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2025 DIGILAW 2843 (KER)

SUO MOTU v. Union Of India, Represented By The Secretary (Road, Transport And Highways), Ministry Of Road Transport And Highways, Transport Bhawan, Gokul Nagar, Sansad Marg Area, New Delhi

2025-11-21

ANIL K.NARENDRAN, MURALEE KRISHNA S.

body2025
ORDER : Anil K. Narendran, J. This writ petition is registered suo motu based on the order of this Court dated 09.07.2024 in SSCR No.30 of 2023, regarding the use of contract carriages and stage carriages in public places openly flouting the safety standards prescribed in AIS-008 - Installation Requirements of Lighting and Light-Signalling Devices for Motor Vehicle having more than Three Wheels including Quadricycles, Trailer and Semi-Trailer excluding Agricultural Tractors - and even AIS-052 - Code of Practice for Bus Body Design and Approval - posing a threat to the safety of other road users; the use of motor vehicles fitted with exhaust systems emitting fumes and loud sound, wide tyres protruding out of wheel arches/mudguards, etc., posing a potential threat to the safety of its passengers and other road users; recording of videos inside the driver cabin of contract carriages and other vehicles, while the vehicle is moving, thereby disturbing the concentration of the driver while driving; uploading videos by the vloggers on ‘YouTube’ and other online platforms promoting such unauthorised alterations and use of such vehicles in public places, etc. 2. On 09.12.2024, when this writ petition along with the connected matter, i.e., W.P.(C)No.25129 of 2024, came up for consideration before the Division Bench headed by the Hon’ble the Chief Justice, in view of the earlier order passed, the matters were directed to be placed on the administrative side for appropriate orders. When the matters were placed before the Hon’ble the Chief Justice on the administrative side, it was ordered on 13.12.2024, to place the writ petitions before the Division Bench headed by one among us [Anil K. Narendran, J.]. Accordingly, this writ petition along with the connected matter, i.e., W.P.(C)No.25129 of 2024 are being listed before the Division Bench headed by one among us [Anil K. Narendran, J.] and various orders have been passed from 19.12.2024. 3. Accordingly, this writ petition along with the connected matter, i.e., W.P.(C)No.25129 of 2024 are being listed before the Division Bench headed by one among us [Anil K. Narendran, J.] and various orders have been passed from 19.12.2024. 3. In the order dated 27.01.2025, this Court noticed that in view of the provisions contained in the Motor Vehicles Act, 1988 and the Rules and Regulations made thereunder and also the safety standards in AIS-008 - Installation Requirements of Lighting and Light-Signalling Devices for Motor Vehicle having more than Three Wheels including Quadricycles, Trailer and Semi- Trailer excluding Agricultural Tractors - and AIS-052 - Code of Practice for Bus Body Design and Approval - and the law laid down in Avishek Goenka v. Union of India [ (2012) 5 SCC 321 ] Jijith and others v. State of Kerala and others [2019 (1) KHC 463] ; Suo Motu v. Union of India [ 2024 (6) KLT 437 ] etc., the use of KSRTC ‘Munnar Royal View’ double-decker bus in a public place with ‘RGB’ colour-changing decorative LED lights, emitting Red, Green and Blue light in the passenger compartments and on the edges of the safety glass fitted on the side windows; with three headlamps on either side, i.e., six headlamps, after- market stop lights red in colour with neon halo rings amber in colour, openly flouting the safety standards in Para.5.15 of AIS- 008, without ‘retro-reflectors’ on the exterior bus body, to indicate the presence of the vehicle by the reflection of light emanating from a light source not connected to the vehicle, as per the safety standards in Rule 104 of the Central Motor Vehicles Rules and Para.5.15 of AIS-008, is legally impermissible. The use of such a vehicle in a public place posing a threat to the safety of other road users will be in violation of the law laid down by the Apex Court and this Court in the decisions referred to supra. 4. In paragraph 11 of the order dated 27.01.2025, this Court extracted a few screenshots taken from the news item that appeared in Mathrubhoomi News regarding ‘Munnar Royal View’ double-decker bus by KSRTC, which is fitted with ‘RGB’ colour- changing decorative LED lights, emitting Red, Green and Blue light in the passenger compartments and on the edges of the safety glass fitted on the side windows. The said screenshots are extracted hereunder; 5. The said screenshots are extracted hereunder; 5. In paragraph 13 of the order dated 27.01.2024, this Court noticed that, as evident from the news item that appeared in Mathrubhoomi News, KSRTC ‘Munnar Royal View’ double-decker bus is fitted with three headlamps on either side, i.e., six headlamps; after-market stop lights red in colour with neon halo rings amber in colour, openly flouting the safety standards in Para.5.15 of AIS-008, which specify the colours of the light emitted by the lamps. The said vehicle does not have ‘retro- reflectors’ on the exterior bus body, i.e., front retro-reflectors – white or colourless, rear retro-reflectors - red colour and side retro-reflectors - amber colour, as per the safety standards in Rule 104 of the Central Motor Vehicles Rules, 1989, and Para.5.15 of AIS-008, to indicate the presence of the vehicle by the reflection of light emanating from a light source not connected to the vehicle. The screenshots extracted in paragraph 13 of the order dated 27.01.2024 are extracted hereunder; 6. The order dated 27.01.2025 was followed by the orders dated 31.01.2025, 11.02.2025, 18.03.2025, etc. 7. On 23.10.2025, when this writ petition came up for consideration, this Court noticed the order dated 07.10.2025 of the Apex Court in W.P.(C)No.295 of 2012 - S. Rajaseekaran v. Union of India [2025 SCC OnLine SC 2191 : 2025 INSC 1189]. 8. In paragraphs 33 and 34 of the decision in S. Rajaseekaran [2025 SCC OnLine SC 2191] , the Apex Court noticed hazards from dazzling LED headlights, red-blue strobe lights and unauthorised emergency hooters. Paragraphs 33 and 34 of the said decision read thus; “Hazards from Dazzling LED Headlights, Red-Blue Strobe Lights, and Unauthorised Emergency Hooters: 33. This Court notes with particular concern the widespread use of dazzling white LED headlights, unauthorised red-blue strobe lights, and hooters that mimic emergency sirens. High-intensity headlights, including those fitted in two- wheelers, cause temporary visual disorientation and glare for oncoming drivers, as well as pedestrians. Pedestrians face a momentary loss of spatial awareness, increasing the risk of being hit or tripping into roadside drains, pits, or other hazards. Drivers experience reduced reaction time, difficulty judging distances, and impaired lane discipline, particularly on narrow streets and highways, which heightens the likelihood of collisions. 34. Red-blue strobes, intended exclusively for authorised emergency vehicles, are increasingly misused by private vehicles and are freely available in the market. Drivers experience reduced reaction time, difficulty judging distances, and impaired lane discipline, particularly on narrow streets and highways, which heightens the likelihood of collisions. 34. Red-blue strobes, intended exclusively for authorised emergency vehicles, are increasingly misused by private vehicles and are freely available in the market. Similarly, hooters that imitate emergency sirens are illegally installed on private vehicles. Such misuse creates a false sense of authority, intimidation, and panic among pedestrians and other road users. Drivers may react abruptly, slow down unnecessarily, or make erratic manoeuvres, creating traffic disruptions and raising accident risk. Pedestrians may freeze, retreat, or take unsafe evasive actions, increasing their exposure to injury. The unauthorised use of these lights and siren-like hooters also undermines respect for genuine emergency services, diluting the authority and effectiveness of legitimate responders during critical situations.” (underline supplied) 9. In paragraph 35 of the decision in S. Rajaseekaran v. Union of India [2025 SCC OnLine SC 2191] the Apex Court issued various directions. Paragraph 35.15 deals with directions on white LED dazzling headlights, red-blue strobe lights and unauthorised hooters. Paragraph 35.15 of the said decision reads thus; “Directions on White LED Dazzling Lights, Red-Blue Strobe Lights, and Unauthorized Hooters: 35.15. The Ministry of Road Transport & Highways (MoRTH), State Transport Departments, and traffic police authorities shall prescribe maximum permissible luminance and beam angles for vehicle headlights and ensure compliance through checks during PUC testing and vehicle fitness certification, while conducting targeted drives to penalize non-compliant or modified headlights. A complete ban on unauthorized red-blue strobe flashing lights and illegal hooters shall be enforced through seizure, market crackdowns, and penalties. Simultaneously, nationwide public awareness campaigns by MoRTH, state transport departments, and traffic police shall be conducted to sensitize drivers and pedestrians about the hazards posed by dazzling headlights, unauthorized strobe lights, and illegal hooters, thereby enhancing overall road safety.” 