Administrative Law

Inter-State Transport Permits Cannot Override Notified Routes

Supreme Court rules private operators cannot ply on inter-state routes overlapping notified intra-state routes - approved transport schemes override inter-state agreements under Motor Vehicles Act

Case Reference: U.P. State Road Transport vs. Kashmiri Lal Batra & Ors (Civil Appeal No. 10522 of 2025) Decided by: Supreme Court of India Date: November 4, 2025

❓ Question

IF A PRIVATE BUS OPERATOR GETS AN INTER-STATE PERMIT FROM ONE STATE, CAN THEY AUTOMATICALLY OPERATE ON ROUTES THAT OVERLAP WITH NOTIFIED INTRA-STATE ROUTES IN ANOTHER STATE?

✅ Answer

NO, THEY CANNOT. The Supreme Court has ruled that approved transport schemes and notified routes under Chapter VI of the Motor Vehicles Act, 1988 override inter-state agreements under Section 88. Private operators cannot operate on inter-state routes that overlap with notified intra-state routes, even if they have permits from one state and an inter-state agreement exists.

⚖️ Understanding the Legal Principles

🔹 Chapter VI Override Principle

  • Chapter VI schemes override Chapter V agreements
  • Notified routes prevail over inter-state agreements
  • Section 98 MV Act gives overriding effect to Chapter VI
  • Public interest in notified routes is paramount

🔹 Inter-State Agreement Limits

  • IS-RT Agreement under Section 88 is not "law"
  • Cannot override approved transport schemes
  • Requires publication and objection consideration
  • Binding only if no conflict with notified routes

🔹 Route Overlap Restrictions

  • Even partial overlap with notified route is prohibited
  • No "five-mile rule" or distance exemption applies
  • Conditional permits cannot circumvent prohibition
  • Physical overlap sufficient, no need for explicit exclusion

🔹 Constitutional Bench Precedents

  • Adarsh Travels Bus Services vs State of UP (1985)
  • T.V. Nataraj vs State of Karnataka (1994)
  • Mysore SRTC cases established clear principles
  • Consistent view since 1970s maintained

📜 Key Legal Timeline

November 21, 2006

Inter-State Agreement: MP and UP sign reciprocal transport agreement under Section 88 MV Act

2006-2013

MPSRTC Operations: Madhya Pradesh State Transport Corporation operates Schedule B routes

2013

MPSRTC Winding Up: Corporation stops operations, routes get de-notified

2013-2014

Private Operators Apply: Private operators seek permits for de-notified routes

November 26, 2014

High Court Order: MP High Court directs UP to countersign permits

2017-2018

Multiple Challenges: Various operators file cases for similar relief

2024

Writ Petition Filed: Operators file direct Supreme Court petition

November 4, 2025

Supreme Court Judgment: Sets aside High Court orders, upholds notified route supremacy

🧭 Your Action Plan: Transport Permit Issues

📝 If You're a Private Transport Operator

✅ Step 1: Verify Route Status

  • Check if your proposed route overlaps any notified routes
  • Verify with both state transport authorities
  • Review published transport schemes in official gazettes
  • Check for any approved modifications to schemes

✅ Step 2: Seek Alternative Resolution

  • Approach transport authorities for route modifications
  • Explore possibility of partial exclusion from schemes
  • Consider inter-state dialogue for route adjustments
  • Document all communications with authorities

⚖️ Key Legal Arguments to Make

Legal Argument Basis in Law Application in Your Case
Chapter VI Supremacy Section 98 MV Act Notified routes override inter-state agreements
Public Interest Protection Section 99 MV Act Approved schemes serve public transportation needs
Constitutional Bench Precedents Adarsh Travels Case Clear legal position established since 1985
Route Overlap Prohibition Mysore SRTC Cases Even partial overlap with notified route is prohibited

⚖️ If Facing Legal Challenges

✅ Cite Relevant Precedents

  • Adarsh Travels Bus Services vs State of UP (1985)
  • T.V. Nataraj vs State of Karnataka (1994)
  • Mysore SRTC vs Mysore STAT (1974)
  • T.N. Raghunatha Reddy vs Mysore STA (1970)

📘 Key Legal Terms Explained

Notified Route

A route approved under Chapter VI MV Act where State Transport Undertaking has exclusive or preferential operation rights.

Inter-State Reciprocal Transport Agreement

Agreement between two states under Section 88 MV Act for mutual recognition of transport permits on inter-state routes.

Chapter VI Override

Legal principle that provisions of Chapter VI MV Act prevail over inconsistent provisions in Chapter V or other laws.

Route Overlap

Situation where an inter-state route shares any portion with a notified intra-state route on the same highway.

Approved Scheme

Transport scheme finalized after publication, objections, and approval process under Sections 99-100 MV Act.

🚨 What to Avoid in Transport Permit Cases

❌ Don't Assume Inter-State Agreement Supremacy

  • Don't rely solely on inter-state agreements
  • Avoid investing before checking notified routes
  • Don't ignore Chapter VI override principle
  • Avoid operating without proper route verification

❌ Don't Overlook Legal Precedents

  • Don't ignore established Constitution Bench rulings
  • Avoid arguing against settled legal principles
  • Don't rely on overruled judgments
  • Avoid procedural delays in legal challenges

💡 Core Takeaway from the Supreme Court

"Approved schemes and notified routes, which are envisaged in Chapter VI, would obviously override Section 88, in view of Section 98 of the 1988 MV Act... The consistent view of this Court has been that an IS-RT Agreement by its very nature is an agreement between two States but not a law under the relevant MV Act."

This judgment reinforces the supremacy of public transport schemes over private commercial interests. It protects the integrity of state transport planning and ensures that inter-state agreements cannot undermine carefully crafted transport policies designed to serve public interest through notified routes operated by state transport undertakings.

📞 When to Seek Professional Help

👨‍⚖️ Transport Lawyer Essential For

  • Complex inter-state transport permit applications
  • Challenges involving notified route overlaps
  • Appeals against transport authority decisions
  • Cases involving constitutional interpretations
  • When substantial commercial investments are at stake

📝 You Can Handle With Support

  • Basic route verification with transport authorities
  • Understanding fundamental legal principles
  • Initial permit application procedures
  • Following up on inter-state dialogue processes
  • Basic compliance with transport regulations

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

🌿 LegalEcoSys Mission

Making Supreme Court judgments accessible and actionable for every Indian citizen navigating legal challenges.

This roadmap decodes a complex administrative law judgment to help transport operators and citizens understand the hierarchy between inter-state transport agreements and notified route schemes. It empowers them to navigate transport permit regulations effectively while protecting public interest in transportation systems.