1. PIL challenging seizures of street vendors' goods without seizure memo or list of goods seized. (Para 2 , 3 , 4 , 5 )
Back
Next 
2026 Supreme(Online)(Del) 20087
IN THE HIGH COURT OF DELHI AT NEW DELHI
Prathiba M. Singh, Vikas Mahajan, JJ
Rehri Patri Ekta Manch – Appellant
Versus
Govt. of NCT of Delhi – Respondent
W.P.(C) 10490/2026
Advocates:
For the Appellants/Petitioners: Mr. Aditya
For the Respondents: Mr Jagdish Chandra, Mr. Tushar Sannu, Mr. Sriharsha Peechara, Mr Aditya Bharat Manubarwala, Mr Soumit Ganguli, Ms Ravicha Sharma, Ms Tanishka Grover, Mr Akash Sharma
For the Appellants/Petitioners: Mr. Aditya
For the Respondents: Mr Jagdish Chandra, Mr. Tushar Sannu, Mr. Sriharsha Peechara, Mr Aditya Bharat Manubarwala, Mr Soumit Ganguli, Ms Ravicha Sharma, Ms Tanishka Grover, Mr Akash Sharma
The Court balanced the statutory requirement of providing a seizure memo under the Street Vendors Act, 2014, with practical enforcement challenges, allowing local authorities to issue seizure memos within 24 hours of the seizure to prevent other vendors from escaping action.
Headnote:(A) Street Vending - Seizure of Goods - Compliance with Section 19 of the Street Vendors (Protection of livelihood and regulation of Street Vending) Act, 2014 - Requirement to prepare a list of seized goods and provide a copy to the vendor is mandatory. (Para 11)
(B) Procedural Flexibility - Timing of Seizure Memo - To prevent other vendors from escaping action, the court permits the issuance of seizure memos within 24 hours of the seizure, provided they contain essential details like date, list of goods, and officer's signature. (Para 12, 13)
Issues: Whether the local authorities (MCD and NDMC) can delay the issuance of seizure memos to prevent other vendors from escaping action while complying with the Street Vendors Act, 2014.
Legal Category Hierarchy
Table of Contents
2. Authorities justify delayed seizure memo to prevent other vendors from escaping; petitioners claim no memo is given. (Para 5 , 6 , 7 , 8 , 9 )
3. Court notes authorities must follow Section 19 of the Street Vendors Act requiring immediate seizure list to vendors. (Para 10 , 11 )
4. Seizure memo must be issued within 24 hours under Section 19 of the Street Vendors Act, 2014. (Para 12 , 13 )
5. Petition disposed with directions to issue seizure memos within 24 hours and videography of seizures. (Para 12 , 13 , 14 , 15 , 16 , 17 )
6. What is the requirement under Section 19 of the Street Vendors Act regarding seizure of goods?
Upon seizure, a list of goods seized must be prepared and a copy duly signed must be issued to the street vendor. (Para 11 )
7. Can seizure memos be issued after the seizure under the Street Vendors Act?
Yes, but within an outer limit of 24 hours from seizure, mentioning date, list of goods, shelf numbers, penalty, and officer's details. (Para 12 , 13 )
8. What safeguards must authorities follow during seizure of street vendors' goods?
Videography or photography of the seizure should be done, and seizure memos must contain date, list, shelf number, penalty, and officer's signature. (Para 13 , 14 )
Prathiba M. Singh, J. (Oral)
1. This hearing has been done through hybrid mode.
2. The present petition has been filed by the Petitioner – Rehri Patri Ekta Manch through its General Secretary – Mr. Anil Bakshi, seeking to represent various rights of street vendors in Delhi.
3. The petition itself records that the Petitioner-Association has no personal interest in the present Public Interest Litigation and it is for the interest of the street vendors at large.
4. The issue being raised in this PIL is in respect of seizures made by the Municipal Corporation of Delhi (hereinafter, ‘MCD’) and New Delhi Municipal Corporation (hereinafter, ‘NDMC’), of goods of the street vendors, in cases when there are any violations by the vendors.
5. The grievance is that whenever such seizures are effected, no seizure memo is prepared by the MCD and NDMC and the list of goods seized is also not given to the vendors. Only a receipt for payment of fine is issued in the evening after the seizure is effected.
6. On behalf of the MCD and NDMC, it is submitted that the usual process is that the seizure is done at a particular point in time and if on spot the seizure memo is prepared by the concerned officials, the other vendors then get the knowledge and get to escape the seizure after committing violations.
7. Accordingly, the seizure is effected first and in the evening of the same day, seizure memo is prepared along with the fine receipt and handed to the concerned vendors.
8. On behalf of NDMC, Mr. Peechara, ld. Counsel submits that a proper warehouse is maintained by the NDMC for storing the seized goods and the vendors’ goods are put in particular shelves and the respective shelf number is also given in the receipt issued to them. Upon the payment of the fine, the goods are released to concerned vendors.
9. It is also submitted on behalf of NDMC that videography/photography of the seizure is also done by the concerned officials, depending upon the available resources at the time when seizure is carried out.
10. The Court has heard the submissions made. It is noted that in the present petition, the details of the members of the Petitioner-Association are not set out. Further, no authorizations have also been set out.
11. In any event, both, the MCD and the NDMC are expected to follow Section 19 of the Street Vendors (Protection of livelihood and regulation of Street Vending) Act, 2014, which requires that upon a seizure being carried out, the list of goods seized ought to be prepared and a copy has to be given to the vendor. The said provision reads as under:
“19. Seizure and reclaiming of goods: (1) If the street vendor fails to vacate the place specified in the certificate of vending, after the lapse of the period specified in the notice given under sub-section (3) of section 18, the local authority, in addition to evicting the street vendor under section 18, may, if it deems necessary, seize the goods of such street vendor in such manner as may be specified in the scheme: Provided that where any such seizure is carried out, a list of goods seized shall be prepared, as specified in the scheme, and a copy thereof, duly signed by the person authorised to seize the goods, shall be issued to the street vendor. (2) The street vendor whose goods have been seized under sub-section (1) may, reclaim his goods in such manner, and after paying such fees, as may be specified in the scheme: Provided that in case of non-perishable goods, the local authority shall release the goods within two working days of the claim being made by the street vendor, and in case of perishable goods the local authority shall release the goods on the same day of the claim being made by the street vendor.”
12. Accordingly, considering the difficulties expressed by the authorities that if seizure memos are prepared on spot, other vendors who are in the area tend to escape action, the MCD and NDMC are permitted to issue seizure memos, in accordance with law within an outer limit
