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Regulating The Streets - Analysis Of The Legal Framework Governing Street Vending In India

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REGULATING THE STREETS: ANALYSIS OF THE LEGAL

FRAMEWORK GOVERNING STREET VENDING IN INDIA

Nidhi Thakur, Research Scholar, Department of Law, Himachal Pradesh University, Shimla (HP) Dr. Rajinder Verma, Professor, Research Scholar, Department of Law, Himachal Pradesh University, Shimla (HP)

ABSTRACT

Around the world, street vendors play a crucial role in urban economies by providing convenient access to a variety of products and services in public areas. Despite being viewed as informal, street vendors play a crucial role in urban economies. Selling items on the street is how millions of people in India make a living. They were not really protected by the law for a very long time. Instead of treating them as employees with rights, it viewed them as a problem to be solved. The courts started to gradually alter this over many years. They asserted that street vendors are entitled to employment and a living wage. The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act,2014 was eventually passed by Parliament to safeguard them. This article looks at how this right grew, first through the Constitution and the courts, and then through this new law.

Keywords: street vendors, urban economy, informal, rights.

INTRODUCTION

In India's urban economy, street vending is one of the most prominent and vital elements. Millions of people, especially those with limited access to formal employment, rely on street vendors to make ends meet by offering reasonably priced goods and services in both tiny villages and busy metropolitan areas. Whether they are selling prepared food, clothing, books, fresh vegetables, or household goods, these vendors are crucial to maintaining the availability of everyday essentials and enhancing the energy of city life. Street sellers have generally been perceived as intruders on public areas rather than as legitimate players in urban development, despite their economic and social significance. They have consequently frequently experienced harassment, forced evictions, property confiscation, and legal uncertainty1.

The struggle between the necessity for planned urban planning and people's right to make a living through street vending has become more intense in India due to the country's fast urbanization. Infrastructure development, traffic control, and beautification initiatives are often given first priority by municipal officials, often at the expense of informal workers who rely on public areas to survive2. This conflict is a reflection of a larger problem in urban governance: striking a balance between social fairness, economic inclusion, and public order. Therefore, street vending is not just a matter of controlling public areas; it is also a matter of upholding constitutional rights, encouraging inclusive cities, and acknowledging the role that the informal sector plays in the advancement of the country.

Over the past few decades, there has been a considerable change in the legal status of street sellers. At first, street vendors were subject to arbitrary administrative action because street peddling was primarily regarded by municipal authorities as an illegal business. 3 By acknowledging that the right to conduct business under Article 19(1)(g) of the Indian Constitution includes the right to engage in street vending, subject to reasonable restrictions in the public interest, judicial intervention played a crucial role in changing this legal position. The Supreme Court upheld that street sellers cannot be stripped of their livelihood without fair and reasonable regulating methods through a series of historic rulings4.

1 Sharit K. Bhowmik, Street Vendors in the Global Urban Economy (Routledge 2010).

2 Ministry of Housing and Urban Affairs, National Policy on Urban Street Vendors, 2009 (Government of India 2009). 3 Sharit K. Bhowmik, 'Street Vendors in Asia: A Review' (2005) 40(22–23) Economic and Political Weekly 2256. 4 Sodan Singh v New Delhi Municipal Committee (1989) 4 SCC 155; Gainda Ram v Municipal Corporation of

As a result of these judicial developments The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014, was eventually passed, which signalled a paradigm shift from a punitive regulatory approach to a rights-based legal framework. 5 Through participatory organizations like Town Vending Committees, the Act aims to protect street vendors' livelihoods while creating an institutional framework for vending activity regulation. By encouraging stakeholder involvement, transparent vending space distribution, and protection from arbitrary eviction, it exemplifies the ideas of inclusive urban governance6. This study examines the legal framework governing street vending in India.

It analyses the constitutional foundations of vendors' rights, the evolution of judicial interpretation, the statutory framework established under the 2014 Act, and the practical challenges encountered in its implementation.

MEANING OF STREET VENDING

Street vending is the practice of people selling products or rendering services in public locations like parks, streets, sidewalks, markets, and other open spaces. For millions of people, especially in developing nations like India, it is an essential source of income and a major component of the informal economy. 7 Street vendors typically operate with little capital investment, use temporary or mobile structures, and meet the daily needs of urban consumers by providing reasonably priced goods and services. 8 They offer services including shoe repair, tailoring, and key manufacturing in addition to selling fruits, vegetables, food products, apparel, books, and home things.

