Allahabad High Court Calls For Crowd Behaviour Science To Prevent Stampedes At Mathura-Vrindavan Religious Gatherings

The Allahabad High Court has held that the right to life under Article 21 of the Constitution casts a positive obligation on the State to create and maintain conditions in which lives are not lost to preventable disasters. It held that institutionalising the science of crowd behaviour in academia, administration and policy is a constitutional imperative.

The Court was hearing a writ petition against a demolition order in Mathura-Vrindavan, but expanded its scope to examine whether the district administration had any crowd and crisis management plan grounded in a scientific understanding of how crowds behave.

Justice Vinod Diwakar held,

“The right to life guaranteed under Article 21 of the Constitution of India is not fulfilled merely by the absence of active State violence; it imposes upon the State a positive obligation to create and maintain conditions in which human life is not lost to preventable disasters arising from the State's own administrative and intellectual unpreparedness. The institutionalization of crowd behaviour science- in academia, in administration, and in policy- is a constitutional imperative that this Court urges the State Government to act upon with the seriousness, urgency, and commitment that it deserves.”

Petitioner, Swami Shiv Swarupanand Ji Maharaj, claimed to own 167.22 square meters land in Village Vrindavan Khaddar, District Mathura. His building plan for an Ashram was disapproved by the Mathura Vrindavan Development Authority as the plot fell in a flood-affected area. He raised the construction anyway, and the Authority passed a demolition order under Sections 27(1), 28(1) and 28(ii) of the U.P. Urban Planning and Development Act, 1973. His appeal under Section 27(iv) was dismissed by the Commissioner, Agra Division, Agra on 04.09.2025.

Before the High Court, the petitioner argued that the action was arbitrary, amounting to “pick and choose”, as demolition orders had been passed against 23 persons but executed only against him and a few others.

Recording that Mathura had witnessed stampede-like crowd crush during pre-Holi events and other occasions, and that unauthorised construction had obstructed rescue and emergency operations, the Court directed the District Magistrate, the Municipal Commissioner and the SSP to disclose whether a crowd and crisis management plan existed, whether any expert body studied crowd behaviour, and whether any scientific study had been commissioned on the subject.

In response, the administration placed on record coordination meetings, one-way routing and barricading, separate entry and exit gates at the Banke Bihari Temple, extended darshan hours, CCTV, five traffic zones in Vrindavan, and a ten-year master plan. The Court held that it had never set out to test the efficacy of traffic plans; its concern was whether crowd management in Mathura rested on the science of crowd behaviour. On the affidavits, it found that no such study had ever been commissioned, conducted or even consulted.

The Court identified three systemic failings: a master plan prepared for only ten years, crowd management reduced to little more than traffic management, and crowd crush attributed chiefly to narrow lanes and unauthorised construction, which it treated as symptoms of a deeper planning failure. Contrasting Mathura with Chandigarh, New Delhi and Jaipur, it said it was deeply shocked that a pilgrimage city of over a thousand years of heritage had a plan expiring in a decade.

“A city that is eternal in its religious significance cannot be governed by a planning document that expires in a decade. The temporal inadequacy of the master plan is not a technical oversight- it is a governance failure of the first order.”

The Court observed that the crowds converging on Mathura are drawn by faith rather than political passion or competitive excitement and are in that sense self-regulating, but their devotional state and tendency to move in unison during rituals leave them peculiarly exposed to sudden surges in density.

“To equate the two- as administrative practice in this country has long tended to do- is not merely academically imprecise; it is administratively dangerous, because it leads to the application of crowd control strategies designed for adversarial or unruly gatherings to assemblies that are inherently peaceful and cooperative in their orientation, thereby generating unnecessary friction, confusion, and, in extreme cases, panic.”

Noting that no structured curriculum on crowd behaviour exists in any university in Uttar Pradesh or across most of India, the Court recommended that State universities introduce courses on crowd flow dynamics and density modelling, crowd risk assessment, crowd management policy and law, and case studies in crowd disasters. It also recommended a Center of Excellence for Crowd Science, Mass Gathering Safety, and Urban Risk Management, mandatory engagement of certified crowd behaviour experts at the planning stage of every major public gathering, and a statutory commission for the State on the lines of the Delhi Urban Art Commission constituted under the Delhi Urban Art Commission Act, 1973.

On merits, the Court disposed of the petition with liberty to the petitioner to approach the Development Authority afresh, which shall decide in the light of the circulars issued by the State Government in compliance with the Supreme Court's order dated 13.11.2024 in Writ Petition (Civil) No. 295 of 2022, In Re: Directions in the matter of demolition of structures and others. The impugned order was kept in abeyance meanwhile.

Case Title: Swami Shiv Swarupanand Ji Maharaj vs. State of U.P. & 3 Others 2026 LiveLaw (AB) 514

Case citation: 2026 LiveLaw (AB) 514

Counsel for Petitioners :- Dharmendra Kumar Gupta, Kiran Gupta

Counsel for Respondents :- Harsh Vardhan Gupta

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