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27 Apr 2026Polity & Governance3 questions

Supreme Court Holds Safe Travel on National Highways a Fundamental Right Under Article 21

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Article summary

In a suo motu case titled In Re: Phalodi Accident vs. NHAI and Others, the Supreme Court held that safe travel on National Highways is an enforceable component of the right to life under Article 21 of the Constitution. Acting on two November 2025 accidents that killed 34 people, a bench of Justices J.K. Maheshwari and A.S. Chandurkar invoked Article 142 to issue binding nationwide directives to NHAI, MoRTH, and all State governments. The judgment imposes a positive obligation on the State — not merely a negative restraint — to maintain safe highway conditions, marking a significant expansion of Article 21's jurisprudential scope.

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recallTests whether you read the article and retained key facts.
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applicationTests whether you can apply the concept to a new scenario.
1Q
analysisTests whether you can reason across multiple related facts.
1Q

Sample questions — answers revealed after test

Polity & GovernanceRecallEasy

Q1. In the 'In Re: Phalodi Accident vs. NHAI and Others' judgment (April 2026), the Supreme Court cited a specific statistical disproportion to establish the urgency of highway safety regulation. Which of the following correctly states that disproportion?

ANational Highways constitute 2% of India's total road network but account for 30% of all road accident fatalities.
BNational Highways constitute 5% of India's total road network but account for 40% of all road accident fatalities.
CNational Highways constitute 2% of India's total road network but account for 20% of all road accident fatalities.
DNational Highways constitute 10% of India's total road network but account for 30% of all road accident fatalities.
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Polity & GovernanceApplicationMedium

Q2. A High Court, hearing a petition on unsafe conditions on a State Highway that has caused multiple fatalities, wishes to pass sweeping directions binding on all State departments, district administrations, and highway authorities simultaneously — analogous to what the Supreme Court did in the Phalodi Accident case (2026). Which of the following constitutional or legal limitations is most directly applicable to the High Court's intent?

AA High Court cannot invoke Article 142 of the Constitution, as that power is exclusively vested in the Supreme Court to pass orders necessary for 'complete justice'.
BA High Court cannot take suo motu cognisance of road accidents, as suo motu jurisdiction is constitutionally restricted to the Supreme Court under Article 136.
CA High Court cannot issue directions to NHAI because NHAI, being a statutory body under the Central Government, falls entirely outside State judicial review.
DA High Court cannot invoke Articles 38 and 47 (Directive Principles) as independent grounds for issuing enforceable directions, since DPSPs are non-justiciable under Article 37.
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Polity & GovernanceAnalysisHard

Q3. Consider the following statements about the evolution of Article 21 jurisprudence in India and the Supreme Court's 'In Re: Phalodi Accident' judgment (2026): 1. The Supreme Court in Maneka Gandhi v. Union of India (1978) expanded Article 21 by holding that the procedure established by law must satisfy requirements of fairness, justice, and reasonableness — effectively reading in a substantive due process dimension. 2. In the Phalodi Accident judgment (2026), the Court characterised commuter safety as a 'positive mandate' on the State, meaning the State must actively create safe conditions, not merely refrain from endangering citizens. 3. Article 142, invoked in the Phalodi Accident case, is also available to High Courts under Article 226 when they exercise original jurisdiction over fundamental rights petitions. 4. The Phalodi Accident judgment cited Articles 38 and 47 of the Constitution — both Directive Principles — alongside Article 21 to ground the State's obligation toward road safety. Which of the above statements are correct?

A1, 2 and 4 only
B1 and 2 only
C2, 3 and 4 only
D1, 2, 3 and 4
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