The Supreme Court ruled that the safety of passengers on highways is an integral part of the right to life under Article 21 of the Constitution, affirming that the state has a positive obligation to prevent even a single avoidable death caused by hazards such as illegal parking or accident-prone “black spots.”
In a ruling on Saturday, a bench of Justices JK Maheshwari and AS Chandorkar observed that a road, especially a high-speed expressway, “should not become a corridor of danger due to administrative inactivity or infrastructure gaps”. The court added that “losing even one life due to avoidable dangers such as illegal parking or black spots represents a failure in the umbrella of protection provided by the state.”
The ruling came in a suo motu case titled In Re: Phalodi Accident, where the court looked into systemic lapses in highway safety and the recurring nature of fatal road accidents linked to preventable causes following two fatal accidents in November 2025 — in Phalodi district, Rajasthan, and Rangareddy district, Telangana — that claimed 34 lives.
Extending the scope of Article 21, the Court explained that the right to life is not merely a negative guarantee against unlawful deprivation of life, but imposes a positive duty on the State to create conditions in which life is preserved and protected.
The court considered that “recognition of passenger safety is an integral aspect of the right to live in dignity,” stressing that the state must take proactive steps to eliminate risks that expose road users to danger. He stressed that constitutional provision requires more than just reactive measures after incidents occur; It requires proactive action to remove known risks from public infrastructure.
Pointing to frequent accidents caused by unregulated heavy parking lots, poor lighting, lack of signage and untreated accident areas, the council said such failures point to gaps in implementation and planning and not just isolated lapses.
To address these concerns, the court issued a series of nationwide directions aimed at strengthening highway safety mechanisms, with the assistance of amicus curiae and senior advocate Anas Nadkarni and Solicitor General Tushar Mehta.
The court ordered the authorities to identify, review and correct accident-prone “black spots” on a specific time basis, with periodic reporting and monitoring to ensure compliance. The court explained that such sites, where frequent incidents occur, cannot be allowed to continue due to bureaucratic delays or lack of coordination.
The authority also directed strict enforcement against illegal parking on highways, especially heavy and commercial vehicles, noting that vehicles parked on high-speed lanes are a major cause of fatal accidents. It asked the authorities to ensure continuous patrols, the immediate removal of obstructing vehicles, and to impose penalties to deter violations.
Recognizing infrastructure deficiencies, the court called for improvements to road engineering and design, including proper lighting, reflective signage, lane markings, crash barriers, and warning systems, especially in high-risk areas. She stressed that highways should adhere to scientifically defined safety standards rather than ad hoc or minimum compliance.
The ruling further stressed the need for institutional coordination between multiple agencies, including road ownership authorities, traffic police, and local administrations, to ensure that safety measures are not fragmented or inconsistently implemented. The court stressed that accountability must be clearly established, and lapses may not be passed between departments.
In addition, the court highlighted the importance of data-driven decision making, directing authorities to maintain and analyze incident data to identify patterns and intervene proactively. He also called for public awareness and compliance measures, recognizing that road safety is a shared responsibility, although ultimately based on the state’s constitutional duty.
The authority noted that compliance with these directives must be monitored at appropriate levels, indicating that highway safety will remain under judicial scrutiny if systemic deficiencies persist.
The court ordered that copies of the order be distributed to chief secretaries and directors-general of police of all states and union territories for immediate implementation. The matter will be relisted after two months to report on compliance.
