S. Rajaseekaran v. Union of India, 2025 INSC 1189 - Road Safety- Helmet Rule

Road Safety - 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. Directions issued - 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. - 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- 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- 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 -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.

Case Info

  • Case name: S. Rajaseekaran v. Union of India and Ors.
  • Neutral citation: 2025 INSC 1189
  • Coram: J.B. Pardiwala; K.V. Viswanathan, JJ.
  • Judgment date: 7 October 2025
  • Jurisdiction: Supreme Court of India, Civil Original Jurisdiction, Writ Petition (C) No. 295 of 2012

Caselaws and Citations

  • Olga Tellis v. Bombay Municipal Corporation: (1985) 3 SCC 545.
  • Ahmedabad Municipal Corporation v. Nawab Khan Gulab Khan: (1997) 11 SCC 121.
  • Sudhir Madan v. Municipal Corporation of Delhi: (2009) 17 SCC 332.
  • MC Mehta v. Union of India: (2019) 10 SCC 614.

Statutes/Laws Referred

  • Motor Vehicles Act, 1988: Sections 128, 129, 138(1A), 177, 184, 194-D, 198-A, 210-B, 210-C, 210-D, 215(3).
  • Road Regulations, 1989: Rule 5, Rule 8, Rule 11.
  • Indian Penal Code: Sections 279, 337, 338.
  • Central Motor Vehicles (Eleventh Amendment) Rules, 2020: Rule 166.
  • Indian Roads Congress Guidelines: IRC:103-2022 (Guidelines for Pedestrian Safety, Second Revision); IRC:35-2015; IRC:67-2012; IRC:110-2017; IRC:SP:117.
  • MOHUA Harmonised Guidelines (2021): Harmonised Guidelines and Space Standards for Barrier Free Built Environment (Sections 3.7, 3.8, 39).
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