The Jodhpur High Court has definitively ended the era of manual vehicle fitness certification in Rajasthan, enforcing a strict transition to Automated Testing Stations. This judgment resolves a prolonged administrative ambiguity and establishes a non-negotiable statutory compliance deadline, with immediate implications for transport authorities, vehicle owners, and fitness center operators across the state.
Background & Facts
The Dispute
The petitioner, Jalore Fitness Center, operated under a Letter of Authorization (LOA) granted under the FIJA-2018 Scheme, which permitted private entities to conduct manual vehicle fitness inspections. With the Union Government’s push to implement Automated Testing Stations (ATS) under amended Rule 62(1)(b) of the Central Motor Vehicles Rules, 1989, the petitioner faced obsolescence as the state moved to phase out manual certification.
Procedural History
- The petitioner challenged the proposed discontinuation of LOAs and the imposition of ATS-only certification.
- A batch of similar writ petitions was heard by a Division Bench in State of Rajasthan & Ors. v. Rajasthan Vehicle Fitness Center Nokha & Anr. (D.B. Special Appl. Writ No. 1560/2025).
- The Division Bench issued comprehensive directions on the transition timeline and operational framework.
- The present petition was filed independently but raised identical issues.
Relief Sought
The petitioner sought continuation of its operations under the FIJA-2018 Scheme and challenged the mandatory shift to ATS as arbitrary and violative of legitimate expectations.
The Legal Issue
The central question was whether the Union Government’s mandate under Rule 62(1)(b) of the Central Motor Vehicles Rules, 1989 permits continued manual issuance of fitness certificates after the prescribed transition deadline, and whether existing LOAs under the FIJA-2018 Scheme can override this statutory requirement.
Arguments Presented
For the Petitioner
The petitioner argued that the FIJA-2018 Scheme created a legitimate expectation of continued operation until adequate ATS infrastructure was available. It relied on K. S. Puttaswamy v. Union of India to assert that abrupt termination of authorized operations without transitional safeguards violated Article 14. It contended that the state had not fulfilled its obligation to ensure equitable access to ATS facilities, particularly in rural districts like Jalore.
For the Respondent
The State and Union contended that Rule 62(1)(b) is a mandatory statutory provision requiring all fitness certificates to be issued exclusively through ATS. They cited the Office Order dated 02.07.2025, which clarified the implementation timeline, and emphasized that the FIJA-2018 Scheme was always intended as a temporary measure pending full automation. The respondents stressed that public interest in standardized, tamper-proof vehicle safety certification outweighed private commercial interests.
The Court's Analysis
The Court declined to entertain the petition on its merits, holding that the legal issues had been conclusively settled by the Division Bench in the lead case. It adopted the Division Bench’s reasoning in full, emphasizing that statutory mandates under the Central Motor Vehicles Rules, 1989 cannot be subordinated to administrative schemes.
"This Court further clarifies that from the said date, no Certificate of Fitness shall be issued in the State of Rajasthan except through an Automated Testing Station (ATS), in terms of Rule 62(1)(b) of the Central Motor Vehicles Rules, 1989, read with Office Order dated 02.07.2025, notwithstanding the fact that such facilities may be available only at limited locations, and such facilities have to be availed from the nearest operational ATS."
The Court rejected the argument that lack of infrastructure justified non-compliance. It held that the state’s duty to implement statutory provisions is not contingent on perfect infrastructure but requires proactive measures to ensure access. The extension of the deadline to 15 April 2026 was framed not as a concession but as a calibrated enforcement mechanism to allow for logistical preparation.
The Court also clarified that LOAs under FIJA-2018 remain valid only until an ATS becomes operational in the district, but no new LOAs may be issued. This distinction between temporary operational continuity and permanent entitlement was critical to the reasoning.
The Verdict
The petitioner’s writ petition was dismissed. The Court held that Rule 62(1)(b) of the Central Motor Vehicles Rules, 1989 mandates exclusive use of Automated Testing Stations for vehicle fitness certification in Rajasthan from 15 April 2026. Manual issuance by LOA holders is no longer lawful after that date, regardless of infrastructure gaps.
What This Means For Similar Cases
Manual Fitness Certification Is Now Illegal
- Practitioners must advise clients that any fitness certificate issued manually after 15 April 2026 is void and renders the vehicle non-compliant under Rule 62(1)(b).
- RTOs and DTOs issuing manual certificates post-deadline risk administrative liability and potential prosecution under Section 192 of the Motor Vehicles Act.
Transition Period Does Not Extend Operational Rights
- LOA holders may continue operating only until an ATS is commissioned in their district, but cannot claim a right to indefinite operation.
- Applications for ATS establishment must be processed within 60 days; delays beyond this period may be challenged under Article 21 as denial of livelihood.
Access Is Not Optional - Proximity Is Mandatory
- The Court’s directive that vehicle owners must travel to the nearest ATS establishes that geographic accessibility is not a defense for non-compliance.
- Practitioners should prepare petitions for equitable relief if districts remain without ATS beyond the deadline, invoking the state’s positive obligation under Article 21 to ensure public safety infrastructure.
