Vidhi Centre Seeks a ‘Mixed-Use Educational Building’ Category for Delhi’s PGs and Coaching Centres

The news

New Delhi. After the Satya Niketan building collapse, which this magazine carried on September 17, The Hindu on Thursday published a prescription for the regulatory gap behind it from Kartavi Satyarthi, Senior Resident Fellow at the Vidhi Centre for Legal Policy, a legal-policy think tank; what is new today is the fix. She describes a cycle in which investigations, suspensions of officials and arrests of landlords after each disaster “gain momentum for some time and slowly settle down”: “It is Satya Niketan now, it was a flooded basement in Rajinder Nagar two years ago.” Delhi, she writes, houses millions of students who come to join premier institutes or prepare for competitive government exams, feeding “a sprawling ecosystem of largely unregulated” paying-guest (PG) accommodations and coaching centres. A PG is a room or floor let out, usually with meals, to students or workers; many have grown from an extra room rented out into “full-blown commercial establishments”. Coaching centres also run from floors of buildings marked residential. Both turn a residential building partly or wholly commercial, which should attract different safety norms, but enforcement cannot identify such hybrids, and rules for schools and college hostels do not apply to them. Three instruments together create “an odd mismatch between the law on paper and the way it actually functions”. The Master Plan of Delhi (MPD), the statutory land-use plan, does not specifically mention PGs. The Unified Building Bye-Laws (UBBL) recognise coaching centres as educational buildings, but their development controls — limits on floor area, height, setbacks and the like — do not apply to them. The Ministry of Education’s 2024 coaching-centre guidelines “lack teeth” and cover only broad infrastructure. First, she proposes, the DDA and the MCD should recognise PGs and coaching centres as a separate land-use category of “mixed-use educational buildings”, with standards on fire protection, safe exits, minimum floor area per person and maximum capacity, in which owners could register their buildings. Second, since blanket standards with “little recourse for correction” invite rent-seeking, enforcement should help owners comply: a building safety task force or district-level committee of urban local body representatives under State oversight, periodic audits, a compliance resolution plan that grades gaps, with immediate closure where they are alarming, and annual reports to the State government on buildings shut and rehabilitated. The syllabus link is GS1 on urbanisation, GS2 on local government and GS3 on disaster management.

Static syllabus linkage

1. Delhi’s land use is planned by the DDA through a statutory Master Plan. The Delhi Development Authority (DDA) was set up under the Delhi Development Act, 1957 to prepare and enforce the Master Plan of Delhi; the Lieutenant-Governor is its Chairman. The first Master Plan came in 1962, followed by MPD-2001 and MPD-2021, notified in 2007, with MPD-2041 prepared as its successor. The plan zones land by use, and its mixed-use regulations decide which non-residential activities may run from residential plots; these were widened in MPD-2021 after the Supreme Court-monitored sealing of commercial premises in residential areas in 2006, in the M.C. Mehta litigation. Under Article 239AA(3)(a), land in Delhi lies outside the Delhi Legislative Assembly’s law-making power.
2. Bye-laws turn the plan into building rules, and the National Building Code supplies the safety floor. Building bye-laws set development controls — floor area ratio, ground coverage, height, setbacks, parking — and the approvals a building needs. Delhi’s Unified Building Bye-Laws, 2016 replaced the Building Bye-Laws of 1983 and apply across the city’s local bodies. The National Building Code of India, 2016, published by the Bureau of Indian Standards, is a model code whose Part 4 deals with fire and life safety; it binds only when adopted into bye-laws. The Code classifies buildings by occupancy: Group A is residential, covering lodging or rooming houses and dormitories among others, and Group B is educational, each with its own exit and fire requirements. A building that is sanctioned in one group and used as another escapes the rules that fit its real use.
3. The 2024 coaching guidelines are advisory because education and building regulation sit with States and cities. The Ministry of Education issued its Guidelines for Registration and Regulation of Coaching Centres in January 2024. They provide for registration, bar enrolment of students below 16 years, require at least one square metre per student in a class, mandate compliance with fire and building safety codes, and call for counsellors, with penalties of ₹25,000 for a first offence, ₹1 lakh for a second, and cancellation of registration thereafter. Per a PIB release, the guidelines were sent to States and Union Territories to consider “by way of appropriate legal framework”, because education is in the Concurrent List — Entry 25 of List III, moved there by the Forty-second Amendment, 1976. PRS tracks a Rajasthan Coaching Centres (Control and Regulation) Bill, 2025, one State’s move to legislate, and the Central Consumer Protection Authority separately polices misleading coaching advertisements.
4. The Rajinder Nagar deaths of 2024 showed what happens when sanctioned use and actual use diverge. On July 27, 2024, three civil services aspirants drowned when rainwater flooded the basement of a coaching centre in Old Rajinder Nagar that was being used as a library, although basements were permitted for uses such as parking and storage. The Delhi High Court transferred the investigation to the Central Bureau of Investigation, and in August 2024 the Supreme Court took suo motu cognisance of safety norms in coaching centres, remarking that centres flouting them had become “death chambers”. Under the Seventy-fourth Amendment, the Twelfth Schedule (Article 243W) lists urban planning, regulation of land use and construction of buildings, and fire services among municipal functions, which places day-to-day responsibility with the city’s civic bodies.

Why UPSC loves this

1. GS1 asks about the problems of urbanisation, and student hubs are a textbook case. The GS1 syllabus reads “urbanization, their problems and their remedies”, and UPSC asked in 2013 about the social problems that originated from the speedy process of urbanisation in India. Coaching hubs such as Mukherjee Nagar and Rajinder Nagar show informal conversion of housing, overcrowding and safety risk arising from a migration that the city never planned for.
2. GS2 and GS3 treat such deaths as failures of local government and disaster management. GS2 questions on the 74th Amendment ask why urban local bodies remain weak despite constitutional status, and this case shows the cost of split responsibility between the DDA, the MCD and the fire service. For GS3 disaster management, the National Disaster Management Authority’s guidelines on urban flooding (2010) and school safety (2016) are the natural references; answers that move from tragedy to institutional design stand out.
3. Interview boards ask aspirants about the coaching economy itself. Candidates who have lived in Delhi’s coaching hubs are often asked what they would change there as administrators; a clear view on classification, graded enforcement and student safety is a strong answer.

Analysis

1. The core failure is classification: buildings are regulated by what they were sanctioned as, not by what they are. A house converted into a thirty-bed PG or a floor turned into a two-hundred-seat classroom remains, on paper, a residential building, so the fire exits, occupancy limits and structural checks meant for dormitories or educational buildings are never triggered. That is why the author’s central proposal is a new category rather than more inspections: inspectors can only enforce rules that attach to a building. A “mixed-use educational building” category gives regulators a trigger and owners a standard to meet. The counter-view is that a new category with costly standards may push small landlords further into informality, renting rooms without registering; the author concedes this risk, which is why she pairs standards with supported compliance.
2. