Helmet requirement for two-wheeler riders upheld as a lawful safety measure and reasonable public restriction.

A helmet requirement for riders of motor-cycles and scooters was upheld as a valid safety measure under the Motor Vehicles Act. The Court treated the State's rule-making power as broad enough to cover measures intended to prevent danger and injury, and held that the specific illustrations in the rule-making provision did not limit that general power. The challenge under Article 19(1)(d) failed because the requirement was a reasonable restriction in the interests of the general public under Article 19(5). The Article 21 challenge also failed because the rule was made under lawful authority, and objections based on medical discomfort were rejected.

---

---

Issues: Validity of a rule requiring riders of motor-cycles and scooters to wear protective helmets, and validity of a police notification enforcing that requirement, in light of the Motor Vehicles Act and Articles 19(1)(d) and 21 of the Constitution of India.

Analysis: The rule was held to be within the rule-making power under the Motor Vehicles Act. The power conferred on the State Government to make rules for carrying into effect the relevant chapter was broad enough to cover a safety measure intended to prevent danger and injury to persons, including the rider of a two-wheeler. The specific illustrations in the rule-making provision were treated as not limiting the general power. The challenge under Article 19(1)(d) failed because the helmet requirement was a safety measure promoting welfare and was, in any event, a reasonable restriction in the interest of the general public under Article 19(5). The challenge under Article 21 also failed because the rule was made under lawful authority. The objection based on possible medical discomfort was rejected.

Conclusion: The helmet rule and the impugned notification were upheld as valid, and the constitutional and statutory challenges failed.

---