After Mathura crowd-crush concerns, Allahabad High Court recommends UP Centre of Excellence for crowd science and mass-gathering safety

The petitioner claimed ownership and possession of a 167.22 sq. metre property in Village Vrindavan Khaddar, Mathura, on which he proposed to construct an ashram.

The Mathura Vrindavan Development Authority (MVDA) rejected the building plan on the ground that the property was situated in a flood-affected area where permanent construction was impermissible.

Despite the rejection, the petitioner raised construction, leading the MVDA to pass a demolition order under Sections 27(1), 28(1) and 28(ii) of the Uttar Pradesh Urban Planning and Development Act, 1973.

The petitioner’s statutory appeal under Section 27(iv) was dismissed by the Commissioner, Agra Division, on 4 September 2025.

The petitioner alleged discriminatory “pick and choose” enforcement, asserting that demolition orders had been issued against 23 properties but executed only against him and certain other property owners.

The High Court directed the MVDA to disclose the status of all 23 demolition proceedings, its enforcement data for the preceding five years, and its policy framework for controlling unauthorized constructions.

In view of recurring crowd-crush and stampede-like incidents in Mathura and Vrindavan, the Court expanded the scope of the proceedings and sought affidavits from the District Magistrate, Municipal Commissioner and Senior Superintendent of Police regarding crowd and crisis management, expert bodies, scientific studies, inter-agency coordination and public-safety measures.

The MVDA disclosed that, between 2021–22 and 2025–26, it issued 2,453 notices, passed 700 demolition orders, executed 323 demolitions, sealed 104 properties and accepted 212 applications for compounding.

The District Magistrate and SSP relied primarily on traffic-diversion plans, barricading, CCTV surveillance, vehicle restrictions, parking arrangements, emergency routes and departmental coordination measures.

The Court found that the authorities had undertaken considerable preparatory work but had not demonstrated that their crowd-management systems were based on scientific studies or a sustained institutional understanding of crowd behaviour.

Whether the petitioner’s challenge to the demolition order and appellate order could be sustained on the ground of discriminatory or selective enforcement of the law against unauthorized constructions.

Whether the MVDA was required to reconsider the petitioner’s demolition proceedings in light of the State Government circulars issued pursuant to the Supreme Court’s directions concerning demolition of structures.

Whether the district administration and statutory authorities had an adequate, comprehensive and scientifically grounded plan for managing crowds and preventing crowd-crush incidents in Mathura and Vrindavan.

Whether crowd behaviour science should be institutionally integrated into academic programmes, urban planning, development control, building bye-laws and the management of major public gatherings.

The Court applied Sections 27(1), 28(1), 28(ii) and 27(iv) of the Uttar Pradesh Urban Planning and Development Act, 1973, which empower the development authority to proceed against unauthorized constructions and provide a statutory appellate remedy.

It also relied on the Supreme Court’s order dated 13 November 2024 in Re: Directions in the Matter of Demolition of Structures and Others, and the consequential State Government circulars dated 15 January 2025, 17 January 2025 and 25 April 2026, requiring procedural safeguards and fresh compliance before demolition.

The Court invoked Article 21 of the Constitution, holding that the right to life includes a positive obligation upon the State to maintain conditions protecting citizens and pilgrims from preventable disasters.

Its broader reasoning drew upon contemporary crowd-science principles concerning crowd density, flow velocity, pedestrian movement, collective behaviour, risk assessment and emergency evacuation, including the work associated with Gustave Le Bon, John Fruin and G. Keith Still.

The Court further held that crowd management must extend beyond traffic control and barricading to evidence-based, multidisciplinary and research-informed planning.

The Court did not finally determine that the petitioner was entitled to retain the unauthorized construction or that the MVDA’s enforcement action was conclusively discriminatory.

Instead, it noted that the demolition proceedings concerning the 23 properties had been affected by pending compounding applications, appeals, jurisdictional issues and the newly issued State Government circulars.

Consequently, the petitioner was granted liberty to approach the MVDA afresh, which was required to reconsider the matter in conformity with the applicable circulars.

On the expanded public-safety issue, the Court distinguished traffic management from crowd-behaviour analysis.

Although the authorities had prepared routing plans, imposed vehicle restrictions, installed barriers and undertaken infrastructure works, the affidavits did not establish that the administration had commissioned or used scientific studies, computational models or specialized behavioural research concerning religious crowds in Mathura and Vrindavan.

The Court reasoned that religious crowds possess distinct behavioural characteristics and may become vulnerable to dangerous density and spatial constriction even without an external trigger.

It therefore treated the absence of institutionalized crowd research as a serious governance deficiency and recommended permanent multidisciplinary expertise, academic programmes, a Centre of Excellence, expert consultation for major gatherings, and incorporation of crowd-safety principles into planning and building regulations.

The petitioner was granted liberty to approach the MVDA afresh with his grievances, and the MVDA was directed to take a decision in accordance with the State Government circulars dated 15 January 2025, 17 January 2025 and 25 April 2026, issued pursuant to the Supreme Court’s order dated 13 November 2024.

Pending such reconsideration, the Commissioner’s order dated 4 September 2025 was directed to remain in abeyance.

The Court also recorded recommendations urging the State Government and relevant institutions to institutionalize crowd-behaviour science through academic courses, a Centre of Excellence, mandatory engagement of qualified crowd-safety experts for major gatherings, and integration of crowd-safety norms into master plans, development regulations and building bye-laws.

A copy of the judgment was directed to be transmitted to the Chief Secretary, the relevant higher-education authorities and the University Grants Commission for future reference and necessary consideration.