The two cases
Both orders rely on existing central statutes — the Motor Vehicles Act 1988 and the Rights of Persons with Disabilities Act 2016. Together they activate Streams 1 and 4 of the Framework.
S. Rajaseekaran v. Union of India
2025 INSC 1189 · W.P.(C) 295/2012
Rajive Raturi v. Union of India
2024 INSC 858 · W.P.(C) 243/2005
The 13 May 2026 order did not address §138(1A)/§210D state compliance.
At the post-relisting hearing on 12 May 2026, the same Pardiwala-Viswanathan bench that issued the October 2025 directive pivoted to a different head of road-safety enforcement. The order of 13 May 2026 (2026 SCC OnLine SC 877) directs strict implementation of Rule 125-H of the Central Motor Vehicles Rules — Vehicle Location Tracking Devices and emergency panic buttons in public service vehicles — under MV Act §§56, 66, and 215-B. Less than 1% of transport vehicles have VLTDs installed. Only 8 states submitted Rule 118 compliance reports.
On the question that mattered to the §138(1A)/§210D rule-making deadline of 7 April 2026 — whether 35 states would be issued show-cause, granted extensions, or whether the Court would itself frame the rules — the public record of the 13 May order is silent. The primary PDF is not yet on api.sci.gov.in. Whether that aspect was deferred to a later date or addressed off-record cannot be confirmed.
What this means for the Framework
- Karnataka remains alone. No other state has notified rules under §138(1A) or §210D between 7 April and 30 May 2026. The Centre's only 2026 amendment to the CMV Rules (GSR 07(E), 6 January 2026) covers AVAS for electric vehicles and does not touch Rajaseekaran.
- The pressure point shifts. Without a fresh judicial mandamus, state compliance moves into political and citizen-pressure terrain — RTIs, Assembly questions, model-Bill adoption.
- Stream 4 (Universal Accessibility) also drifts. In Rajive Raturi, the Centre received a further four-month extension on 11 February 2026; final §40 rules under the RPwD Act remain unnotified. Next listing: 16 July 2026.
Sources: SCC Online (2026 SCC OnLine SC 877), Bar and Bench, LiveLaw, Rising Kashmir. Karnataka notification: TD 147 TDO 2025, 12 May 2026. Rajive Raturi extension: ThePrint and Mission Accessibility fortnightly report, February 2026. DEPwD draft: depwd.gov.in, 5 January 2026.
State-by-state compliance
36 jurisdictions — 28 states and 8 Union Territories — were directed to notify rules under MV Act §138(1A) and §210D by 7 April 2026. Karnataka has acted. 35 have not.
| State / UT | MV Act §138(1A) Rules | MV Act §210D Rules | Notes |
|---|---|---|---|
| Karnataka | Notified | Notified | Karnataka MV (Amendment) Rules 2026 · 12 May 2026 · TD 147 TDO 2025 · Read more → |
| Tamil Nadu | None | None | 18 Oct 2025 amendment was under §65(2)(k) — fancy number plates — not VRU related |
| Delhi (NCT) | None | None | Most recent rule on Transport Dept page from August 2024 |
| Maharashtra | None | None | Declared 2026 "Save Two-Wheeler Riders and Pedestrians Year" but no statutory rule |
| Gujarat | None | None | Last MV amendment Feb 2024 on registration plates — not VRU related |
| Andhra Pradesh | None | None | No public notification located |
| Arunachal Pradesh | None | None | No public notification located |
| Assam | None | None | No public notification located |
| Bihar | None | None | No public notification located |
| Chhattisgarh | None | None | No public notification located |
| Goa | None | None | No public notification located |
| Haryana | None | None | No public notification located |
| Himachal Pradesh | None | None | No public notification located |
| Jharkhand | None | None | No public notification located |
| Kerala | None | None | No public notification located |
| Madhya Pradesh | None | None | No public notification located |
| Manipur | None | None | No public notification located |
| Meghalaya | None | None | No public notification located |
| Mizoram | None | None | No public notification located |
| Nagaland | None | None | No public notification located |
| Odisha | None | None | No public notification located |
| Punjab | None | None | No public notification located |
| Rajasthan | None | None | No public notification located |
| Sikkim | None | None | No public notification located |
| Telangana | None | None | No public notification located |
| Tripura | None | None | No public notification located |
| Uttar Pradesh | None | None | No public notification located |
| Uttarakhand | None | None | No public notification located |
| West Bengal | None | None | No public notification located |
| Union Territories | |||
| Andaman & Nicobar Islands | None | None | No public notification located |
| Chandigarh | None | None | No public notification located |
| Dadra & Nagar Haveli and Daman & Diu | None | None | No public notification located |
| Jammu & Kashmir | None | None | No public notification located |
| Ladakh | None | None | No public notification located |
| Lakshadweep | None | None | No public notification located |
| Puducherry | None | None | No public notification located |
What you can do
If your state is in the red, here are the paths that move the needle — by role.
Citizen
- Write to your state Transport Secretary citing the Karnataka Rules and the S. Rajaseekaran order.
- File an RTI on the status of state §138(1A) and §210D rule-making.
- Share this tracker on social media — every state's officials see press attention.
Expert / Engineer
- Submit technical comments on any draft state rules.
- Help draft model rules for states that need them — adapt Karnataka's Chapter V-B and VI-A.
- Cite IRC 103-2022 and the Harmonised Guidelines 2021 as the binding floor.
Lawyer
- File RTIs to your state Transport Department on rule-making status.
- Track the S. Rajaseekaran docket via the Supreme Court Observer.
- Consider intervention in the existing PIL on behalf of a civil society organisation.
Elected Representative
- Question the Transport Department in the Legislative Assembly on §138(1A) and §210D compliance.
- Push for the Karnataka template as the state model.
- Table a State Active Mobility Bill modelled on Karnataka's DULT draft.
Keep this tracker honest — and use it
This tracker is hand-maintained by CFAM from primary government sources and compliance databases. If you spot a correction, an update, or a gazette CFAM hasn't recorded, please send it in.