10. On 23.10.2025, when this writ petition came up for consideration, the learned Senior Panel Counsel for the 1 st respondent Union of India, the learned Special Government Pleader for the 2 nd respondent State and the official respondents and also the learned Standing Counsel for Kerala State Road Transport Corporation for the additional 7 th respondent sought time to get instructions. 11. 11. By the order dated 05.11.2025, the learned Senior Panel Counsel for Government of India was directed to make available for the perusal of this Court a copy of AIS-008 - Installation Requirements of Lighting and Light-Signalling Devices for Motor Vehicle having more than three wheels including Quadricycles, Trailer and Semi-Trailer excluding Agricultural Tractors – and a copy of AIS-052 - Code of Practice for Bus Body Design and Approval with amendments made thereto. 12. On 19.11.2025, the learned Senior Panel Counsel for the Government of India has placed on record a copy of AIS-008 - Installation Requirements of Lighting and Light-Signalling Devices for Motor Vehicle having more than Three Wheels including Quadricycles, Trailer and Semi-Trailer excluding Agricultural Tractors - and a copy of AIS-052 - Code of Practice for Bus Body Design and Approval, with the amendments made thereto. 13. In Avishek Goenka v. Union of India [(2012) 5 SCC 321] , a Two-Judge Bench of the Apex Court, in the context of Rule 100 of the Central Motor Vehicles Rules, 1989, which deals with safety glass, after taking note of the provisions contained in the Motor Vehicles Act, 1988, and the Central Motor Vehicles Rules, 1989, relating to lighting and light-signalling devices and retro-reflectors, found that the said Rules deal with every minute detail of construction and maintenance of a vehicle. In other words, the standards, sizes and specifications which the manufacturer of a vehicle is required to adhere to while manufacturing the vehicle are exhaustively dealt with under the Rules. What is permitted has been specifically provided for, and what has not been specifically stated would obviously be deemed to have been excluded from these Rules. It would neither be permissible nor possible for the Court to read into these statutory provisions what is not specifically provided for. 13.1. In Avishek Goenka (1) [ (2012) 5 SCC 321 ] , after referring to the provisions contained in Rule 106 of the Central Motor Vehicles Rules, which deals with deflection of lights, Rule 119, which delas with horns and Rule 120, which deals with silencers, the Apex Court found that the provisions under the Central Motor Vehicles Rules demonstrate the extent of minuteness in the Rules and the efforts of the framers to ensure, not only the appropriate manner of construction and maintenance of vehicles, but also the safety of other users of the road. The legislative intent attaching due significance to the ‘public safety’ is evident from the object and reasons of the Motor Vehicles Act, the provisions of the said Act, and more particularly, the Rules framed thereunder. 14. In Avishek Goenka v. Union of India [(2012) 8 SCC 441] , the Two-Judge Bench held that, if the interpretation given by the applicants is accepted, it would frustrate the very purpose of enacting Rule 100 of the Central Motor Vehicles Rules, 1989, and would also hurt the safety requirements of a motor vehicle as required under the Motor Vehicles Act. The Two-Judge Bench observed that a number of Rules have been discussed in the judgment dated 27.04.2012 - Avishek Goenka (1) [(2012) 5 SCC 321] to demonstrate that these Rules are required to be strictly construed, otherwise they would lead to disastrous results, and frustrate the very purpose of enacting such a law. 15. In Suo Motu v. Union of India [2024 SCC OnLine Ker. 6894] - order dated 04.10.2024 in this writ petition - after taking note of the law laid down by the Apex Court in Avishek Goenka (1) [ (2012) 5 SCC 321 ] , the safety standards in AIS- 008 and AIS-052 and the also the provisions contained in the Motor Vehicles (Driving) Regulations, 2017, this Court held that a motor vehicle governed by AIS-008, which is not installed with lighting and light-signalling devices and also retro-reflectors referred to in Para.6.0, conforming to the individual specifications for such lighting and light-signalling devices and also for retro- reflectors prescribed in Paras.6.1 to 6.20, or a motor vehicle governed by AIS-008, which is installed with lighting and light- signalling devices or retro-reflectors other than those referred to in Para.6.0, shall not be permitted to be used in any public place, since the use of such a motor vehicle in a public place without complying with the safety standards in AIS-008 is likely to endanger the safety of other road users. 15.1. In Suo Motu v. Union of India [2024 SCC OnLine Ker. 6894] , this Court held that in view of the provisions contained in AIS-052, ‘cab lamp’ or ‘courtesy lamp’ fitted in the driver cabin above the head of the driver is for lighting up the dashboard area and the inside driver cabin, which is meant for operation while the bus is stationary [para 1.1.49]. 6894] , this Court held that in view of the provisions contained in AIS-052, ‘cab lamp’ or ‘courtesy lamp’ fitted in the driver cabin above the head of the driver is for lighting up the dashboard area and the inside driver cabin, which is meant for operation while the bus is stationary [para 1.1.49]. Similarly, ‘passenger area lamps’ provided in the passenger compartment are for lighting up the passenger area and assist the passenger in identifying objects and reading the printed matter [para 1.1.55]. The ‘driver cabin’ or ‘passenger compartment’ of a contract carriage or stage carriage governed by AIS-052 cannot be fitted with unauthorised multi-coloured LED lights, neon lights, laser lights, flashlights, etc., flouting the safety standards contained in AIS-052, in order to convert the passenger compartment into a dancing floor. A contract carriage or stage carriage, which is fitted with unauthorised multi-coloured LED lights, neon lights, laser lights, flashlights, etc. in the ‘driver cabin’ or ‘passenger compartment’, flouting the safety standards contained in AIS-052, cannot be treated as a vehicle which complies with the provisions of the Motor Vehicles Act and the rules made thereunder, for the purpose of grant of certificate of fitness. 15.2. In Suo Motu v. Union of India [2024 SCC OnLine Ker. 6894] , this Court held that, in view of the provisions contained in para 7.8.1 of AIS-052, the accredited bus body building units shall meet the type approval requirements specified in para 7.2. The accreditation granted to the bus body building unit is liable to be suspended or withdrawn in case of non- conformity, by the Ministry of Road Transport and Highways, as per the notified procedures for facility accreditation of bus body builders, in view of the provisions contained in para 7.9.1. 15.3. In Suo Motu v. Union of India [2024 SCC OnLine Ker. 6894] , this Court held that in view of the prohibition contained in sub-rule (1) of Rule 92 of the Central Motor Vehicle Rules, no person shall use or cause or allow to be used in any public place a contract carriage or stage carriage flouting the safety standards contained in AIS-008 or AIS-052. 6894] , this Court held that in view of the prohibition contained in sub-rule (1) of Rule 92 of the Central Motor Vehicle Rules, no person shall use or cause or allow to be used in any public place a contract carriage or stage carriage flouting the safety standards contained in AIS-008 or AIS-052. In addition to the penal consequences provided in the Motor Vehicles Act, the owner of such a vehicle has to be imposed with a fine of Rs.5,000/- per such alteration; i.e., Rs.5,000/- for each unauthorised multi- coloured LED lights, neon lights, laser lights, flashlights, etc. fitted on the ‘exterior body’, ‘driver cabin’ and ‘passenger compartment’, in view of the provisions contained in sub-section (4) of Section 182A of the Motor Vehicles Act, read with S.R.O.No.788/2019 published in the Kerala Gazette Extraordinary No.2577 dated 26.10.2019. Paragraphs 20 to 23 of the said decision read thus; “20. Section 182A of the Motor Vehicles Act, inserted by the Motor Vehicles (Amendment) Act, 2019, deals with punishment for offences relating to the construction, maintenance, sale and alteration of motor vehicles and components. As per sub-section (4) of Section 182A, whoever, being the owner of a motor vehicle, alters a motor vehicle, including by way of retrofitting of motor vehicle parts, in a manner not permitted under the Act or the rules and regulations made thereunder shall be punishable with imprisonment for a term which may extend to six months, or with a fine of five thousand rupees per such alteration or with both. 21. Section 190 of the Motor Vehicles Act, as substituted by Section 72 of the Motor Vehicles (Amendment) Act, 2019, deals with using vehicle in unsafe condition. As per sub- section (2) of Section 190, any person who drives or causes or allows to be driven, in any public place a motor vehicle, which violates the standards prescribed in relation to road safety, control of noise and air - pollution, shall be punishable for the first offence with imprisonment for a term which may extend to three months, or with a fine with may extend to ten thousand rupees or with both and he shall be disqualified for holding licence for a period of three months and for any second or subsequent offence with imprisonment for a term which may extend to six months, or with fine which may extend to ten thousand rupees, or with both. 22. As per sub-section (4) of Section 206 of the Motor Vehicles Act, inserted by Section 88 of the Motor Vehicles (Amendment) Act, 2019, a police officer or other person authorised in this behalf by the State Government shall, if he has reason to believe that the driver of a motor vehicle has committed an offence under any of Section 183, Section 184, Section 185, Section 189, Section 190, Section 194C, Section 194D, or Section 194E, seize the driving licence held by such driver and forward it to the licensing authority for disqualification or revocation proceedings under Section 19. 