The National Policy on Urban Street Vendors, 2009 defines a street vendor as a person who offers goods or services to the public without having a permanent built-up structure but who operates in public or private spaces on a temporary or semi-permanent basis. 9 This definition recognizes both stationary and mobile vendors and acknowledges their contribution to urban economies and employment generation. Delhi (2010) 10 SCC 715; Maharashtra Ekta Hawkers Union v Municipal Corporation, Greater Mumbai (2004)

1 SCC 625.

5 The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 (Act No. 7 of 2014)

6 ibid, ss 3–12.

7 Sharit K. Bhowmik, Street Vendors in the Global Urban Economy (Routledge 2010) 1–5.

8 International Labour Organization, Women and Men in the Informal Economy: A Statistical Picture (3rd edn, ILO 2018) 41–45.

9 Ministry of Housing and Urban Affairs, National Policy on Urban Street Vendors, 2009 para 1.3.

The legal definition of street vending in India is provided under Section 2(1)(l) of the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014, which defines a street vendor as: “a person engaged in vending of articles, goods, wares, food items or merchandise of everyday use or offering services to the general public, in a street, lane, sidewalk, footpath, pavement, public park or any other public place or private area, from a temporary built up structure or by moving from place to place and includes hawker, peddler, squatter and all other synonymous terms which may be local or region specific; and the words “street vending” with their grammatical variations and cognate expressions, shall be construed accordingly;”10 Constitutional Framework and Judicial Recognition of Street Vendors' Rights Street vending holds a contradictory position in Indian urban governance: it is both essential to the informal sector and perpetually exposed to executive discretion wielded through municipal by-laws enacted under colonial-era law.

11 Unlike several other informal-sector occupations, street vending has been the subject of sustained constitutional litigation for nearly four decades, resulting in a judicially constructed rights framework that was eventually codified in the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 ("the 2014 Act")12.

A) The Constitutional Basis

No provision of the Constitution of India refers to “street vending” in terms. The right has instead been judicially derived, principally, from four constitutional provisions read together and reinforced by the Directive Principles of State Policy. Article 19(1)(g) grants all citizens the right "to practise any profession, or to carry on any occupation, trade, or business. " The courts have regularly ruled that hawking and street trading are covered by this assurance. 13 However, the right is not absolute. Article 19(6) allows the state to impose "reasonable restrictions" on the exercise of this freedom "in the interests of the 10 The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 s 2(1)(l) 11Sharit K. Bhowmik, “Hawkers and the Urban Informal Sector: A Study of Street Vending in Seven Cities,” National Alliance of Street Vendors of India (2001).

12Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014, Act No. 7 of 2014, published in the Gazette of India on 4 March 2014, brought into force with effect from 1 May 2014. 13Sodan Singh v. New Delhi Municipal Committee, (1989) 4 SCC 155: AIR 1989 SC 1988, per Sharma, J. (majority) and Kuldip Singh, J. (concurring).

general public," and it is this qualifying language that has served as the constitutional foundation for vending activity licensing, zoning, and time-and-place regulation. Article 21 states that no one shall be deprived of "life or personal liberty except in accordance with the procedure established by law. " In Olga Tellis v. Bombay Municipal Corporation, a Constitution Bench ruled that the right to life under Article 21 is broad enough to include the right to livelihood, reasoning that eviction from the means by which a person earns a living is tantamount to a deprivation of life.

14This logic has been applied to the vending jurisprudence, but with a crucial caveat: the Supreme Court has repeatedly stated that although livelihood considerations influence the Article 19(1)(g) analysis, there is neither an independent fundamental right under Article 21 to engage in hawking business nor a right under Article 21 to hawk at a specific location. 15 As a result, Article 21 serves more as an interpretive tool that shapes the "reasonableness" inquiry under Article 19(6) and as the theoretical foundation for procedural protections against arbitrary eviction than as an independent source of the vending right. Article 14 provides equal protection under the law and equality before the law.

This article has been used to contest selective enforcement of anti-encroachment campaigns, discriminatory licensing processes, and the lack of clear standards for defining vending and no-vending areas. Instead of creating a freestanding right to sell, its role has been supplemental rather than fundamental, strengthening procedural fairness requirements. Articles 38 and 39 of the Directive Principles require the state to establish a social order in which justice informs all institutions of national life, as well as to ensure that citizens have enough means of subsistence. Though not directly enforceable under Article 37, courts have repeatedly used these provisions to interpret Articles 19 and 21 broadly in favour of subsistence-level informal traders, and to justify directing the State toward affirmative regulatory action rather than mere prohibition.

The Judicial Trajectory Judicial engagement with street vending has progressed through three distinct phases: (a) an 14Olga Tellis v. Bombay Municipal Corporation, (1985) 3 SCC 545. The case concerned pavement and slum dwellers rather than vendors as such, but its reasoning on the Article 21–livelihood nexus was subsequently extended to street-vending disputes. 15Maharashtra Ekta Hawkers Union v. Municipal Corporation, Greater Mumbai, (2004) 1 SCC 625, para 10

early phase recognising the bare existence of the right subject to municipal regulation; (b) a middle phase in which the Supreme Court began issuing detailed operative directions in the form of interim regulatory codes; and (c) a culminating phase in which the Court explicitly called for statutory codification, resulting in the 2014 Act. The Supreme Court acknowledged that street trading is protected by Article 19(1)(g) in the

1985 case of Bombay Hawkers’ Union v. Bombay Municipal Corporation. However, the court

held that municipal corporations still have the authority to regulate through licensing and designated hawking zones as long as the regulation does not amount to a de facto prohibition. 16Later benches used the rules established in that case as a blueprint for other municipal initiatives, including limitations on hawking near hospitals, houses of worship, educational institutions, and footbridges, as well as constraints on the size and position of stalls. 17 In Sodan Singh v. New Delhi Municipal Committee, decided on August 30, 1989, a five-judge Constitution Bench made the most doctrinally significant early ruling. 18 Pavement vendors who had previously paid "tehbazari" fees to occupy particular locations were the petitioners. They claimed that the municipality's refusal to allow further business violated Articles 19(1)(g) and 21. In Pyare Lal v. N. D. M. C.

, the Division Bench made two decisions that still govern the field, and the Bench referred the case to reevaluate the validity of that decision. First, drawing on the logic in Saghir Ahmad v. State of U. P. 19, street trading is protected as a trade or occupation under Article 19(1)(g), regardless of whether it is done from a permanent receptacle or on the road. Second, and perhaps most importantly, no citizen has a fundamental right to use a specific location on a public street for commerce; the State is responsible for designating the roadways and marking the locations from which commerce is permitted. In his concurring opinion, Kuldip Singh, J. made a striking note on the socioeconomic context: in a nation where unemployment is high, people who work for themselves through hawking should be supported rather than hindered.

20 The Bench went beyond previous rulings by ruling that the State's failure to create a regulatory framework would nullify the fundamental right on its own and 16Bombay Hawkers’ Union v. Bombay Municipal Corporation, (1985) 3 SCC 528. 17These conditions were expressly reaffirmed as “final” and applicable without alteration in Maharashtra Ekta Hawkers Union v. Municipal Corporation, Greater Mumbai, (2004) 1 SCC 625. 18Sodan Singh v. New Delhi Municipal Committee, (1989) 4 SCC 155 : AIR 1989 SC 1988 : 1989 SCR (3) 1038, Sharma, J. for the majority, Kuldip Singh, J. concurring. 19Saghir Ahmad v. State of U. P. , AIR 1954 SC 728, cited with approval in Sodan Singh for the proposition that public streets, though vested in the State, are held by it as trustee for the public, whose use may reasonably extend beyond mere passage. 20Sodan Singh, (1989) 4 SCC 155, per Kuldip Singh, J. , para 33.

that the courts would be responsible for defending the rights of vendors if the State did not take action in a timely manner. This is where the now-established phrase "right to trade, not right to a specific pavement" came from. 21 Between Sodan Singh and the enactment of the 2014 Act, the Supreme Court found itself repeatedly seized of the same underlying grievance—the absence of a statutory scheme— through a protracted line of orders in Maharashtra Ekta Hawkers Union v. Municipal Corporation, Greater Mumbai, spanning a 2003 decision reported at (2004) 1 SCC 625, further orders reported at (2009) 17 SCC 151 and (2009) 17 SCC 231, and a final substantive order in

2013 reported at (2014) 1 SCC 490. 22 The Court openly admitted in the 2013 order that "in

last 28 years, this Court has struggled to find a workable solution of the problems of street vendors/hawkers," citing the continuous line of earlier rulings from the Bombay Hawkers' Union onwards and noting that "the situation has not changed in last four decades." 23In this series of cases, the Court essentially served as an interim regulator, directing the demarcation of hawking and no-hawking zones, incorporating the National Policy on Urban Street Vendors,

