pedestrian
rights into driver training and licence renewal may be explored.
35.10 State transport departments, municipal authorities, NHAI, and
traffic police shall strengthen implementation and monitoring
of pedestrian safety measures. Section 198A of the MV Act
shall be invoked to hold officials and contractors personally
liable in cases of pedestrian deaths due to infrastructural
or design failures. Authorities shall reinforce earlier judicial
directions regarding helmet enforcement, pedestrian audits,
legislative gaps, and grievance redressal, ensuring continuity,
compliance, and accountability. Pedestrian safety reviews
should be systematically incorporated into existing road
safety monitoring frameworks to identify lapses and enforce
timely remedial action.
35.11 It is very important that a simple and effective grievance
redressal mechanism is put in place by the landowning
agencies i.e. PWD Department, Municipal Authorities and
NHAI so that complaints pertaining to lack of maintenance
of footpaths and the requirement of a pedestrian crossing,
are addressed. State Governments/Municipal Authorities/
NHAI are directed to create an online grievance redressal
mechanism regarding footpaths which would include
complaints of encroachments on footpaths, maintenance of
footpaths and also suggestions for pedestrian crossing. The
concerned authority should respond to complaints within a
specified time frame and ensure that the issue is resolved in
a time-bound manner. The grievance redressal system must
incorporate a review mechanism by higher authorities, to be
invoked in cases where the complainant is not satisfied with
the resolution provided.
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35.12 The District Road Safety Committees (DRSCs), constituted
under Section 215(3) of the MV Act play a crucial role in
the implementation and monitoring of road safety measures
at the district level. Given the rising number of pedestrian
deaths in both urban and rural areas, these committees
should mandatorily address pedestrian safety issues in their
monthly meetings.

Directions relating to wearing of helmets
35.13 We direct all the State Governments, UTs and the NHAI to
strictly implement the provisions of law relating to wearing
helmets by two-wheeler drivers and passengers using two
wheelers. Strict enforcement of these rules should be ensured
inter alia through e-enforcement mechanism i.e. cameras
installed at various places. The mechanism available for
enforcement of the aforesaid violation shall be brought to
the notice of this Court. The number of persons penalized
and the amounts recovered by challans and the licenses
suspended shall also be informed to this Court.

Direction on Unlawful and Wrongful Lane Driving:
35.14 State transport departments, traffic police authorities, and
urban local bodies shall take measures to enforce lane
discipline by addressing unlawful or wrong-lane driving,
including the use of automated cameras, graduated fines,
coloured and textured lane markings (e.g., for bus and cycle
lanes), dynamic lighting, rumble strips, and tyre killers at
critical conflict points. The development and publication of
real-time dashboards on lane violations may also be explored
to build public awareness, enhance compliance, and improve
overall road safety.

Directions on White LED Dazzling Lights, Red–Blue
Strobe Lights, and Unauthorized Hooters:
35.15 The Ministry of Road Transport & Highways (MoRTH), State
Transport Departments, and traffic police authorities shall
prescribe maximum permissible luminance and beam angles
for vehicle headlights and ensure compliance through checks
during PUC testing and vehicle fitness certification, while
[2025] 10 S.C.R. 341

S. Rajaseekaran v. Union of India and Ors.

conducting targeted drives to penalize non-compliant or modified
headlights. A complete ban on unauthorized red–blue strobe
flashing lights and illegal hooters shall be enforced through
seizure, market crackdowns, and penalties. Simultaneously,
nationwide public awareness campaigns by MoRTH, state
transport departments, and traffic police shall be conducted
to sensitize drivers and pedestrians about the hazards posed
by dazzling headlights, unauthorized strobe lights, and illegal
hooters, thereby enhancing overall road safety.

Regarding Framing of rules by the State Governments:
35.16 We direct all the States and UTs to formulate and notify Rules
under Section 138(1A) of the MV Act within a period of six
months, if not already framed, for the purposes of regulating the
activities and access of non-mechanically propelled vehicles
and pedestrians to public places and national highways.
35.17 We direct all the States and UTs to formulate and notify
Rules under Section 210-D of the MV Act within a period
of six months, if not already framed, for design, construction
and maintenance of standards for roads other than national
highways.
36. Lastly, this Court expresses its deep sense of gratitude towards the
learned amicus, Mr. Gaurav Agrawal for his valuable assistance,
contribution and efforts. Mr. Gaurav Agrawal was appointed as amicus
way back in the year 2015 and has assisted this Court all throughout
for a period of almost more than ten years on a very important and
sensitive issue. We place on record our appreciation for the yeoman
services rendered by the learned amicus, Mr. Gaurav Agrawal.
37. The Registry shall list this matter once again after a period of seven
months to report compliance of our directions and further progress
in the matter.

Result of the case: Directions issued.

†
Headnotes prepared by: Nidhi Jain