23. A contract carriage or stage carriage governed by AIS- 008 and AIS-052, which is fitted with unauthorised multi- coloured LED lights, neon lights, laser lights, flashlights, etc. in the ‘exterior body’, ‘driver cabin’ or ‘passenger compartment’, flouting the safety standards contained in AIS-008 or AIS-052, cannot be treated as a vehicle which complies with the provisions of Chapter V of the Motor Vehicles Act (which deals with construction, equipment and maintenance of motor vehicles) and the rules made thereunder, for the purpose of grant of certificate of fitness. As per sub-rule (1) of Rule 92 of the Central Motor Vehicles Rules, no person shall use or cause or allow to be used in any public place any motor vehicle which does not comply with the provisions of Chapter V. In view of the prohibition contained in sub-rule (1) of Rule 92 of the Central Motor Vehicle Rules, no person shall use or cause or allow to be used in any public place a contract carriage or stage carriage flouting the safety standards contained in AIS-008 or AIS-052. In addition to the penal consequences provided in the Motor Vehicles Act, the owner of such a vehicle has to be imposed with a fine of Rs.5,000/- per such alteration; i.e., Rs.5,000/- for each unauthorised multi-coloured LED lights, neon lights, laser lights, flashlights, etc. fitted on the ‘exterior body’, ‘driver cabin’ and ‘passenger compartment’, in view of the provisions contained in sub-section (4) of Section 182A of the Motor Vehicles Act, read with S.R.O.No.788/2019 published in the Kerala Gazette Extraordinary No.2577 dated 26.10.2019.” 16. Chapter III of the Central Motor Vehicles Rules deals with registration of motor vehicles. Rule 62 deals with validity of certificate of fitness. Chapter III of the Central Motor Vehicles Rules deals with registration of motor vehicles. Rule 62 deals with validity of certificate of fitness. In view of the provisions contained in Rule 62, the certificate of fitness in respect of a transport vehicle issued in Form No.38 contains a certification that the vehicle complies with the provisions of the Motor Vehicles Act and the Rules made thereunder. As per the proviso to sub-rule (1) of Rule 62 of the Central Motor Vehicles Rules, the renewal of a fitness certificate shall be made only after carrying out the tests specified in the Table given in Rule 62. Rule 62 contemplates checking the condition of spark plug/suppressor cap/high tension cable, head lamp beams, other lights, reflectors, bulbs, rear view mirror or device for indirect vision, safety glass, horn, silencer, dash board equipment, windshield wiper, exhaust emission, braking system, speedometer and steering gear; functioning of all the aforesaid items except the reflectors, bulbs, rear view mirror, safety glasses and exhaust emission; the make/rating, etc. of spark plug/ suppressor cap/high tension cable, bulbs and safety glass as per original equipment recommendations. While checking other lights it has to be ensured that unauthorised lights are not fitted; while checking reflectors it has to be ensured that the colour of reflectors and reflective tapes are as per Rule 104; while checking bulbs it has to be ensured that head light bulbs wattage, especially halogen, is not higher than those indicated in IS 1606-1993 and also that halogen bulbs with P45t caps are not used in all vehicles; while checking safety glasses it has to be ensured that laminated windscreen glass is used for vehicles manufactured from April, 1996 onwards; etc. Therefore, a transport vehicle fitted with unauthorised lighting, light-signalling devices and retro-reflectors cannot be treated as a vehicle which complies with the provisions of the Motor Vehicles Act and the Rules made thereunder, for the purpose of granting a certificate of fitness. 17. Chapter V of the Central Motor Vehicles Rules deals with construction, equipment and maintenance of motor vehicles. Therefore, a transport vehicle fitted with unauthorised lighting, light-signalling devices and retro-reflectors cannot be treated as a vehicle which complies with the provisions of the Motor Vehicles Act and the Rules made thereunder, for the purpose of granting a certificate of fitness. 17. Chapter V of the Central Motor Vehicles Rules deals with construction, equipment and maintenance of motor vehicles. As per sub-rule (1) of Rule 92, no person shall use or cause or allow to be used in any public place any motor vehicle which does not comply with the provisions of Chapter V. As per the proviso to sub- rule (1), nothing contained in Rue 92 shall apply to vehicles manufactured prior to the coming into force of the Central Motor Vehicles (Amendment) Rules, 1993. As per sub-rule (2), nothing in Rule 92 shall apply to a motor vehicle enumerated in clauses (a) to (d). As per sub-rule (3) of Rule 92, substituted by G.S.R.870(E) dated 13.09.2018, whenever a part, component, or assembly is compliant with the international standard namely, EEC or ECE or Japanese, in lieu of the standard notified in the rules, the compliance of such part, component or assembly shall be deemed to be established for the purpose of Rules 124 and 126, by a certificate of compliance for the relevant standard issued by an authorised agency or accredited certifying agency. As per sub- rule (4) of Rule 92, inserted by G.S.R.935(E) dated 18.12.2019, the manufacturers who are affixing microdot identifiers in the motor vehicles and their parts, components, assemblies, sub- assemblies shall conform to Automotive Industry Standard (AIS- 155) as amended from time to time. 18. Rule 102 of the Central Motor Vehicles Rules deals with signalling devices, direction indicators and stop lights. 18. Rule 102 of the Central Motor Vehicles Rules deals with signalling devices, direction indicators and stop lights. As per sub-rule (1) of Rule 102, the signal to turn to the right or to the left shall be given by electrically operated direction indicator lamps on all motor vehicles including construction equipment vehicles and combined harvesters, and such construction equipment vehicles and combined harvester be fitted and maintained so that conditions enumerated in clauses (i) to (iii) of sub-rule (1) are met, i.e., (i) the direction indicator lamps shall be of amber colour which is illuminated to indicate the intention to turn, by a light flashing at the rate of not less than 60 and not more than 120 flashes per minute; (ii) the light emitted by the lamp when in operation shall be clearly visible from both front and rear of the vehicle; and (iii) the minimum illuminated area of each direction indicator shall be 60 square centimeters. As per the proviso to sub-rule (1) of Rule 102, nothing contained in this sub-rule shall apply to L1 category of motorcycles. As per sub-rule (2) of Rule 102, on all vehicles other than motorcycles, the intention to stop the vehicle (other than construction equipment vehicle having hydrostatic brakes) shall be indicated by two electrical stop lamps which shall be red in colour and shall be fitted one on each left and right-hand sides at the rear of the vehicle. The stop lamps shall light up on the actuation of the service brake control. In the case of motorcycle, the intention to stop the vehicle shall be indicated by one stop lamp at the rear which shall light up on the actuation of the control operating the brakes on the rear wheels. As per sub-rule (3) of Rule 102, one year from the date of commencement of the Central Motor Vehicles (Amendment) Rules, 1993, the stop-lamp of every motorcycle shall be so designed and fitted that it will light up on actuation of any of the controls which actuate the brakes on any wheel. 