Delhi High Court

Vendors failing to timeously produce the required three challans for survey inclusion may be considered only in future surveys.

Devender vs Delhi Cantonment Board And Anr.

Delhi High CourtJUDGMENT: May 29, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, claiming to be a street vendor at Dhaula Kuan since 2014, sought a direction to the Delhi Cantonment Board (DCB) to include his name in the list of eligible street vendors

Source reference: para. 2–3

He claimed to possess three challans issued prior to October 27, 2023, which was the cutoff date established by the Town Vending Committee (TVC) in its meeting on January 15, 2026

Source reference: para. 3–4

The DCB had previously resolved that only vendors providing at least three challans prior to the survey commencement date would be considered, subject to holding capacity

Source reference: para. 4–5

By the time this petition was heard, the DCB had already completed the scrutiny of vendors and finalized the list based on prior court directions in similar matters like Gyan Chand v. DCB and Dinesh v. DCB

Source reference: para. 7–9
02

Issues

1. Whether the Petitioner is entitled to be included in the list of authorized street vendors after the survey and scrutiny process has been finalized by the TVC.

Source reference: para. 10

2. Whether vendors with the requisite number of challans who approach the Court belatedly can compel the reopening of a concluded survey.

Source reference: para. 10–11
03

Law Applied

Policy decision formulated by the TVC in Resolution No. 3 dated January 27, 2026, which mandated the production of at least three challans issued by the DCB prior to October 27, 2023, for inclusion in the street vendor list

Source reference: para. 4

Precedent in Dinesh v. Delhi Cantonment Board & Ors. [W.P.(C) 7270/2026], which held that vendors failing to meet the three-challan criteria or those approaching the Court after the finalization of the vending plan cannot fault the rejection of their candidature

Source reference: para. 9

The principles of finality in administrative surveys and the "holding capacity" limitations of vending zones

Source reference: para. 5, 11
04

Reasoning

The Court noted that the TVC had already undertaken an extensive scrutiny exercise, as evidenced by the minutes of the meeting dated April 24, 2026, where candidates were either accepted or rejected based on documented proof

Source reference: para. 9

Although the Petitioner claimed to possess the three requisite challans, the Court observed that he approached the Bench "extremely belatedly"

Source reference: para. 10

Relying on the reasoning in the Dinesh case, the Court held that since the list of authorized vendors had already been drawn up and the survey completed, the process could not be reopened for individual latecomers

Source reference: para. 10

The Court emphasized that the TVC's decision-making was "properly done" and that the eligibility criteria were applied uniformly to maintain the holding capacity of the vending zones

Source reference: para. 9
05

Holding

The Court dismissed the Petitioner’s request for immediate inclusion, holding that the survey cannot be reopened at this late stage

The Court directed that if any excess capacity remains after the TVC finalizes the vending plan, the Petitioner’s claim (based on his three challans) may be considered during the next survey cycle

Source reference: para. 11

The petition was disposed of with the clarification that the DCB remains free to take action against any unauthorized vendors in accordance with the law

Source reference: para. 9, 12
Delhi High Court

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DevendervsDelhi Cantonment Board And Anr.

Delhi High Court · May 29, 2026

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