13 May 2026 Legal Updates

“No Concept Of Lane Driving In India”: Supreme Court Flags Road Safety Crisis, Orders Strict Compliance With Vehicle Safety Rules

Supreme Court expressed concern over increasing road accidents, stressed the importance of lane discipline, and directed strict implementation of vehicle tracking and safety regulations across India.

Case Details

(a) Case Title:

• S. Rajaseekaran v. Union of India

(b) Court:

• Supreme Court of India

(c) Bench:

• Justice JB Pardiwala and Justice KV Viswanathan

Facts of the Case

The Supreme Court was hearing an ongoing matter relating to road safety and implementation of various transport safety regulations across the country. Over the years, the Court has issued several directions concerning:

• reduction of road accidents,
• safety standards,
• vehicle regulation,
• enforcement of traffic norms.

During the hearing, the Court expressed serious concern over the lack of lane discipline in India and observed that most accidents occur because drivers do not follow proper lane driving practices.

The Court also examined compliance with:

• Rule 125H of the Central Motor Vehicles Rules, 1989,
• speed limiting devices,
• installation of Vehicle Location Tracking Devices (VLTDs),
• constitution of the National Road Safety Board.

The amicus curiae informed the Court that less than 1% of public transport vehicles have installed the mandatory tracking devices and emergency buttons.

The Court treated the situation as alarming and issued several directions to the Union Government and States.

Issues Raised

• Whether the States and Union Territories are properly implementing road safety regulations under the Motor Vehicles framework?
• Whether public service vehicles are complying with mandatory installation of tracking devices and emergency buttons?
• Whether lack of lane discipline contributes significantly to road accidents in India?
• Whether the delay in constituting the National Road Safety Board violates statutory obligations?

Contentions / Concerns Raised Before The Court

The amicus curiae highlighted that:

1. Rule 125H of the Central Motor Vehicles Rules mandates:

• Vehicle Location Tracking Devices (VLTDs),
• emergency panic buttons in public service vehicles.

2. These measures are critical for:

• passenger safety,
• emergency response,
• protection of women, children and elderly persons.

3. Compliance across India is extremely poor.

4. Less than 1% of vehicles currently have such systems installed.

5. Several States have also failed to comply with directions relating to:

• speed limiting devices,
• road safety enforcement,
• constitution of statutory authorities.

Stand Of The Court / Government

The Court noted:

• Poor implementation of safety measures by States and transport authorities.
• Absence of proper lane-driving culture in India.
• Delayed constitution of the National Road Safety Board despite earlier directions.
• Weak enforcement of existing traffic and transport safety laws.

The Court suggested: Automobile manufacturers should pre-install tracking devices in vehicles.

Court’s Reasoning & Key Findings

1. Lack Of Lane Discipline Is A Major Cause Of Accidents

• Justice Pardiwala observed: “There is no concept of lane driving in this country.”
• The Court noted that: lane indiscipline is a major contributor to road accidents in India.
• The Bench emphasized: proper lane driving can significantly reduce accidents.
• The Court urged the Government to: focus more on lane-driving awareness and enforcement.

2. Strict Enforcement Of Rule 125H Necessary

• The Court examined: Rule 125H of the Central Motor Vehicles Rules, 1989.
• This Rule mandates: Vehicle Location Tracking Devices (VLTDs), and emergency panic buttons in public service vehicles.
• The Court observed: compliance is extremely poor.
• Thus: All States and UTs were directed to strictly enforce the Rule.

3. Public Safety Is Paramount

The Court emphasized that:

tracking devices and emergency buttons are essential for:

• passenger protection,
• emergency response,
• women’s safety,
• real-time monitoring.

The Court stressed that technology-based safety systems are now indispensable in modern transport governance.

4. No Fitness Certificate Without Safety Compliance

The Court issued an important direction: No public service vehicle should receive:

• Fitness Certificate under Section 56 MV Act, OR
• Permit under Section 66 MV Act

Unless: Installation of tracking devices is verified.

This makes compliance: mandatory, enforceable, technologically monitored.

5. Integration With Vahan Database

The Court directed: integration of compliance systems with the Vahan portal.

Purpose:

• real-time oversight,
• digital monitoring,
• transparency,
• automated compliance checks.

6. Delay In Constituting National Road Safety Board Criticised

• The Court expressed displeasure that: National Road Safety Board had still not been constituted.
• Despite earlier directions granting six months’ time, no progress had occurred.
• The Court granted: A final opportunity of three months.

7. Courts Can Ensure Enforcement Of Existing Laws

An important principle from the case: Courts may not create policy, BUT they can ensure implementation of existing statutory obligations.

The Court repeatedly stressed:

• the problem is not absence of law,
• but poor enforcement.

Legal Principles Established

1. Right To Safe Transportation Is Linked To Article 21

• Although not expressly discussed, the judgment reflects: Right to Life under Article 21 includes road safety and passenger protection.

2. Courts Can Ensure Enforcement Of Existing Laws

• The Court clarified: the issue is lack of implementation, not absence of law.
• Judiciary can: compel enforcement of statutory obligations.

3. Technology-Based Governance Is Essential

• The judgment strongly supports: digital compliance systems, AI/tech-enabled road safety, real-time monitoring.

4. Public Safety Overrides Administrative Delay

The Court treated:

• poor compliance,
• delay,
• bureaucratic inaction as unacceptable where public safety is concerned.

5. Lane Discipline Is A Key Road Safety Principle

The Court recognized: lane driving as an essential safety mechanism.

This observation may influence:

• future road safety policies,
• enforcement mechanisms,
• traffic regulation reforms.

6. Statutory Compliance Must Be Verifiable

• The Court emphasized: Digital verification through Vahan portal.
• Meaning: compliance should not remain merely paper-based.