Kerala HC Dismisses PIL Against Aadhaar OTP for Tatkal Booking, Suggests IRCTC Consider PAN Card as Alternative
The Kerala High Court dismissed a PIL challenging the Ministry of Railways' June 2025 circular mandating Aadhaar-based OTP authentication for online Tatkal ticket bookings, while suggesting IRCTC consider PAN Card authentication as an equally effective option.
A Division Bench of the Kerala High Court, led by Chief Justice Soumen Sen and Justice Syam Kumar V.M., dismissed a public interest litigation on 22 July 2026 that sought to strike down the Ministry of Railways' circular dated 10 June 2025. That circular introduced mandatory Aadhaar-based OTP authentication for booking Tatkal tickets online through the IRCTC website and mobile application. The petitioner argued that the requirement violated the right to privacy and informational autonomy, and failed to address the underlying technical deficiencies of the Tatkal system. The bench found no merit in the challenge but, accepting a submission from petitioner's counsel, directed IRCTC to consider allowing PAN Card authentication as an alternative to Aadhaar for online Tatkal bookings.
The PIL and the Challenge to the June 2025 Circular
Bahadur Shah Anakkot Nasirali, a 25-year-old resident of Kodungallur, Thrissur, filed WP(PIL) No. 129 of 2025 claiming to be a public-spirited individual aggrieved by the Railways' new authentication requirement. Prior to 10 June 2025, Tatkal bookings online carried no Aadhaar-based OTP requirement.
The petitioner's principal grievance was threefold. First, that the circular dated 10 June 2025, issued under Notification No. 2025/TG-1/P/TATKAL MODIFICATION, was contrary to statute. Second, that it disproportionately abrogated the right to privacy and informational autonomy of citizens. Third, that it failed to address the actual infrastructure and technical deficiencies affecting the Tatkal system — treating the symptom of traffic congestion by imposing identity verification rather than by upgrading server capacity or network bandwidth.
Respondents included the Union of India represented through the Ministry of Railways, the Railway Board, the Director/Passenger Marketing-II at Rail Bhavan, the Indian Railway Catering and Tourism Corporation (IRCTC), and the Centre for Railway Information Systems (CRIS). The petition was taken up for admission and disposed of on the same day.
The Railways' Justification: Touts, Syndicates, and Demand Regulation
The Union of India and the Railway Board filed a counter affidavit affirmed on 28 November 2025, with an additional counter affidavit affirmed on 1 April 2026. IRCTC filed its counter affidavit on 28 January 2026. The respondents' position, taken together, offered both a policy rationale and a statutory compliance argument.
On policy, the Railways stated that Tatkal tickets were being cornered by touts, syndicates, and automated booking software, causing severe hardship to genuine passengers. Aadhaar authentication was designed to enforce a one-person-one-booking rule, prevent multiple accounts per individual, reduce speculative and repetitive access attempts, and filter high-frequency requests before they reached seat allocation processes.
The Railways accepted that Aadhaar authentication does not physically increase server capacity, improve code efficiency, or enhance network bandwidth. It characterised the measure instead as a demand-regulation mechanism: by controlling who can access the Tatkal booking window and how often, it reduces artificial congestion caused by bots and proxy accounts, thereby making available capacity accessible more fairly to genuine users. Infrastructure upgrades including server scaling, CDN deployment, and load balancing were described as ongoing but insufficient on their own to prevent monopolisation through repeated speculative access by single users.
On statutory compliance, the additional counter affidavit of 1 April 2026 stated that the authentication operates strictly within the framework of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 and the regulations framed thereunder. Authentication is carried out only with the informed consent of the user, through encrypted channels, and on data minimisation principles, with the response limited to a yes/no confirmation or e-KYC information. No Aadhaar number is stored by IRCTC or the Railways. The respondents stated that the framework fully complies with the privacy principles laid down by the Supreme Court in Justice K.S. Puttaswamy (Retd.) v. Union of India (2019) 1 SCC 1.
The Railways also clarified two points that would become central to the bench's reasoning. First, Aadhaar authentication is a one-time exercise for the IRCTC user account and is not required afresh before each booking. Second, and critically, individuals who do not possess Aadhaar or prefer not to use it can obtain Tatkal tickets at physical counters without any Aadhaar requirement whatsoever.
The Bench's Reasoning on Privacy and Proportionality
The petitioner pressed before the bench that the Aadhaar OTP requirement for online Tatkal booking violates the Supreme Court's ruling in Justice K.S. Puttaswamy (Retd.) with respect to individual privacy. The bench did not accept this argument.
The reasoning turned on the optional nature of the online channel. Because a passenger who does not wish to share Aadhaar details can still purchase a Tatkal ticket at a physical counter without restriction, the bench held that the online Aadhaar requirement does not amount to compulsion. There is no mandatory demand to share Aadhaar details as a precondition for obtaining a Tatkal ticket; the requirement attaches only to online booking through the IRCTC platform.
The bench then applied the proportionality test to the policy itself. It found that the decision to require Aadhaar authentication for online Tatkal bookings had a clear justification — past experience of deceit, manipulation, and bulk booking by touts and automated software — and that the measure was directed at preventing a genuine harm. On those facts, the bench held that the wisdom of the decision could not be regarded as unjustified even under the proportionality standard. It found no merit in the petition.
The bench also confirmed, by way of clarification, that for the purchase of offline Tatkal tickets at counters, Aadhaar-based authentication is not required.
PAN Card Authentication: A Direction from the Bench
Petitioner's counsel submitted during the hearing that PAN Card authentication could achieve the same result as Aadhaar-based OTP authentication. The bench found substance in that submission.
The bench reasoned that a PAN Card also generates an OTP when used as authentication for any payment transaction, and the transaction proceeds only after OTP verification. If the Railways' objective is to ensure that each booking is tied to a verified, unique individual, PAN Card OTP authentication could serve the same purpose as Aadhaar OTP authentication. On that basis, the bench observed that “the IRCTC may consider the option of Aadhaar or PAN Card for authentication.”
This observation stopped short of a mandatory direction. The bench's language was recommendatory, leaving it to IRCTC to act on the suggestion. The Railways' position in its counter affidavit had been that alternative identity documents such as Voter ID and PAN Card could only be considered as authentication mechanisms once those documents are equipped with reliable, real-time, de-duplicated verification mechanisms comparable to Aadhaar. The bench did not expressly address or override that position but indicated that, at least in the case of PAN Card, the OTP mechanism may already achieve the desired result.
Order
The Division Bench disposed of WP(PIL) No. 129 of 2025 on 22 July 2026, finding no merit in the challenge to the Ministry of Railways' circular dated 10 June 2025 mandating Aadhaar-based OTP authentication for online Tatkal ticket bookings through IRCTC. The bench clarified that no Aadhaar authentication is required for offline Tatkal ticket purchases at counters. It further directed, by way of observation, that IRCTC may consider extending the authentication option to PAN Card as an alternative to Aadhaar, given that PAN Card transactions also involve OTP verification. The petition was disposed of accordingly.