2004 and 2009 into its operative directives, and making it clear that any scheme developed in

this way was only temporary, "valid only till the regulations" contemplated under the National Policy were framed by the State Government. 24 Gainda Ram v. Municipal Corporation of Delhi, which was resolved on October 8, 2010, was the result of parallel and equally drawn-out litigation in the Delhi setting. 25 Given that the right had already been "declared by this Court" to be a component of the Article 19(1)(g) guarantee, the Bench examined the National Policy on Urban Street Vendors, 2009, the Master Plan of Delhi, 2012, and the Model Street Vendors (Protection of Livelihood and Regulation of Street Vending) Bill, 2009 prepared by the Ministry of Housing and Urban Poverty Alleviation. Together, these documents represented an attempt "to regulate the fundamental right of street hawking and street vending by law. " 26 21Sodan Singh, (1989) 4 SCC 155, per Sharma, J.

This directive language — effectively placing the burden of inaction on the State — became the doctrinal hook for the subsequent line of mandamus-style orders culminating in Gainda Ram and the Maharashtra Ekta Hawkers Union litigation. 22Maharashtra Ekta Hawkers Union v. Municipal Corporation, Greater Mumbai, (2004) 1 SCC 625 (decided 9 December 2003); (2009) 17 SCC 151; (2009) 17 SCC 231; and (2014) 1 SCC 490 (decided 9 September 2013). 23Maharashtra Ekta Hawkers Union v. Municipal Corporation, Greater Mumbai, (2014) 1 SCC 490, para 6 (order dated 9 September 2013). 24Maharashtra Ekta Hawkers Union v. Municipal Corporation, Greater Mumbai, (2009) 17 SCC 151, para 41. 25Gainda Ram v. Municipal Corporation of Delhi, (2010) 10 SCC 715, Singhvi and Ganguly, JJ. 26Gainda Ram v. Municipal Corporation of Delhi, (2010) 10 SCC 715, para 64.

Notably, the Bench also connected the proposed Bill to Article 21, arguing that legislation safeguarding urban street sellers' livelihoods would give that constitutional value legislative form. 27 The Court gave the relevant government until June 30, 2011, to pass laws prohibiting hawking; otherwise, the temporary plans created by the Municipal Corporation of Delhi and the New Delhi Municipal Council will remain in effect. 28 When taken as a whole, the Gainda Ram and Maharashtra Ekta Hawkers Union rulings signify the Supreme Court's shift from resolving individual cases to actively pressuring the legislature to codify a type of ongoing or structural mandamus that is rarely upheld for such a long time in Indian constitutional practice.

EVOLUTION OF STREET VENDING LAWS IN INDIA

The legal development of street vending in India reflects the nation's overall progress in acknowledging the rights of the unorganized labour force. For generations, street vending has been a traditional mode of business, offering reasonably priced goods and services and generating jobs for millions of people, especially those from lower socioeconomic groups. For a very long period, street vending was not covered by the official legal framework, despite its significant contribution to urban economies. Vendors were at risk of being evicted, harassed, and losing their jobs because they were frequently seen as intruders on public areas rather than as legitimate economic actors. Early Legal Position Street vending was governed by municipal rules throughout the colonial era, which mainly sought to preserve public order, sanitation, and unrestricted traffic.

These rules gave municipal authorities the authority to clear any obstacle from public roadways, and street sellers were frequently viewed as unauthorized occupants rather than honest business people. Illegal encroachments and livelihood-based vending operations were not distinguished. After Independence, India largely continued with the same municipal regulatory framework. Different State Municipal Corporation Acts authorized local bodies to issue licences, regulate public markets, and remove encroachments from streets and pavements. However, the licensing system was often arbitrary and inadequate. Since the number of licences issued was 27Gainda Ram, (2010) 10 SCC 715, para 63: “the Bill then prima facie recognizes the rights of hawkers and vendors under Article 21 of the Constitution since it seeks to protect their livelihood. ” 28Gainda Ram, (2010) 10 SCC 715, para 69.

much lower than the actual number of vendors, many continued their businesses without official permission, exposing them to frequent eviction drives and administrative harassment. National Policy on Urban Street Vendors The Government of India introduced the National framework on Urban Street Vendors, 2004, after realizing the necessity for a uniform framework. The first formal attempt to recognize street vending as a respectable line of work was this policy. It suggested participatory decisionmaking, open licensing procedures, and safeguards against arbitrary eviction. However, the policy had no statutory force, as a result its implementation remained inconsistent across different States. As a result, the National Policy on Urban Street Vendors, 2009 was introduced by the government.

the updated policy took a rights-based stance and proposed for the creation of Town Vending Committees (TVCs) with representation from street vendors, local government, and civil society organisations, It also suggested identifying vending zones, conducting frequent vendor surveys, and engaging in participatory urban planning. Despite the fact that the policy of 2009 greatly improved the policy framework, its recommendations remained advisory rather than legally binding. Enactment of the Street Vendors Act, 2014 The most significant milestone in the evolution of street vending laws was the enactment of the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014. The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 did not appear overnight.