19. Rule 104 of the Central Motor Vehicles Rules deals with fitment of reflectors. As per sub-rule (1) of Rule 104, every motor vehicle manufactured on and after the 1 st day of April, 2006, including trailers and semi-trailers, other than motorcycles, shall be fitted with two red reflectors, one each on both sides at their rear. 19. Rule 104 of the Central Motor Vehicles Rules deals with fitment of reflectors. As per sub-rule (1) of Rule 104, every motor vehicle manufactured on and after the 1 st day of April, 2006, including trailers and semi-trailers, other than motorcycles, shall be fitted with two red reflectors, one each on both sides at their rear. Every motorcycle shall be fitted with at least one red reflector at the rear. Clauses (i) to (v) of the proviso to sub-rule (1) deal with fitment of reflectors in respect of vehicle of Categories N1, N2, N3, M2, M3 and three wheeled vehicles including e-rickshaw and e-cart. As per sub-rule (3) of Rule 104, all trailers including semi-trailers, other than those drawn by three wheeled tractors shall be fitted with reflex reflectors provided in clauses (i) to (iii). As per sub-rule (4) of Rule 104, substituted vide G.S.R.1192(E) dated 10.12.2018, with effect from 11.12.2018, after omitting sub-rules (2) and (5) of Rule 104, the reflectors referred to in Rule 104 and in Rule 110 fitted with motor vehicles manufactured on or after the 1 st day of October, 2019 shall be of reflex type conforming to AIS-057 (Rev.1) 2010 standard as amended from time to time, till such time the corresponding BIS specifications are notified under the Bureau of Indian Standards Act, 2016. 20. Rule 105 of the Central Motor Vehicles Rules deals with lamps. As per sub-rule (1) of Rule 105, save as provided in the said rule, every motor vehicle, while being driven in a public place during the period half an hour after sunset and at any time when there is no sufficient light, shall be lit with the lamps enumerated in clauses (a) to (d) of sub-rule (1), which shall render clearly discernible persons and vehicles on the road at a distance of one hundred and fifty-five metres ahead. As per clause (a) of sub-rule (1) of Rule 105, a motor vehicle other than three- wheelers, three-wheeled invalid carriages and motorcycles shall have two or four headlamps. As per clause (a) of sub-rule (1) of Rule 105, a motor vehicle other than three- wheelers, three-wheeled invalid carriages and motorcycles shall have two or four headlamps. As per clause (i) of sub-rule (2), every such motor vehicle other than a three-wheeler shall carry two rear lamps showing to the rear a red light visible in the rear from a distance of one hundred and fifty-five metres; and as per clause (ii) lamp, which may be the rear lamp or some other device, illuminating with a white light the whole of the registration mark exhibited on the rear of the vehicle, so as to render it legible from a distance of fifteen metres to the rear. Sub-rule (3) of Rule 105 specifies the power and height of front headlamps of a motor vehicle. As per sub-rule (3) of Rule 105, on and from the commencement of the Central Motor Vehicles (Amendment) Rules, 1993, all the obligatory front headlamps of a motor vehicle other than motorcycles shall be as nearly as possible of the same power and fixed at a height as specified in Indian Standards IS:8415-1977 (clause 4.1). As per the first proviso to sub-rule (3), in the case of four-wheel drive cross-country vehicles, the maximum height of the said front headlamps may be as per limits specified in Indian Standards IS:8415-1977 (clause 4.1.1). As per sub-rule (4), the rear lamp shall be fixed either on the centre line of the vehicle or to the right-hand side, and save in the case of transport vehicle, at a height of not exceeding one metre above the ground. As per sub-rule (5), in the case of a transport vehicle, the rear light may be fixed at such level as may be necessary to illuminate the registration mark. 21. Rule 106 of the Central Motor Vehicles Rules provides for deflection of lights. As per sub-rule (1) of Rule 106, substituted by the Central Motor Vehicles (6 th Amendment) Rules, 2014, which came into force with effect from 24.04.2014, no head lamp showing a light to the front shall be used on any motor vehicle including agricultural tractor and construction equipment vehicle and combine harvester (whether fitted with single or dual head lamp) unless such vehicle is so constructed, fitted and maintained that the beam of light emitted therefrom meet the requirements of the respective safety standards notified under Rules 124 and 124A. 22. Rule 107 of the Central Motor Vehicles Rules deals with top lights. As per Rule 107, every goods vehicle including trailer and semi-trailer other than three-wheelers and vehicles with overall width not exceeding 2.1 metres shall be fitted with two white lights at the top right and left corners showing white light to the front and two red lights at the top at the rear showing red light to the rear. The lights shall remain lit when the vehicle is kept stationary on the road during night and at the time of poor visibility. As per the proviso to Rule 107, in the case of goods carriage without a full body in the rear, provision for fitting of the top light at the rear shall not be necessary. 23. Rule 108 of the Central Motor Vehicles Rules deals with use of red, white or blue light. As per sub-rule (1) of Rule 108, no motor vehicle shall show a red light to the front or light other than red to rear. As per the proviso to sub-rule (1) of Rule 108, the provisions of this rule shall not apply to the internal lighting of the vehicle [clause (i)]; or the amber light, if displayed by any direction indicator or as top light used on vehicle for operating within the premises such as airports, ports, mines and project sites, without going outside the said premises on to public roads [clause (ii)]; the amber light, if displayed by any direction indicator as top light on a vehicle specifically designated for the purpose of patrolling on the National Highways [clause (ii-a)]; the blinker type of red light with purple glass fitted to an ambulance van used for carrying patients or the warning lamps fitted on Road Ambulance in accordance with Annexure I of AIS-125 (Part-1)- 2014 [clause (iv)]; white light illuminating the rear number plate [clause (vi)]; white light used while reversing [clause (vii)]; plough light provided in agricultural tractors for illuminating the implement's working area on the ground in agricultural field operations [clause (viii)]. As per sub-rule (4) of Rule 108, use of multi-coloured red, blue and white light shall be permitted only on vehicles specifically designated for such emergency and disaster management duties as may be specified by the Central Government. As per sub-rule (4) of Rule 108, use of multi-coloured red, blue and white light shall be permitted only on vehicles specifically designated for such emergency and disaster management duties as may be specified by the Central Government. As per sub-rule (7) of Rule 108, on and after the 1 st April, 2018, the top lights (warning lamps) fitted on Road Ambulances shall be in accordance with AIS:125 (Part 1)-2014, as amended from time to time, for all types of ambulances specified therein, till the corresponding BIS specifications are notified under the Bureau of Indian Standards Act, 1986. 24. Rule 109 of the Central Motor Vehicles Rules deals with parking lights. As per Rule 109, every construction equipment vehicle, combine harvester and motor vehicle and every motor vehicle other than motorcycles and three-wheeled invalid carriages shall be provided with one white or amber parking light on each side in the front. In addition to the front lights, two red parking lights one on each side in the rear shall be provided. The front and rear parking lights shall remain lit even when the vehicle is kept stationary on the road. As per the first proviso to Rule 109, these rear lamps can be the same as the rear lamps referred to in sub-rule (2) of Rule 105. As per the second proviso to Rule 109, construction equipment vehicles and combine harvesters, which are installed with flood light lamps or spot lights at the front, rear or side of the vehicle for their off-highway or construction operations, shall have separate control for such lamps or lights and these lights shall be permanently switched off when the vehicle is travelling on the road. 25. Rule 110 of the Central Motor Vehicles Rules deals with lamps on three-wheelers. Rule 111 of the Central Motor Vehicles Rules, which deals with prohibition of spotlights, etc., provides that no spotlight or searchlight shall be carried on the front of any vehicle except in exceptional circumstances with the prior approval of the registering authority. 26. Rule 124 of the Central Motor Vehicles Rules deals with safety standards of components. Rule 111 of the Central Motor Vehicles Rules, which deals with prohibition of spotlights, etc., provides that no spotlight or searchlight shall be carried on the front of any vehicle except in exceptional circumstances with the prior approval of the registering authority. 