Vending survey inclusion remains subject to prescribed documentary criteria and established holding capacity limits.

The Petitioner, a street vendor operating near Delhi Cantonment Metro Station, sought a direction to the Respondents to include her name in the list of eligible street vendors

She claimed eligibility based on possessing three challans issued prior to the commencement of the statutory survey on October 27, 2023

The Petitioner relied on a Town Vending Committee (TVC) resolution dated January 15, 2026, which established a three-challan criterion 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 mandatory inclusion in the current list of street vendors based on the three-challan policy, notwithstanding the completion of the survey

2. Whether the TVC is obligated to consider belated representations for inclusion after the authorized vendor list has been finalized

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

Resolution No. 3 of the Delhi Cantonment Board dated January 27, 2026 (based on TVC minutes dated January 15, 2026), which mandated that only vendors producing at least three challans issued prior to October 27, 2023, would be considered for inclusion, subject to holding capacity

Gyan Chand v. Delhi Cantonment Board

Dinesh v. Delhi Cantonment Board, which upheld the three-challan threshold as a valid policy for verifying long-term vending

The Court observed that while the Petitioner claimed to meet the three-challan criteria, she approached the Court "extremely belatedly"

By the time of the hearing, the Delhi Cantonment Board had already completed its comprehensive survey and finalized the list of authorized vendors

The Court reasoned that the survey process cannot be reopened indefinitely to accommodate late entrants, as this would disrupt the finalized vending plan

The Court maintained that the Petitioner’s right to be considered is not extinguished but deferred; if excess vending capacity exists after the current plan's execution, those with the requisite challans who applied late can be accommodated in the subsequent survey cycle

It directed the Town Vending Committee to consider and dispose of the Petitioner’s representation dated May 8, 2026, in accordance with the law and the criteria set in the January 15, 2026 meeting minutes

The Petitioner may be considered for inclusion in the "next survey" should there be any excess holding capacity after the current vending plan is finalized

The petition was disposed of with these directions