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Supreme Court of India9 April 20262026 INSC 341

Malkit Singh v. State of U.T. Chandigarh

Bench of 2 · Justice Sanjay Karol, Justice Nongmeikapam Kotiswar Singh

Why it matters

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Advocates acting for municipal bodies or residents' associations in encroachment-removal matters must now demonstrate not merely that illegal vendors were evicted but that the State took affirmative steps — vending zone allocation, information dissemination, and customer-awareness drives — to support displaced vendors; failure to show this transition-support will expose enforcement drives to challenge as punitive and violative of Articles 19(1)(g) and 21.

Summary

The appellant, President of the Manimajara Vyaapar Mandal, Chandigarh, filed a writ petition before the Punjab & Haryana High Court seeking removal of encroachments on public paths, roads and public property by fruit vendors, rehri vendors, hawkers, squatters and other vendors, alleging nuisance and traffic hazards. The High Court dismissed the petition and imposed costs of Rs. 50,000 each on the associations represented by the appellant. The appellant challenged that order before the Supreme Court in Civil Appeal No. 4400 of 2026.

The Supreme Court, after granting leave and staying the impugned judgment, directed the Commissioner, Municipal Corporation, Chandigarh to file a personal affidavit. The affidavit disclosed that 1,024 challans had been issued between 1st August and 30th November 2025, all illegal street vendors had been removed, and only licensed vendors in the category of essential service providers or mobile vendors had been permitted to continue. The Court found these efforts appreciable but directed the State to file a further affidavit within two weeks, clarifying: (i) information available at designated vending zones; (ii) steps taken to actively support displaced vendors in transitioning to those zones; and (iii) awareness drives to redirect customers to designated areas. The matter was listed for 27th April 2026.

The Court laid down that the constitutional approach to competing rights between street vendors and residents is regulation, not blanket eviction. Clearly identified vending zones, transparent licensing, and regular consultations with vendor groups and resident welfare associations are the prescribed processes. Heavy-handed crackdowns, removal without warning, or use of heavy machinery to demolish semi-permanent structures offend the dignity guarantee under Article 21. The Court further held that once vendors are displaced through lawful encroachment drives and vending zones exist, the State bears an affirmative duty to support their transition — including public awareness drives to redirect their customer base — and that failure to do so renders the exercise punitive rather than regulatory. The Court referred to, without overruling, Olga Tellis v. Bombay Municipal Corpn., Sodan Singh v. New Delhi Municipal Committee, Ahmedabad Municipal Corpn. v. Nawab Khan Gulab Khan, Sudhir Madan v. MCD, Gainda Ram v. MCD, and Maharashtra Ekta Hawkers Union v. Municipal Corpn., Greater Mumbai.

Key principle

Street vending is protected under Article 19(1)(g) and the constitutional method of resolving competing rights between vendors and residents is regulation through designated vending zones and transparent licensing — not indiscriminate eviction; once vendors are displaced through lawful encroachment drives, the State bears an affirmative duty to actively support their relocation to designated vending zones, including through public awareness drives, failing which the exercise becomes punitive and offensive to Article 21.

Holding

Disposed of with directions — the Supreme Court set aside the High Court's dismissal, directed the Municipal Corporation, Chandigarh to file an affidavit detailing steps taken to regularise displaced vendors in designated vending zones and to conduct awareness drives redirecting customers, holding that the State's duty does not end with removal of encroachments but extends to actively facilitating the transition of displaced vendors to lawful vending zones.

Statutes invoked

  • Constitution · Article 19(1)(g)
  • Constitution · Article 19(6)
  • Constitution · Article 21
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 2(d)
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 2(l)
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 2(n)
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 12
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 21
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 27
  • Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 · 33

Practice areas

constitutionalwritcivil
AI-generated summary, written by Claude Sonnet 4.6 from the court's published judgment. Always verify the original before relying on the summary in court. Generated on 21 May 2026.