It marked the conclusion of a legal procedure that had been in motion for thirty years prior to it, as well as a policy process that had been progressing slowly for ten years prior. The National Policy for Urban Street Vendors of 2004, which was updated into the National Policy on Urban Street Vendors, 2009, is typically cited as the origin. 29 A Model Street Vendors (Protection of Livelihood and Regulation of Street Vending) Bill, 2009 was distributed to the States by the Ministry of Housing and Urban Poverty Alleviation in addition to the 2009 Policy. However, because it lacked legal power, the majority of States chose not to 29Street Vendors Act, 2014, “Street Vendors Act, 2014,” summarising the policy history from the 2004 and 2009 National Policies.

implement it. In Gainda Ram v. Municipal Corporation of Delhi (2010), the Supreme Court instructed the Ministry to pursue a central law instead of relying on non-binding policy. A draft Bill was made available to the public in November 2011. 30 The then-Minister for Housing and Urban Poverty Alleviation introduced the Bill in the Lok Sabha on September 6, 2012. It was passed by the Lok Sabha on September 6, 2013, and the Rajya Sabha on February 19, 2014. On March 4, 2014, the President signed it into law, and on May 1, 2014, it became Act No. 7 of 2014. 31 The Act covered all of India at the time it was passed, with the exception of the State of Jammu and Kashmir. On October 30, 2019, a notification was issued extending the Act to the Union Territories of Jammu and Kashmir and Ladakh.

32 The Act has twin purpose: to protect the rights of urban street vendors and to control street vending activities. In order to prevent the protection from being circumvented by merely using a different local term for the same activity, Section 2 of the Act provides a broad definition of "street vendor," covering anyone who offers goods or services for sale in a public place from a temporary structure or by moving from place to place. It specifically folds in local and regional terms like hawker, peddler, and squatter. 33 The Act is divided into ten chapters that cover a wide range of topics, including substantive rights and obligations, dispute resolution, governance (the Town Vending Committee), identification machinery (survey and certification), and penalties. 34 a.

Survey and the Certificate of Vending Every local authority is required by Section 3 to conduct a survey of all current street vendors in conjunction with the Town Vending Committee. This study must be repeated at least once every five years. The following clause, which gives this survey its teeth, states that no street vendor identified in the survey may be evicted or relocated until the survey is finished and the vendor has either received a certificate of vending or been given a hearing on why one was 30Gainda Ram v. Municipal Corporation of Delhi, (2010) 10 SCC 715, paras 63–69. 31Street Vendors Act, 2014, s. 1(3), read with Notification S. O. 1185(E), dated 1 May 2014. 32Street Vendors Act, 2014, s. 1(2), as amended by Notification No. S. O. 3912(E), dated 30 October 2019. 33Street Vendors Act, 2014, s. 2(1)(l).

34The ten-chapter structure is summarised in ‘Street Vendors Act’ (Scribd presentation), and can be verified against the Act as published at indiacode. nic. in.

denied. 35 Every surveyed vendor over the age of fourteen is then required by Section 4 to receive a certificate of vending from the Town Vending Committee, provided that the vendor has no other source of income, will sell directly or through a designated family member, and will not transfer the certificate. 36 One of three categories—stationary vendor, mobile vendor, or any other category specified by the relevant state scheme—is used to issue certificates. The criteria for allocation must prioritise Scheduled Castes, Scheduled Tribes, Other Backward Classes, women, people with disabilities, and minorities. An individual who feels wronged by a certificate's denial, cancellation, or suspension may file an appeal with the local government, which is unable to rule on the matter without holding a hearing for the vendor. 37 b.

