Allahabad HC Directs UP Government to Institutionalise Crowd Behaviour Science After Mathura Writ Reveals Governance Gaps
Disposing of a writ against a demolition order, Justice Vinod Diwakar expanded scope to address the absence of crowd science in Mathura’s disaster planning framework.
What began as a challenge to a demolition order against an ashram in Vrindavan has ended with the Allahabad High Court directing the Government of Uttar Pradesh to institutionalise crowd behaviour science across its universities, development authorities, and district administrations. Justice Vinod Diwakar, sitting singly in Court No. 38, disposed of Writ-C No. 41777 of 2025 on 22 July 2026, but used the occasion to record detailed recommendations — described as “minimum governance necessities” — for preventing crowd crush disasters at pilgrimage sites. The judgment draws on academic crowd science, compares Mathura’s ten-year master plan unfavourably with the centennial planning horizons of Chandigarh and New Delhi, and calls the absence of any scientific crowd study by district authorities a “governance failure of the first order.”
The Demolition Dispute That Opened the Writ
The petitioner, Swami Shiv Swarupanand Ji, claims ownership of 167.22 square metres of land in Khasra Nos. 64/189, 65 and 66, Village Vrindavan Khaddar, Tehsil and District Mathura. He submitted a building plan to the Mathura Vrindavan Development Authority (MVDA) for construction of an ashram. The MVDA disapproved the plan on the ground that the plot falls within a flood-affected area where no permanent structure may be erected.
The petitioner raised the construction regardless. MVDA passed a demolition order under Sections 27(1), 28(1) and 28(ii) of the Uttar Pradesh Urban Planning and Development Act, 1973. The petitioner appealed under Section 27(iv) of the same Act. The Appellate Authority — the Commissioner, Agra Division — dismissed the appeal on 4 September 2025, finding that the petitioner had failed, despite sufficient opportunity, to show that the construction matched any approved sanction plan.
Before this Court, the petitioner argued selective enforcement. Out of 23 demolition orders passed by MVDA in the same notification (Annexure-10 to the writ), proceedings were executed only against the petitioner and those at serial nos. 4, 9, 10 and 11, leaving similarly situated persons untouched. Counsel contended this “pick and choose” approach was arbitrary and violated the guarantee of equal treatment.
How the Court Expanded the Scope
On 23 April 2026, the Court directed MVDA’s Vice Chairman — to file a comprehensive affidavit, prepared in consultation with the Authority’s Chairman, covering: the status of demolition proceedings against all 23 properties; the number of properties booked for unauthorized construction over the preceding five years; and the policy framework, statutory guidelines, and standard operating procedures adopted by MVDA to regulate such construction.
The Court simultaneously noted that Mathura had witnessed crowd crush incidents during pre-Holi events and other festivals, resulting in injuries and casualties, and that unauthorized constructions had obstructed rescue and emergency operations. On this basis it expanded the writ’s scope and directed the District Magistrate, Municipal Commissioner, and SSP, Mathura, to each file affidavits disclosing whether a comprehensive crowd and crisis management plan existed, whether any expert body studied crowd behaviour, and what scientific studies — if any — had been commissioned by or on behalf of the district administration.
What the Affidavits Revealed
The Vice Chairman’s affidavit disclosed that following the Supreme Court’s order dated 13 November 2024 in Writ Petition (Civil) No. 295 of 2022 (Re: Directions in the matter of demolition of structures and others), the State Government issued circulars on 15 January 2025, 17 January 2025, and 25 April 2026 requiring fresh notices before any demolition order could be executed. Of the 23 offending constructions: one had been compounded; three were found to be outside MVDA’s territorial jurisdiction; three had received fresh notices; and 16 remained to be examined in the light of the new circulars, with applications for compounding pending in several of those cases.
On enforcement data for the past five years (2021–22 to 2025–26), MVDA issued 2,453 notices under Section 27(1) of the 1973 Act; 700 demolition orders were passed; 323 were executed; 104 properties were sealed; and 212 cases were regularised through compounding. The Court noted these figures represented “merely the tip of the iceberg.”
The District Magistrate’s affidavit acknowledged that after two persons died in a stampede at Shri Banke Bihari Ji Temple, Vrindavan, on 20 August 2022, the State Government constituted a High-Level Committee chaired by former DGP Sulkhan Singh, which submitted a report on 7 September 2022 recommending immediate, short-term, and long-term measures. The Supreme Court subsequently constituted the “Thakur Shri Banke Bihari Ji Temple High Powered Management Committee” under a retired Allahabad High Court judge, with the DM, SSP, District Judge, Municipal Commissioner, and MVDA Vice Chairman as members.
The affidavit described a crowd management framework that included multi-departmental coordination meetings, one-way routing, barricading, separate entry and exit gates at Banke Bihari Temple, extended darshan hours, online darshan registration, live telecasting, CCTV deployment, and a structural survey of temple lanes by IIT Roorkee. A ten-year Development Master Plan had been prepared by UP Braj Teertha Vikas Parishad. An NHAI bypass on NH-530B (32 km) was completed on 30 August 2025.
The SSP’s affidavit detailed a division of Vrindavan into five traffic zones, 34 traffic intersections with deployed personnel, seven designated E-Rickshaw routes, 34 iron chain barrier locations (several already damaged), and prohibition of heavy vehicles from specified entry points on weekends and festivals. The Court observed that what both affidavits described was, in substance, traffic management — not crowd management.