26. Rule 124 of the Central Motor Vehicles Rules deals with safety standards of components. As per sub-rule (1) of Rule 124, the Central Government may, from time to time, specify, by notification in the Official Gazette, the standards or the relevant standards specified by the Bureau of Indian Standards of any part, component or assembly to be used in the manufacture of a vehicle including construction equipment vehicle and the date from which such parts, components or assemblies are to be used in the manufacture of such vehicle and on publication of such notification every manufacturer shall use only such of these parts, components or assemblies in manufacture of the vehicle. As per sub-rule (2) of Rule 124, every manufacturer shall get the prototype of the part, component or sub-assembly for which standards have been notified, approved from any agency as referred to in Rule 126 and in the case of tyre and rubber components from the Indian Rubber Manufacturers Research Association, Thane, or in case of compliance with notified Indian Standards from any laboratory duly authorised by the Bureau of Indian Standards. On the basis of such approval, every manufacturer shall also certify compliance with the provisions of the rule in Form 22. As per sub-rule (4) of Rule 124, the procedure for type approval and establishing conformity of production for components, listed in Table below sub-rule (4), shall be in accordance with AIS:037-2004 till the corresponding BIS specifications are notified under the Bureau of Indian Standards Act, 1986. 27. Chapter VII of the Kerala Motor Vehicles Rules deals with construction, equipment and maintenance of motor vehicles. As per sub-rule (1) of Rule 249, no person shall use and no person shall cause or allow to be used or to be in any public place any motor vehicle which does not comply with the rules contained in Chapter VII or with any order thereunder made by the competent authority. 28. Rule 257 of the Kerala Motor Vehicles Rules deals with electric wires. As per Rule 257, all electric wires or leads shall be adequately insulated. 28. Rule 257 of the Kerala Motor Vehicles Rules deals with electric wires. As per Rule 257, all electric wires or leads shall be adequately insulated. As per the proviso to Rule 257, the electric wires in buses that are registered on or after 1 st day of October, 2017 shall be in accordance with AIS-052 (Rev.1) - 2008 as amended from time to time. 29. Rule 278 of the Kerala Motor Vehicles Rules provides that every vehicle shall be so constructed that, save for the front pillars of the body, the driver shall have a clear vision both to the front and through an angle of ninety degrees to his right or left- hand side, as the case may be. The front pillars of the body shall be so constructed as to cause the least possible obstruction to the vision of the driver. 30. As per Rule 286 of the Kerala Motor Vehicles Rules, 1989, every vehicle shall be furnished with one or more electric lights adequate to give reasonable illumination throughout the passenger compartment or compartments, but of such power or so screened as not to impair the forward vision of the driver. As per the proviso to Rule 286 of the Kerala Motor Vehicles Rules, the internal lighting in buses that are registered on or after 01.10.2017 shall be in accordance with AIS-052 (Rev.1) - 2008 as amended from time to time. 31. In Jijith and others v. State of Kerala and others [2018 SCC OnLine Ker 8262 : 2019 (1) KHC 463 ] , this Court held that, as provided under Rule 286 of the Kerala Motor Vehicles Rules, the internal lighting in a contract carriage, which is a public service vehicle, is for the purpose of providing reasonable illumination throughout the passenger compartment. Therefore, the passenger compartment of a contract carriage cannot be fitted with continuously blinking multi-coloured LED lights, laser lights, etc., in order to convert it to a dancing floor. The law laid down in Jijith [2018 SCC OnLine Ker 8262] was followed in Saji K.M. v. Deputy Transport Commissioner, Thrissur and others [2019 SCC OnLine KER 2047 : 2019 (3) KHC 836]. 32. The law laid down in Jijith [2018 SCC OnLine Ker 8262] was followed in Saji K.M. v. Deputy Transport Commissioner, Thrissur and others [2019 SCC OnLine KER 2047 : 2019 (3) KHC 836]. 32. On 19.11.2025, the learned Senior Panel Counsel for the Government of India has placed on record a copy of AIS-008-Installation Requirements of Lighting and Light-Signalling Devices for Motor Vehicle having more than Three Wheels including Quadricycles, Trailer and Semi-Trailer excluding Agricultural Tractors, with the amendments made thereto, i.e., AIS-008 (Rev.2). 33. Para 5.0 of AIS-008 (Rev.2), deals with General Specifications. As per para 5.1 only those lighting and light signalling devices referred to in para 6.0 of the standard (AIS- 008) shall be permitted to be installed on motor vehicles. As per clause 5.9.1 direction indicator lamps, vehicle hazard warning signal, amber side marker lamps complying with para 6.18.7 and the emergency stop signal shall be flashing lamps. 34. Para 5.15 of AIS-008 (Rev.2) deals with colours of light emitted by lamps. Para 5.15 reads thus; “5.15. The colours of the light emitted by the lamps are the following: main-beam headlamp White dipped-beam headlamp White front fog lamp White or selective yellow reversing lamp White emergency stop signal Amber or Red rear-end collision alert signal Amber rear registration plate lamp White front position lamp White rear position lamp Red rear fog lamp Red parking lamp White in front, Red at the rear, Amber if reciprocally incorporated in the side direction-indicator lamps or in the side-marker lamps. side-marker lamp amber; however the rearmost side-marker lamp can be red if it is grouped or combined or reciprocally incorporated with the rear position lamp, the rear end-outline marker lamp, the rear fog lamp, the stop lamp or is grouped or has part of the light emitting surface in common with the rear retro-reflector. side-marker lamp amber; however the rearmost side-marker lamp can be red if it is grouped or combined or reciprocally incorporated with the rear position lamp, the rear end-outline marker lamp, the rear fog lamp, the stop lamp or is grouped or has part of the light emitting surface in common with the rear retro-reflector. end-outline marker lamp: White in front, red at the rear daytime running lamp White rear retro-reflector, non-triangular: Red Rear retro-reflector, triangular: White or colourless side retro-reflector, non-triangular Amber; however the rearmost side retro-reflector can be red if it is grouped or has part of the light emitting surface in common with the rear position lamp, the rear end-outline marker lamp, the rear fog lamp, the stop-lamp or the red rearmost side-marker lamp or the rear retro reflector, non-triangular cornering lamp White Conspicuity marking White to the front Yellow to the side Red to the rear Adaptive front-lighting systems (AFS) White Exterior courtesy lamp White Maneuvering lamp White 35. Para 5.16 of AIS-008 (Rev.2) deals with number of lamps. As per para 5.16.1, the number of lamps mounted on the vehicle shall be equal to the number indicated in the individual specifications of this standard. 36. Para 6.13 of AIS-008 (Rev.2) deals with end-outline marker lamp. As per para 6.13.1 end-outline marker lamp is mandatory on vehicles exceeding 2.10 width. It is optional on vehicles between 1.80 and 2.10 metre in width. Rear end-outline marker lamps are optional on chassis cabs. As per para 6.13.2, the number of end-outline marker lamp is 2 visible from the front and the 2 visible from the rear. Additional lamps may be fitted as follows; (a) 2 visible from the front and (b) 2 visible from the rear. 37. Para 6.18 of AIS-008 (Rev.2) deals with side marker lamps. As per para 6.18.1, side marker lamps are mandatory on all vehicles, the length of which exceeds 6 metre, except for chassis-cabs. As per para 6.18.4.3, at least on side marker lamp shall be fitted to the middle third of the vehicle, the foremost side marker lamp being not further than 3 metre from the front. The distance between 2 adjacent side marker lamp shall not exceed 3 metre. The distance between the rear most side marker lamp and the rear of the vehicle shall not exceed 1 metre. 38. The distance between 2 adjacent side marker lamp shall not exceed 3 metre. The distance between the rear most side marker lamp and the rear of the vehicle shall not exceed 1 metre. 38. As held by the Apex Court in Avishek Goenka (1) [ (2012) 5 SCC 321 ] , the provisions under the Central Motor Vehicles Rules demonstrate the extent of minuteness in the Rules and the efforts of the framers to ensure, not only the appropriate manner of construction and maintenance of vehicles, but also the safety of other users of the road. What is permitted has been specifically provided for in the Central Motor Vehicles Rules, and what has not been specifically stated would obviously be deemed to have been excluded from these Rules. 39. In view of the law laid down by the Apex Court in Avishek Goenka (1) [ (2012) 5 SCC 321 ] , every motor vehicle, including transport vehicles, shall be fitted with the lighting, light- signalling devices and retro-reflectors which are specifically provided for in the Central Motor Vehicles Rules and the relevant safety standards in AIS-008, AIS-052, etc. What has not been specifically stated in the said Rules and the safety standards would obviously be deemed to have been excluded from those Rules/safety standards. Therefore, no motor vehicle, including a transport vehicle, can be fitted with lighting, light-signalling devices and retro-reflectors, which are not specifically provided for in the Central Motor Vehicles Rules and the relevant safety standards. The use of such a motor vehicle in a public place without complying with the provisions under said Rules and the relevant safety standards is likely to endanger the safety of other road users. 