Single Entry-Exit Doors In Buses 'Compromise Safety': MP High Court Directs Transport Authority To Enforce Two Doors Rule

The Madhya Pradesh High Court has directed the Regional Transport Authority to ensure all stage carriages and tourist buses comply with Rule 164 of M.P. Motor Vehicle Rules, mandating separate entry and exit doors, within a period of 45 days.

The bench of Justice Vivek Jain made a strong observation on systematic non-compliance with safety norms;

"...it is a very sorry state of affairs that many airconditioned buses, and even non- airconditioned luxury buses and sleeper buses, are not having two doors on left and an additional emergency door... A large number of lives and properties are being lost in fire accidents involving luxury buses is well known. The height of laxity is that the State has not ensured two gates on left side on almost any of the said vehicles, and permits are being issued indiscriminately".

Therefore, invoking its jurisdiction under Article 227 of the Constitution, the court directed,

"Therefore, the respective Road Transport Authorities are directed to enquire as to whether there is violation of Rule- 164 of M.P. Rules on any of the Stage carriages and Tourist buses in the State registered prior to 05.1.2012 i.e. when the amended Rule 164 was enforced, and if any of the buses is found violating Rule 164, then its operation shall be stopped within 45 days from today, till it complies Rule 164".

The petition challenged an order of the State Transport Appellate Tribunal (STAT), which had allowed a revision filed by a rival operator (respondent no 2) and cancelled the petitioner's permit.

The counsel for the petitioner argued that respondent no 2 had no locus to challenge the grant of the permit, as respondent no 2 became a route operator only on May 5, 2025, whereas the petitioner had already lifted the permit on May 2, 2025. Therefore, the respondent no 2 was not a rival route operator and had no locus to object to the grant of the permit.

The counsel for the Regional Transport Authority argued that although the permit had been lifted on May 2, 2025, the application for the permit was filed by the respondent no 2 before the petitioner. The respondent no 2 grant order was passed much prior to the grant order of the petitioner.

The bench held that the question of locus was not determinative as the cancellation of the permit was justified on statutory non-compliance. It was noted that the petitioner's vehicle failed to meet the requirements under Rule 77 (1-A) of M.P. Motor Vehicle Rules, 1994, which defines a Deluxe Air Conditioned Bus. The rule mandates a minimum seating capacity of 35+ 2 ( including driver and conductor).

The petitioner's bus had only 36 seats in total, falling short of the prescribed requirement. Rejecting the contention that a conductor was not mandatory, the court held that Rule 77 explicitly requires a provision for a conductor.

The court further observed that under Rule 164 every carriage should have at least two doors on the left side, one for entrance and one for exit, and there should be an emergency door on the right or back side. The bench noted that in the present case, the bus only had one entry and an emergency door.

In the present case, the bus had only a single-entry-cum-exit door, raising concerns of non-compliance.

Without delving deeper into the Rule 164 violations, the court held that the permit itself had been granted in violation of Rule 77, as the vehicle did not meet the minimum requirement. Accordingly, it found no reason to interfere with STAT's order, cancelling the permit.

The bench noted that having two doors raises practical concerns, but held that the doors are necessary in case of accidents and fire incidents.

The bench further highlighted, "It may be a situation that given one conductor, it may be difficult to control two doors, or it may result into loss of two seats. Be that as it may be, it is for the bus owner to take a decision as to the manner in which the doors are to be operated and he will get profitability, but a single door seriously compromises lives and properties carried in buses at the time of accidents and fire incidents".

The bench further emphasised that commercial considerations cannot override passenger safety, and therefore the court directed the RTA to enquire whether there is a violation of Rule 164 by any stage carriages and tourist buses in the State and if any buses are found violating, then their operation shall be stopped within 45 days from today.

The matter was listed for April 27, 2026.

Case Title: Ram Milan Rai v Regional Transport Authority [MP-5921-2025]

For Petitioner: Advocate Ashish Rawat

For State: Advocate Mayur Gulati

For respondents: Advocate Brajesh Kumar Dubey

Click here to read/download the Order