Vending list inclusion requires three pre-survey challans subject to holding capacity and survey timelines.

The Petitioner, claiming to be a street vendor near Delhi Cantonment Metro Station, sought a direction to the Respondents to include his name in the list of eligible street vendors under the Street Vendors Act, 2014, and the Delhi Street Vendors Scheme, 2019

The Petitioner asserted he possessed three challans issued prior to the commencement of the official survey on October 27, 2023

He relied on a Town Vending Committee (TVC) resolution dated January 15, 2026, which stipulated that vendors with three such challans would be considered for inclusion

Despite submitting a representation on May 8, 2026, the Petitioner remained excluded from the survey list

1. Whether the Petitioner is entitled to retrospective inclusion in the list of authorized street vendors after the survey has been finalized

2. Whether the production of three challans prior to the cut-off date creates an absolute right to be surveyed regardless of the timing of the application

The Court applied the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014, and the Delhi Street Vendors Scheme, 2019

Delhi Cantonment Board’s Resolution No. 3 dated January 27, 2026 (based on the TVC minutes of January 15, 2026), which established a qualifying criterion: vendors must produce at least three challans issued by the Board prior to October 27, 2023, subject to the area's holding capacity

Doctrine derived from Gyan Chand v. Delhi Cantonment Board and Danveer Yadav v. Delhi Cantonment Board, which upheld the "three-challan" policy as a reasonable basis for verification and inclusion

The Court observed that while the Petitioner claimed to meet the "three-challan" threshold established in the TVC minutes dated January 15, 2026, he approached the Court "extremely belatedly"

The Court noted that the Delhi Cantonment Board had already completed its survey and finalized the list of authorized vendors following a rigorous scrutiny process; referring to Dinesh v. Delhi Cantonment Board, the Court reasoned that the survey process cannot be reopened once concluded to prevent administrative instability

The Court acknowledged that the Petitioner’s claim regarding the three challans warrants verification by the TVC to determine potential eligibility for future vacancies or subsequent surveys

The Court directed the TVC to consider and dispose of the Petitioner’s representation in accordance with the law and the criteria set in the January 15, 2026 minutes; if the Petitioner is found to have the requisite challans, he may be considered in the next survey or if excess vending capacity becomes available

The petition was disposed of with these directions