40. Sub-section (4) of Section 56 of the Motor Vehicles Act provides for cancellation of a certificate of fitness, at any time, if the prescribed authority, for reasons to be recorded in writing, is satisfied that the vehicle to which it relates no longer complies with all the requirements of the Motor Vehicles Act and the Rules made thereunder. 40. Sub-section (4) of Section 56 of the Motor Vehicles Act provides for cancellation of a certificate of fitness, at any time, if the prescribed authority, for reasons to be recorded in writing, is satisfied that the vehicle to which it relates no longer complies with all the requirements of the Motor Vehicles Act and the Rules made thereunder. Therefore, at any time after the issuance of a fitness certificate, if the prescribed authority, for reasons to be recorded in writing, is satisfied that the transport vehicle to which it relates no longer complies with all the requirements of the Motor Vehicles Act and the Rules made thereunder, the fitness certificate is liable to be cancelled, as per the procedure contemplated under sub-section (4) of Section 56 of the Act. In case of violation of the standards prescribed in relation to road safety, control of noise and air pollution, any person who drives or causes or allows to be driven, such a vehicle in a public place, shall also be proceeded against as per the provisions under sub-section (2) of Section 190 of the Act. 41. Rule 334 of the Kerala Motor Vehicle Rules provides for exemption by the Government. As per Rule 334, the Government may, for good and sufficient reasons, exempt to such extent as they may deem necessary any motor vehicle or class of motor vehicles from all or any of the provisions of the rules in Chapter VII, which deals with the construction, equipment and maintenance of motor vehicles. 42. Invoking the provisions under Rule 334 of the Kerala Motor Vehicles Rules, the State Government, vide G.O.(Ms.)No. 501/2024/Trans. dated 28.12.2024, granting exemption to KSRTC double-decker buses bearing registration Nos.KL-15/587 and KL- 15/9051, 1989, for installing multi-coloured LED lights inside the passenger compartments, on the edges of the safety glass fitted on the side windows and also in the wheel arches of the said vehicles. 43. The installation requirements of lighting, light- signalling devices and retro-reflectors in a motor vehicle are specifically provided for in the Central Motor Vehicles Rules and the relevant safety standards in AIS-008, AIS-052, etc. 43. The installation requirements of lighting, light- signalling devices and retro-reflectors in a motor vehicle are specifically provided for in the Central Motor Vehicles Rules and the relevant safety standards in AIS-008, AIS-052, etc. The provisions contained in Rule 334 of the Kerala Motor Vehicles Rules, which provides for exemption by the Government, of any motor vehicle or class of motor vehicles from any of the provisions of the Rules in Chapter VII of the said Rules, which deals with construction, equipment and maintenance of motor vehicles, would not enable the State Government to exempt a motor vehicle or class of motor vehicles from the installation requirements of lighting, light-signalling devices and retro-reflectors in a motor vehicle, specifically provided in Chapter V of the Central Motor Vehicles Rules, which deals with construction, equipment and maintenance of motor vehicles, or the relevant safety standards in AIS-008, AIS-052, etc. 44. In view of the statutory provisions referred to hereinbefore and also the law laid down in the decisions referred to supra, every motor vehicle, including transport vehicles, shall be fitted with the lighting, light-signalling devices and retro- reflectors which are specifically provided for in the Central Motor Vehicles Rules and the relevant safety standards in AIS-008, AIS- 052, etc. The use of a motor vehicle in a public place without complying with the provisions under the Central Motor Vehicles Rules and the relevant safety standards is likely to endanger the safety of other road users. Therefore, by invoking the provisions under Rule 334 of the Kerala Motor Vehicles Rules, the State Government cannot exempt a motor vehicle or class of motor vehicles from the installation requirements of lighting, light- signalling devices and retro-reflectors in a motor vehicle, specifically provided in Chapter V of the Central Motor Vehicles Rules or the relevant safety standards in AIS-008, AIS-052, etc. Therefore, on the strength of the so called ‘exemption’ granted by the State Government under Rule 334 of the Kerala Motor Vehicles Rules, 1989, vide G.O.(Ms.)No.501/2024/Trans. dated 28.12.2024, KSRTC double-decker buses bearing registration Nos.KL-15/587 and KL-15/9051, cannot be permitted to be used in any public place, installing multi-coloured LED lights inside the passenger compartments, on the edges of the safety glass fitted on the side windows and also in the wheel arches of the said vehicles. dated 28.12.2024, KSRTC double-decker buses bearing registration Nos.KL-15/587 and KL-15/9051, cannot be permitted to be used in any public place, installing multi-coloured LED lights inside the passenger compartments, on the edges of the safety glass fitted on the side windows and also in the wheel arches of the said vehicles. As evident from the screenshots extracted hereinbefore at paragraph 4 (at page 4), the use of such vehicles in a public place, which are fitted with ‘RGB’ colour changing decorative LED lights, emitting red, green and blue light in the passenger compartments and on the edges of the safety glass fitted on the side windows, etc., without complying with the provisions under the Central Motor Vehicles Rules and the relevant safety standards is likely to endanger the safety of other road users. 45. The learned Special Government Pleader and also the learned Standing Counsel for KSRTC would submit that in view of the specific observation made by this Court in paragraph 20 of the order dated 27.01.2025 in this writ petition that the use of such a vehicle in a public place posing threat to the safety of other road users will be in violation of the law laid down by the Apex Court and this Court in the decisions referred to in that order, the decorative LED lights were removed from the double-decker buses in terms of G.O.(Ms.)No.501/2024/Trans. dated 28.12.2024 and the said vehicles are now fitted with lighting, light-signalling devices and retro reflectors as per the requirements of the Central Motor Vehicles Rules and the relevant safety standards. 46. The aforesaid submission made by the learned Special Government Pleader and the learned Standing Counsel for KSRTC is recorded. 47. The Motor Vehicles (Driving) Regulations, 2017 made by the Central Government, in exercise of the power conferred by Section 118 of the Motor Vehicles Act, and in supersession of the Rules of the Road Regulations, 1989, was notified vide G.S.R.634(E) dated 23.06.2017. 48. Regulation 3 of the Motor Vehicles (Driving) Regulations, which deals with duty towards other road users and general public, provides that no vehicle shall be driven, stopped or parked on a road or in a public place in such a manner as is likely to endanger the safety of or cause inconvenience to other road users. 49. Regulation 5 deals with duties of drivers and riders. 49. Regulation 5 deals with duties of drivers and riders. As per clause (3) of Regulation 5, the driver shall at all times maintain a good lookout and concentrate on the road and traffic and avoid any activity which distracts or is likely to distract his attention. As per clause (5) of Regulation 5, the driver shall ensure that his vehicle, while moving or when stationary, does not cause any hindrance or undue inconvenience to other road users or to the occupants of any properties. As per clause (6) of Regulation 5, the driver shall ensure that his view is not obstructed and his hearing is not impaired by passengers, animals, load, equipment in the vehicle or by the conditions of the vehicle. As per clause (10) of Regulation 5, the driver shall ensure that loud music is not played in the vehicle. As per clause (11) of Regulation 5, the driver shall not watch digital motion pictures or videos while driving, except where required for route navigation. 50. Regulation 26, which deals with a bar on traffic impairment. As per Regulation 26, unless validly permitted by the competent authority under the Act or the rules made thereunder, no driver shall (i) offer goods or services of any kind on the road; or (ii) display any advertisement on the vehicle. 51. Regulation 31 deals with vehicle lighting. As per sub- regulation (1) of Regulation 31, the driver shall use the specified lighting devices at nightfall and at dawn, and at other times when visibility is poor. As per sub-regulation (2) of Regulation 31, the lighting devices of a vehicle shall at all times be kept in good working condition, and no lighting device shall be obscured by any object or dirt. As per sub-regulation (5) of Regulation 31, the driver shall switch on the fog light headlamps only when visibility is considerably affected due to fog, dust, storm, rain or snow, and only with dipped headlamps. 