The Town Vending Committee According to Section 22, the Town Vending Committee (TVC) is the primary governing body of the Act. It is presided over by the local Municipal Commissioner and is made up of a diverse range of official and non-official members, including representatives from the police, the planning authority, the medical or health department, resident welfare associations, and—most importantly—street vendors themselves, who are expected to hold at least 40% of the seats, with one-third of that vendor representation set aside for women. The TVC's powers are spread throughout the Act rather than being centralised: it conducts the survey, issues certificates, approves the street vending plan, and hears relocation cases. In principle, this makes the TVC the only venue where vendors are not only regulated, but also expected to engage in their own regulation. c.

Rights and Obligations of Street Vendors Chapter III of the Act is brief but crucial. Section 12 grants every vendor the right to conduct business in line with the requirements of the certificate, while emphasising that no vending may take place in an area labelled a no-vending zone. However, immediately afterward, the Act contains a qualifying clause that is easy to overlook but is extremely important in practice: nothing in the Act confers on a vendor any "temporary, permanent, or perpetual right" to continue vending in the zone granted to them or at any other location where they vend. 38 35Street Vendors Act, 2014, s. 3(3). 36Street Vendors Act, 2014, s. 4. 37Street Vendors Act, 2014, s. 9. 38Street Vendors Act, 2014, s. 12(sub-section on non-conferral of vested right); see the reproduction of this clause

d. Relocation, Eviction, and the Street Vending Plan Every five years, local authorities must create a street vending plan that designates no-vending zones, limited vending zones, and restriction-free vending zones after consulting with the planning authority and following the TVC's advice. The Act imposes significant restrictions on the declaration of a no-vending zone, including the following: no zone may be declared a novending zone prior to the completion of the survey and the plan itself; an existing or natural market identified in the survey cannot be turned into a no-vending zone; overcrowding alone is insufficient justification; and sanitation concerns can only justify such a declaration if they are specifically caused by vending activity and cannot be resolved through ordinary civic measures.

In the event that relocation is required, the Second Schedule to the Act mandates that it be preceded by a survey, be need-based, adhere to natural justice, and, if practical, be accompanied by an alternate location. The eviction-without-process pattern that dominated the case law before to 2014 is most clearly addressed by this clause. e. Grievance Redressal According to Section 20, each local authority area must have a Grievance Redressal Committee appointed by the relevant government. The committee will be led by a civil judge or judicial magistrate, with equal numbers of vendors and traders making up the remaining membership. Instead than leaving vendors at the mercy of the same municipal personnel whose decisions they are disputing, the Committee is intended to hear disputes over eviction, relocation, and other grievances originating under the Act. f.

Penal Provisions Penalties are outlined in Chapter IX of the Act, and it's important to note how minimal they are. According to Section 28, a vendor may be fined up to two thousand rupees for each infraction, as decided by the local authorities, if they sell without a certificate, violate any of the Act's rules or schemes, or violate its provisions. The Act does not establish a distinct criminal offence and does not impose any penalties on officials or authorities who do not carry out the survey, form the TVC, or otherwise adhere to the Act's own deadlines. This asymmetry has real implications for how seriously the Act's deadlines have been handled in practice, as in the India Code text of the Act.

the critical discussion that follows indicates. Recent Developments The economic fragility of street vendors nationwide was made clear by the COVID-19 outbreak. In response, the Indian government introduced the PM Street Vendor's AtmaNirbhar Nidhi (PM SVANidhi) Scheme in 2020 to support street vendors' financial inclusion by offering them collateral-free working capital loans. By enhancing the financial stability of vendors, the program enhances the legal framework created by the 2014 Act, although being essentially an economic welfare project. Conclusion A revolutionary piece of social welfare legislation, the Street Vendors (Protection of

Livelihood and Regulation of Street Vending) Act, 2014 demonstrates India's dedication to safeguarding the livelihoods of millions of people working in the unorganised sector. The Act harmonises legislative regulation with constitutional values of equality, freedom of commerce, and the right to livelihood by acknowledging street vending as a valid employment and establishing a system based on surveys, certification, participatory governance, and procedural safeguards. However, the Act's successful execution is just as important as its legal construction. There is a disconnect between legal intent and administrative practice, as evidenced by ongoing incidents of arbitrary eviction, ineffective Town Vending Committees, poor vending infrastructure, and persistent survey delays.

To achieve the goals of the Act, a more coordinated strategy involving State Governments, local authorities, the judiciary, and vendor organizations is necessary. The Act will be able to serve as an effective tool of inclusive urban governance rather than just a symbolic recognition of vendors' rights if institutional accountability is strengthened, urban planning is improved, and street vendors are given real engagement.