Religious Gatherings: Allahabad HC Calls for 'Crowd Science' Courses, Centre of Excellence to Prevent Stampedes

Holding that crowd management at religious places cannot be reduced to traffic regulation, the Allahabad High Court has called for the institutionalisation of crowd behaviour as a scientific discipline, recommending dedicated university courses, a Centre of Excellence for Crowd Science and mandatory engagement of crowd behaviour experts for major public gatherings.

The observations came in a judgment arising out of a challenge to demolition proceedings against an allegedly unauthorised construction in Vrindavan, where the court expanded the scope of the case to examine systemic issues relating to crowd safety, urban planning and unauthorised constructions in Mathura.

"The recurring tragedies witnessed at pilgrimage sites... are not merely the product of administrative failure or infrastructural inadequacy but... reflect a profound and institutionalized ignorance of the science of crowd behaviour," court observed.

The petition itself challenged demolition proceedings initiated after permission to construct an ashram had been refused because the land lay in a flood-affected area. The petitioner alleged discriminatory action, claiming that demolition orders against several similarly situated constructions had not been uniformly enforced.

What did the high court find on unauthorised constructions in Mathura?

After seeking affidavits from the Mathura Vrindavan Development Authority (MVDA), court found that over the last five years, the authority had issued 2,453 notices against unauthorised constructions, passed 700 demolition orders, executed 323 demolitions, sealed 104 properties and regularised 212 through compounding.

Court, however, remarked that these figures represented "merely the tip of the iceberg" and that the magnitude of unauthorised construction was far more serious.

The MVDA also informed the court that among the 23 constructions referred to in the litigation, action in several cases was under reconsideration following fresh State Government circulars issued pursuant to Supreme Court directions governing demolition procedures.

Why did the court stress scientific crowd behaviour research?

Court said that religious gatherings differ fundamentally from political rallies, sporting events or public protests and therefore require a distinct administrative approach.

According to the judgment, devotional crowds are generally peaceful and self-regulating but become particularly vulnerable because participants tend to move collectively, pay less attention to their surroundings and tolerate physical compression, making crowd crushes more likely if spatial planning is inadequate.

The court observed that deploying more police personnel, erecting barricades and issuing standard operating procedures without understanding crowd science would not prevent future disasters. Instead, authorities must move "from reactive crowd control to proactive crowd behaviour research".

It also expressed concern that none of the affidavits demonstrated that authorities had commissioned or relied upon scientific studies or computational models on crowd behaviour despite repeated crowd-related incidents.

What recommendations did the court make?

Calling the absence of structured crowd science education a "governance failure", the court recommended that Uttar Pradesh universities introduce dedicated courses on crowd behaviour, psychology, disaster management and crowd flow modelling.

It further proposed establishing a Centre of Excellence for Crowd Science, Mass Gathering Safety and Urban Risk Management in collaboration with institutions such as IIT Kanpur or IIT Roorkee. The proposed centre would undertake research, maintain databases on crowd-related incidents, train officials and advise governments on evidence-based crowd management.

Court also suggested that the State consider creating a statutory commission on the lines of the Delhi Urban Art Commission and make it mandatory for authorities and event organisers to engage certified crowd behaviour experts while planning major public gatherings. It recommended integrating crowd science into master plans and building bye-laws of development authorities.

The high court observed that the right to life under Article 21 obligates the State not merely to avoid harm but to create conditions in which preventable disasters do not occur because of administrative or intellectual unpreparedness.

On the dispute before it, the court kept the demolition order against the petitioner in abeyance and granted liberty to approach the MVDA afresh, directing the authority to reconsider the matter in accordance with the latest State Government circulars issued pursuant to Supreme Court directions. It also directed that a copy of the judgment be forwarded to the Chief Secretary, the University Grants Commission and higher education authorities for future reference.

Case Title: Swami Shiv Swarupanand Ji Maharaj v. State of Uttar Pradesh & Others

Judgment Date: July 22, 2026

Bench: Justice Vinod Diwakar