Public safety assessment under Petroleum Rules permits technical guidelines, but National Highway norms cannot be extended to other roads.

Rule 144 of the Petroleum Rules, 2002 requires the District Authority to assess public safety factors such as public interest, traffic density, fire-service access and other relevant considerations when deciding no-objection certificates for petroleum outlets. In the absence of specific operational norms from the Central Government, the authority may rely on objective technical guidelines to support consistent and non-arbitrary decision-making; the Indian Roads Congress guidelines were therefore treated as a permissible aid, though not binding law. By contrast, Ministry of Road Transport and Highways norms framed for National Highways could not be extended to petroleum outlets on State Highways or other roads without a lawful basis, and refusal of applications on that footing was not sustainable.

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Issues: (i) Whether the District Authority acting under Rule 144 of the Petroleum Rules, 2002 could rely on the Indian Roads Congress guidelines while granting or refusing no-objection certificates for petroleum outlets; (ii) Whether the Ministry of Road Transport and Highways norms could be applied to petroleum outlets proposed on roads other than National Highways.

Issue (i): Whether the District Authority acting under Rule 144 of the Petroleum Rules, 2002 could rely on the Indian Roads Congress guidelines while granting or refusing no-objection certificates for petroleum outlets.

Analysis: Rule 144 is a public safety provision and requires the District Authority to examine matters such as public interest, traffic density, access for fire services and other safety considerations. Where the Central Government has not prescribed specific operational norms, the authority is expected to act with due care and may rely on objective technical guidelines to avoid subjective and inconsistent decisions. The Indian Roads Congress guidelines, though not having the force of law, were treated as a permissible and relevant aid in discharging the statutory function, especially in light of the public safety character of the rule and the need for consistency.

Conclusion: The District Authority was not barred from relying on the Indian Roads Congress guidelines for deciding applications under Rule 144.

Issue (ii): Whether the Ministry of Road Transport and Highways norms could be applied to petroleum outlets proposed on roads other than National Highways.

Analysis: The materials placed before the Court showed that the Ministry norms were framed for facilities along National Highways. In the absence of material showing their intended application to roads other than National Highways, applying those norms to outlets on State Highways or other roads would be unsupported and arbitrary. The rejection of applications on that basis, where the site was not on a National Highway, could not therefore be sustained.

Conclusion: The Ministry of Road Transport and Highways norms were not held applicable to petroleum outlets situated on roads other than National Highways.

Final Conclusion: The petitions were not granted overall relief, but the Court upheld reliance on Indian Roads Congress guidelines for public safety purposes while holding that the Ministry norms could not govern outlets outside National Highways.

Ratio Decidendi: In a public safety regime where the governing statute leaves room for administrative assessment, the authority may rely on objective technical guidelines to ensure consistent and prudent decision-making, but norms framed for National Highways cannot be extended to other roads without a legally sustainable basis.

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