Mandatory policy of producing minimum three pre-survey challans for street vendor certification held valid.

The Petitioners are street vendors who sought to be included in the list of authorized vendors within the Delhi Cantonment Board area.

The TVC (Town Vending Committee) of the Board passed Resolution No. 3 on 27th January 2026, establishing a eligibility criterion: vendors must produce at least three challans issued by the Board prior to the survey commencement date of 27th October 2023

While some vendors were included after scrutiny, the Petitioners’ applications were rejected because they produced fewer than three challans or challans dated after 2023

The Petitioners challenged these rejections, arguing that even one or two challans proved their prior presence

1. Whether the criteria requiring at least three challans issued prior to 27th October 2023 for inclusion in the street vendor list is legally valid and enforceable

2. Whether vendors who fail to meet the "three challan" policy threshold can be mandated for inclusion as authorized vendors at this stage

The Court applied the principle of judicial restraint regarding policy decisions made by statutory bodies like the Town Vending Committee (TVC) under the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act.

The TVC is empowered to draw up vending plans based on site capacity, pedestrian safety, and vehicular traffic flow

The Court relied on its own precedents in Gyan Chand v. Delhi Cantonment Board [p. 4, para. 6] and Danveer Yadav v. Delhi Cantonment Board [p. 5, para. 8], which upheld the Board's specific 15th January 2026 policy resolution regarding the "three challan" evidentiary requirement

The Court reasoned that the determination of eligibility criteria—specifically the quantity and timing of challans—is a policy decision aimed at balancing vendor rights with public space management

Upon reviewing the TVC’s minutes from April 2024, the Court found that the Board had conducted a fair and detailed scrutiny of documents

The Court rejected the Petitioners' argument that one or two challans should suffice, holding that such a relaxation would undermine the established policy

The Court emphasized that for a vendor to be "authorized," they must strictly adhere to the TVC's verified evidentiary standards to ensure the holding capacity of the zone is not exceeded

However, the Court directed that if excess capacity remains after the final vending plan is implemented, those with fewer than three challans may be considered in the next survey cycle

The Delhi Cantonment Board was granted liberty to take action against any unauthorized vendors in accordance with law