Maniyar Iliyaz @ Shaik Riyaz & Anr. v. P. Ayyappan & Ors., 2026 INSC 647, is a landmark judgment delivered by the Supreme Court of India on 19 June 2026 by a Bench comprising Justice Pamidighantam Sri Narasimha and Justice Atul S. Chandurkar. While the case originated as a motor accident compensation dispute involving the tragic death of a minor pedestrian, the Court treated the matter as presenting significant constitutional questions concerning pedestrian safety and the obligations of public authorities. Moving beyond the determination of compensation under the Motor Vehicles Act, 1988, the Court examined whether the ability to walk safely on public roads, including access to properly demarcated and maintained footpaths, constitutes a fundamental right protected under Articles 19(1)(a), 19(1)(b), 19(1)(c), 19(1)(d), and 21 of the Constitution of India. Recognising the systemic deficiencies in pedestrian infrastructure across the country, the Court held that the right to walk is inseparable from the freedoms of movement, expression, assembly, association, and the right to life with dignity. It further declared that this constitutional right imposes a corresponding duty upon municipal authorities, urban development bodies, panchayats, and other governmental agencies to construct, maintain, and safeguard safe pedestrian infrastructure. The Court also clarified that violations of this right may give rise to constitutional remedies, including claims for compensation, independent of statutory remedies available under the Motor Vehicles Act. In view of the wider public importance of the issue, the Court directed that the proceedings be renumbered as "Re: Fundamental Right to Walk and Footpath" for continued consideration of the broader constitutional questions, making the decision a significant milestone in India's constitutional, public law, urban governance, and road safety jurisprudence.

Legal Issue

Whether the right to walk safely on public roads, including access to demarcated footpaths, forms part of the fundamental rights guaranteed under Part III of the Constitution, and whether public authorities have a corresponding obligation to provide and maintain pedestrian infrastructure.

Brief Facts

The case arose from a motor accident claim involving the death of a minor pedestrian. While considering the compensation payable, the Supreme Court examined broader concerns relating to pedestrian safety and the absence of adequate footpath infrastructure. The Court treated the matter as raising important constitutional questions concerning the rights of pedestrians and the obligations of public authorities responsible for urban and road planning.

Court's Reasoning

The Court held that walking is the most basic form of human movement and is intrinsically connected with the freedoms guaranteed under Articles 19 and 21 of the Constitution. It observed that the ability to move safely on public roads cannot be meaningful unless pedestrians are provided with adequate and protected infrastructure. The Court reasoned that constitutional rights must be accompanied by corresponding public duties. Consequently, if citizens possess a right to walk safely, urban development authorities, municipal bodies, panchayats and other governmental agencies are under an obligation to create, maintain and protect footpaths and pedestrian facilities. The absence of such infrastructure directly affects the exercise of fundamental freedoms and the right to life.  Recognising the systemic nature of the issue, the Court clarified that violations of pedestrian rights may give rise to constitutional remedies independent of claims available under the Motor Vehicles Act. It therefore expanded the scope of the proceedings beyond an individual compensation dispute and framed the issue as one concerning public rights and governmental accountability.

Judgment

The Court enhanced the compensation payable to the claimants and, more significantly, declared that the right to walk is a fundamental right flowing from Articles 19(1)(a), 19(1)(b), 19(1)(c), 19(1)(d) and 21 of the Constitution. The right includes access to demarcated and safe footpaths, which must receive priority over motorised traffic. Public authorities have a corresponding duty to construct, maintain and safeguard pedestrian infrastructure. Citizens may seek constitutional and legal remedies, including compensation, for violations of this right independent of remedies under the Motor Vehicles Act. The Court also directed the Registry to renumber the matter as "Re: Fundamental Right to Walk and Footpath" and continue consideration of the larger constitutional issues.

Legal Significance

The judgment marks a significant expansion of pedestrian rights jurisprudence by expressly recognising a fundamental right to walk and access safe footpaths. It transforms pedestrian infrastructure from a matter of urban policy into a constitutional obligation and creates a direct accountability framework for public authorities responsible for road and urban planning.

Access the Official Judgement here

Case Title

MANIYAR ILIYAZ @ SHAIK RIYAZ & ANR. VERSUS P. AYYAPPAN & ORS.

Neutral Citation

2026 INSC 647

Court

Supreme Court of India

Bench

Justice Pamidighantam Sri Narasimha and Justice Atul S. Chandurkar

Date of Judgment

19 June 2026