Three Systemic Failures the Court Identified
Justice Diwakar identified three critical failures disclosed during arguments.
Inadequate planning horizon. Mathura’s master plan spans only ten years. The judgment draws a pointed comparison with the multi-generational planning of Chandigarh under Le Corbusier in the 1950s, the design of New Delhi by Lutyens and Baker, and the grid-based civic plan of Jaipur conceived by Maharaja Sawai Jai Singh II in 1727. The Court observed that a city carrying an unbroken civilisational heritage of over a thousand years and receiving millions of devotees annually “cannot be governed by a planning document that expires in a decade” — especially when the Government of India’s own Viksit Bharat vision extends to 2047. Mathura, Ayodhya, Varanasi, and Chitrakoot, the Court said, cannot be treated on a par with other cities in Uttar Pradesh.
Crowd management reduced to traffic management. The Court found that the district administration had conflated two distinct concepts. A religious crowd, the judgment explains, is characterised by collective piety, reduced responsiveness to conventional crowd control signals, and a significantly elevated tolerance for physical compression — which paradoxically suppresses the early warning signals that would otherwise prompt self-regulation. Applying adversarial crowd-control strategies to inherently cooperative devotional assemblies generates friction and, in extremis, panic. The Court cited the work of Gustave Le Bon on crowd psychology and Professor John Fruin’s pedestrian level-of-service analysis, noting that at densities exceeding four to five persons per square metre individual volition is effectively lost, and at six to seven persons per square metre — a threshold frequently encountered at Indian pilgrimage sites — compressive asphyxia becomes an imminent risk.
Unauthorized construction as organised illegality. The Court situated Mathura’s unauthorised construction problem within a wider pattern: development authorities under-resourced, enforcement agencies complicit, and real estate interests with political connections building without sanction along pilgrimage routes, riverfront ghats, and congregational spaces. The judgment states that the causes are “multiple, interconnected, and deeply structural,” including corruption of regulatory machinery and systematic interference by construction lobbies. The Court said that confronting this requires “strong, selfless, and incorruptible institutional will” rather than stronger laws, because India does not lack for laws.
Recommendations Recorded by the Court
The Court recorded specific recommendations directed at the State Government and relevant academic and policy bodies.
Crowd behaviour as an academic discipline. The judgment recommends that the Department of Higher Education direct all State universities offering programmes in urban planning, public administration, disaster management, civil engineering, architecture, sociology, applied psychology, and data analysis to introduce dedicated courses covering: crowd flow dynamics and density modelling; crowd risk assessment and safety planning; crowd management policy and law; and case studies in crowd disasters including systematic analysis of major crush incidents in India and internationally.
Centre of Excellence for Crowd Science. The Court recommends establishing, in collaboration with a leading State or Central university — or alternatively with IIT Kanpur, IIT Roorkee, or another institution of national repute within the State — a dedicated Centre of Excellence for Crowd Science, Mass Gathering Safety, and Urban Risk Management. This Centre should conduct original interdisciplinary research, maintain a database of crowd-related incidents and near-misses, provide technical advisory services to district administrations and development authorities, design training programmes for civil servants and police officers, and collaborate with international centres of excellence including the Crowd Science Unit at the University of Suffolk, United Kingdom.
Mandatory expert engagement. The Court recommends that the State Government make it mandatory, through legislative or executive action, for all departments, statutory authorities, local bodies, and event organisers to engage qualified crowd behaviour experts and crowd safety consultants at the planning stage of every major public gathering, whether religious, political, cultural, or recreational.
Integration into master planning. The Court recommends that all development authorities — specifically MVDA and UP Braj Teertha Vikas Parishad — integrate crowd behaviour science and crowd safety norms into their master planning processes, development control regulations, and building bye-laws. Street widths, access and egress design, congregation space capacity, and emergency evacuation routes are described as crowd safety decisions, not merely engineering decisions.
Statutory urban design commission. The Court additionally recommends that the State Government examine the feasibility of constituting a statutory commission for Uttar Pradesh on the lines of the Delhi Urban Art Commission, constituted under the Delhi Urban Art Commission Act, 1973, to advise on proposals for construction that may materially affect areas of historical, architectural, or environmental significance.
The Court grounded all recommendations in Article 21 of the Constitution, stating that the right to life imposes a positive obligation on the State to create and maintain conditions in which human life is not lost to preventable disasters arising from the State’s own administrative and intellectual unpreparedness. The institutionalisation of crowd behaviour science was described as a “constitutional imperative.”
Order
On the merits of the demolition writ, the Court disposed of the petition with liberty to the petitioner to approach MVDA (Respondent No. 4) afresh with his grievances. MVDA was directed to take a decision in the light of the State Government circulars dated 15 January 2025, 17 January 2025, and 25 April 2026 — issued in compliance of the Supreme Court’s order dated 13 November 2024 in Writ Petition (Civil) No. 295 of 2022. The impugned order dated 4 September 2025 passed by the Commissioner, Agra Division, was kept in abeyance in the meanwhile.
The Registrar (Compliance) was directed to forthwith transmit a copy of the order to the Chief Secretary, the Secretary, Higher Education (State Government), the Chairman of the University Grants Commission, and the Secretary, Higher Education, Government of India, for their reference and record.