Polity & Governance

Supreme Court Declares the Right to Walk a Fundamental Right Under Articles 19 and 21

By TestNeeti Editorial TeamPublished Saturday, 11 July 2026 2 min readSource: Legal Service IndiaArticle 5 of 11

The Supreme Court of India has held that the right to walk safely on footpaths without fear and danger to life is a fundamental right guaranteed under Articles 19(1)(d) and 21 of the Constitution. The ruling came in Maniyar Iliyaz @ Shaik Riyaz & Anr. v. P. Ayyappan & Ors. (2026 INSC 647), a case arising from the death of a young child who was compelled to walk on the road due to the absence of proper pedestrian infrastructure. The Court observed that the right to walk is integral to freedom of movement, that safe pedestrian infrastructure is essential to the right to life and dignity, and that the state has a constitutional duty to construct and maintain footpaths. It noted that pedestrians' rights on public roads are at least equal to those of motor-vehicle users.

Key Facts & Details

9 points

1
The Supreme Court declared the right to walk safely on footpaths a fundamental right under Articles 19(1)(d) and 21.
2
The ruling was delivered in Maniyar Iliyaz @ Shaik Riyaz & Anr. v. P. Ayyappan & Ors. (2026 INSC 647).
3
The case arose from the death of a young child forced to walk on the road due to the absence of proper pedestrian infrastructure.
4
The Court held the right to walk is an integral part of the freedom of movement under Article 19(1)(d).
5
It ruled that the state has a constitutional duty to construct and maintain footpaths and pedestrian facilities.
6
The Court held that pedestrians' rights on public roads are at least equal to those of motor-vehicle users.

Deep Dive

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The judgment continues the judicial expansion of Article 21, which already covers implied rights such as livelihood, health, shelter and a clean environment.
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It marks a shift from a vehicle-centric to a human-centric understanding of urban mobility.
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The Court cautioned that failure to provide safe pedestrian infrastructure may amount to a violation of fundamental rights.

Exam Focus

The articles cited (19(1)(d) and 21), the newly recognised right (right to walk), and the fact that the Supreme Court linked safe footpaths to fundamental rights.

Exam Relevance & Angle

Supreme Court rulings that expand fundamental rights are prime polity and governance material. The linkage of the right to walk to Articles 19(1)(d) and 21 is a precise, testable fact, and it fits the recurring theme of the judiciary reading new rights into Article 21 — a favourite in banking GA, SSC and UPSC papers.

Target Exams

SBI POIBPS POSSC CGLSSC CHSLRRB NTPCUPSC CSEState PCS

Background & Context

Article 19(1)(d) guarantees all citizens the right to move freely throughout the territory of India, while Article 21 protects life and personal liberty. Since the landmark Maneka Gandhi v. Union of India (1978) judgment, the Supreme Court has interpreted Articles 14, 19 and 21 — the 'golden triangle' — as interconnected, reading Article 21 expansively to include the right to a life of dignity. Over the decades, the Court has recognised numerous implied rights under Article 21, including the rights to livelihood, health, education, shelter and a clean environment. The recognition of the right to walk continues this progressive, human-centric expansion of constitutional rights.