52. Regulation 36 deals with registration plates. As per sub-regulation (1) of Regulation 36, no vehicle shall be driven or parked on a public road without displaying registration plates as prescribed by the Act and the rules made thereunder. 52. Regulation 36 deals with registration plates. As per sub-regulation (1) of Regulation 36, no vehicle shall be driven or parked on a public road without displaying registration plates as prescribed by the Act and the rules made thereunder. As per sub- regulation (2) of Regulation 36, the registration plates on the front and at the rear of the vehicle shall be clearly visible and legible, and no object whatsoever or dirt shall obstruct clear view of the entire registration plate. As per sub-regulation (3) of Regulation 36, no letter, word, figure, picture or symbol other than the registration number shall be displayed or inscribed or written on the registration plates. As per Sub-regulation (4) of Regulation 36, no load or other goods shall be placed on a motor vehicle in such manner as to fully or partly hide the registration plate. 53. In view of the provisions under Regulation 3 of the Motor Vehicles (Driving) Regulations, no vehicle shall be driven, stopped or parked on a road or in a public place in such a manner as is likely to endanger the safety of or cause inconvenience to other road users. As per clause (3) of Regulation 5, the driver shall at all times maintain a good lookout and concentrate on the road and traffic and avoid any activity which distracts or is likely to distract his attention. As per clause (10) of Regulation 5, the driver shall ensure that loud music is not played in the vehicle. As per clause (11) of Regulation 5, the driver shall not watch digital motion pictures or videos while driving, except where required for route navigation. As per sub-regulation (1) of Regulation 31, the driver shall use the specified lighting devices at nightfall and at dawn, and at other times when visibility is poor. 54. In W.P.(C)No.295 of 2012 filed under Article 32 of the Constitution of India, by a public-spirited citizen, seeking enforcement of road safety norms and appropriate treatment of accident victims, the Apex Court constituted a ‘Committee on Road Safety’, vide its order dated 22.04.2014, and notified by the Ministry of Road Transport and Highways, Government of India, on 30.05.2014. In the said writ petition the Apex Court delivered a judgment dated 30.11.2017 - S. Rajaseekaran v. Union of India [ (2018) 13 SCC 516 ] . In the said writ petition the Apex Court delivered a judgment dated 30.11.2017 - S. Rajaseekaran v. Union of India [ (2018) 13 SCC 516 ] . In the said decision, the Apex Court observed that all States and Union Territories are expected to implement the Road Safety Policy with due earnestness and seriousness. The responsibility and functions of the Road Safety Council, constituted in terms of Section 215 of the Motor Vehicles Act will be as recommended by the Committee on Road Safety constituted as per the order dated 22.04.2014 and Road Safety Councils should periodically review the laws and take appropriate remedial steps whenever necessary. In paragraph 94.13 of the said decision, in the context of Lane Driving, the Apex Court held that the Ministry of Road Transport and Highways has already issued the Motor Vehicles (Driving) Regulations, 2017, vide G.S.R.634 (E) dated 23.06.2017, which should be implemented by the State Governments and Union Territories strictly. Paragraphs 94.1 to 94.25 of the said decision contain various directions issued by the Apex Court. In paragraph 95, the Apex Court has made it clear that if there is any doubt or clarity is required in implementing those directions, the State Government or Union Territory concerned is at liberty to move the Committee on Road Safety. 55. In the order in S. Rajaseekaran [2025 SCC OnLine SC 2191] , the Apex Court noticed widespread use of dazzling white LED headlights, unauthorised red-blue strobe lights, and hooters that mimic emergency sirens. High-intensity headlights, including those fitted in two-wheelers, cause temporary visual disorientation and glare for oncoming drivers, as well as pedestrians. Pedestrians face a momentary loss of spatial awareness, increasing the risk of being hit or tripping into roadside drains, pits, or other hazards. Drivers experience reduced reaction time, difficulty judging distances, and impaired lane discipline, particularly on narrow streets and highways, which heightens the likelihood of collisions. Therefore, the Apex Court ordered that a complete ban on unauthorized red-blue strobe flashing lights and illegal hooters shall be enforced through seizure, market crackdowns, and penalties. 56. Drivers experience reduced reaction time, difficulty judging distances, and impaired lane discipline, particularly on narrow streets and highways, which heightens the likelihood of collisions. Therefore, the Apex Court ordered that a complete ban on unauthorized red-blue strobe flashing lights and illegal hooters shall be enforced through seizure, market crackdowns, and penalties. 56. By the order dated 19.11.2025, the learned Special Government Pleader was directed to get instructions from the Transport Commissioner and also the State Police Chief as to whether any action is being taken to prevent videography by vloggers inside the driver compartment of moving contract carriages and even heavy goods vehicles and against the use of contract carriages, stage carriages and other motor vehicles on public place, openly flouting the safety standards in AIS-008 and AIS-052, posing threat to the safety of the passengers in such vehicles as well as other road users. In the said order, this Court noticed that, the rampant use of such vehicles on public place is evident from the promotional videos posted in YouTube and other social media platforms. Openly flouting the safety standards and the directions issued by this Court in various orders, DJ lights, laser lights, multi-colour LED lights are fitted inside the passenger compartment, in addition to high-power music system. Alternative power source with inverter and multiple batteries, etc., are also installed inside the luggage compartment of most of the contract carriages, posing a threat to the safety of the passengers. 57. Today, when this writ petition is taken up for consideration, we have viewed in open Court videos uploaded by vloggers on YouTube regarding the use of contract carriages as well as other motor vehicles, including goods carriage, in which videography takes place in the driver compartment of contract carriages and in the driver cabin of goods vehicles, while the vehicles are moving through public roads. The contract carriages are fitted with unauthorised lights and light signalling devices, flashlights, neon lights, ‘RGB’ colour changing decorative LED lights, emitting red, green and blue light, etc., on the bus body, passenger compartment and driver compartment. The passenger compartment of contract carriages is fitted with laser lights, DJ lights, continuously blinking multi-coloured LED lights, etc., in order to convert it into a dancing floor. The passenger compartment of contract carriages is fitted with laser lights, DJ lights, continuously blinking multi-coloured LED lights, etc., in order to convert it into a dancing floor. As is evident from the promotional videos uploaded by vloggers on YouTube, while the contract carriages are moving through public roads, including National Highways, the students, who are on a study tour, are dancing to loud music in the passenger compartment fitted with DJ lights, laser lights, etc. The contract carriages are even fitted with flashing neon/LED name boards on the top of the windscreen. The unauthorised lights fitted on the contract carriages and other motor vehicles are capable of dazzling the drivers of the oncoming vehicle, pedestrians, etc., thereby posing a potential threat to the safety of other road users. A few screenshots taken from some of the videos uploaded by vloggers on YouTube, which are viewed today in open Court, are extracted hereunder; 58. In one of the videos viewed in open Court, videography takes place inside the driver cabin of a heavy goods vehicle, while the vehicle was moving through a public road. While videography was going on, the goods vehicle was hit from behind by a stage carriage, resulting in severe damage to the front cowl of the stage carriage, which was carrying passengers. In that accident, the stage carriage was hit from behind by another goods vehicle. Three screenshots taken from that video clipping are extracted hereunder; 59. As already noticed hereinbefore, as per clause (3) of Regulation 5 of the Motor Vehicles (Driving) Regulations, 2017, the driver shall at all times maintain a good lookout and concentrate on the road and traffic and avoid any activity which distracts or is likely to distract his attention. As per clause (11) of Regulation 5, the driver shall not watch digital motion pictures or videos while driving, except where required for route navigation. 60. Registry to give a copy of the video clippings in a compact disc to the learned Special Government Pleader and also the learned Senior Panel Counsel, Government of India, who shall forward the same to the Transport Commissioner, Kerala and the concerned officer in the Ministry of Road Transport and Highways, dealing with road safety. Registry to keep a copy of the video clippings, in a compact disc, in the safe custody of Registrar (Judicial). 61. Registry to keep a copy of the video clippings, in a compact disc, in the safe custody of Registrar (Judicial). 61. The Transport Commissioner, Kerala, shall submit a report before this Court on the use of motor vehicles on public places, openly flouting the safety standards, as borne out from the video clippings, after obtaining reports (along with colour photographs of the vehicles and additional power source, if any, in the case of contract carriages) from the concerned Enforcement Officers in the Motor Vehicles Department. The details of the Educational institutions shall also be obtained from the concerned Educational Officers. The learned Senior Panel Counsel, Government of India, seeks time to get instructions from the concerned officer in the Ministry of Road Transport and Highways, dealing with road safety. 62. The learned Special Government Pleader would submit that after the order of this Court dated 19.11.2025 in this writ petition, the Transport Commissioner, Kerala, has issued a communication dated 20.11.2025 to all the Deputy Transport Commissioners, directing them to conduct a ‘Special Enforcement Drive’ for a period of two weeks. As per the said communication, a copy of which is made available for the perusal of this Court, ‘Special Enforcement Drive’ shall specifically cover, but not be limited to, the following violations; “1. Unauthorised fitment of name boards on motor vehicles. 2. Unauthorised fitment of lights and light-signalling devices on motor vehicles having more than three wheels, including quadricycles, trailers, and semitrailers, excluding agricultural tractors. 3. Unauthorised alteration of bus body design, contrary to approved specifications. 4. Unauthorised videography by vlogger's inside the driving compartment of moving contract carriages, stage carriages, and heavy goods vehicles. 5. Unauthorised use of dazzling LED headlamps, red/blue strobe lights, and unauthorised emergency hooters that mimic official/emergency sirens. 6. Unauthorised high-intensity headlamps installed or used in motor vehicles. 7. Unauthorised fitment of DJ lights, laser lights, multi- colour LED lights inside the passenger compartment 8. Use of High-power sound systems 9. Use of alternative power sources such as inverters, and additional batteries installed in luggage compartments.” 63. In view of the provisions contained in AIS-052, ‘cab lamp’ or ‘courtesy lamp’ fitted in the driver cabin above the head of the driver is for lighting up the dashboard area and the inside driver cabin, which is meant for operation while the bus is stationary [para 1.1.49]. In view of the provisions contained in AIS-052, ‘cab lamp’ or ‘courtesy lamp’ fitted in the driver cabin above the head of the driver is for lighting up the dashboard area and the inside driver cabin, which is meant for operation while the bus is stationary [para 1.1.49]. Similarly, ‘passenger area lamps’ provided in the passenger compartment are for lighting up the passenger area and assist the passenger in identifying objects and reading the printed matter [para 1.1.55]. The ‘driver cabin’ or ‘passenger compartment’ of a contract carriage or stage carriage governed by AIS-052 cannot be fitted with unauthorised multi- coloured LED lights, neon lights, laser lights, flashlights, etc., flouting the safety standards contained in AIS-052, in order to convert the passenger compartment into a dancing floor. 64. A contract carriage or stage carriage, which is fitted with unauthorised multi-coloured LED lights, neon lights, laser lights, flashlights, etc. in the ‘driver cabin’ or ‘passenger compartment’, flouting the safety standards contained in AIS-052, cannot be treated as a vehicle which complies with the provisions of the Motor Vehicles Act and the rules made thereunder, for the purpose of grant of certificate of fitness. 65. In view of the provisions contained in Rule 286 of the Kerala Motor Vehicles Rules, every vehicle shall be furnished with one or more electric lights adequate to give reasonable illumination throughout the passenger compartment or compartments, but of such power or so screened as not to impair the forward vision of the driver. As per the proviso to Rule 286 of the Kerala Motor Vehicles Rules, the internal lighting in buses that are registered on or after 01.10.2017 shall be in accordance with AIS-052 (Rev.1) - 2008 as amended from time to time. Therefore, even in the case of a contract carriage or stage carriage registered before 01.10.2017, the internal lighting for the purpose of providing reasonable illumination throughout the passenger compartment. Therefore, the passenger compartment of a contract carriage cannot be fitted with continuously blinking multi- coloured LED lights, laser lights, etc., in order to convert it to a dancing floor. 66. As per para 5.1 of AIS-008 (Rev.2) only those lighting and light signalling devices referred to in para 6.0 of the standard (AIS-008) shall be permitted to be installed on motor vehicles. 66. As per para 5.1 of AIS-008 (Rev.2) only those lighting and light signalling devices referred to in para 6.0 of the standard (AIS-008) shall be permitted to be installed on motor vehicles. As per clause 5.9.1 direction indicator lamps, vehicle hazard warning signal, amber side marker lamps complying with para 6.18.7 and the emergency stop signal shall be flashing lamps. As per para 5.15, which we have extracted hereinbefore at paragraph 34, the colours of the light emitted by the lamps fitted on motor vehicles, shall be as per the requirements of para 5.15, i.e., white, amber and red. Neon lights, laser lights, DJ lights, ‘RGB’ colour-changing decorative LED lights, emitting red, green and blue lights, strobe lights, flashing neon/LED name boards, etc., cannot be fitted on motor vehicles, including stage carriages, contract carriages and goods vehicles. A stage carriage or a contract carriage, which is fitted with such lights, flouting the safety standards in AIS-008, AIS-052, etc., or Rule 286 of the Kerala Motor Vehicles Rules (vehicles not governed by AIS-052), cannot be allowed to be used on any public place, since the use of such vehicles on any public place, openly flouting the safety standards, pose threat to the safety of the passengers in such vehicles and also other road users. 67. Having considered the submissions made by the learned Special Government Pleader and also the learned Senior Panel Counsel, Government of India, we deem it appropriate to direct the Enforcement Wing of the Motor Vehicles Department and the Police to ensure strict compliance of the directions contained in the order of this Court dated 04.10.2024 in this writ petition - Suo Motu v. Union of India [2024 SCC OnLine Ker. 6894] – in letter and spirit, to ensure the safety of road users, including pedestrians. A noticed by the Apex Court in S. Rajaseekaran [2025 SCC OnLine SC 2191] , widespread use of dazzling white LED headlights, unauthorised red-blue strobe lights, including those fitted in two-wheelers, cause temporary visual disorientation and glare for oncoming drivers, as well as pedestrians. Pedestrians face a momentary loss of spatial awareness, increasing the risk of being hit or tripping into roadside drains, pits, or other hazards. Pedestrians face a momentary loss of spatial awareness, increasing the risk of being hit or tripping into roadside drains, pits, or other hazards. In view of the prohibition contained in sub-rule (1) of Rule 92 of the Central Motor Vehicle Rules, no person shall use or cause or allow to be used in any public place a contract carriage or stage carriage flouting the safety standards contained in AIS-008, AIS-052. The fitness certificate of such a transport vehicle is liable to be cancelled, as per the procedure contemplated under sub-section (4) of Section 56 of the Motor Vehicles Act, since it no longer complies with all the requirements of the Motor Vehicles Act and the Rules made thereunder. In case of violation of the standards prescribed in relation to road safety, control of noise and air pollution, any person who drives or causes or allows to be driven, such a vehicle on a public place, shall also be proceeded against as per the provisions under sub-section (2) of Section 190 of the Act. In addition to the penal consequences provided in the Motor Vehicles Act, the owner of such a vehicle has to be imposed with a fine of Rs.5,000/- per such alteration; i.e., Rs.5,000/- for each unauthorised multi-coloured LED lights, neon lights, laser lights, flashlights, strobe lights, flashing neon/LED name boards, etc. fitted on the ‘exterior body’, ‘driver cabin’ and ‘passenger compartment’, in view of the provisions contained in sub-section (4) of Section 182A of the Motor Vehicles Act, read with S.R.O.No.788/2019 published in the Kerala Gazette Extraordinary No.2577 dated 26.10.2019. List this matter for further consideration on 08.12.2025.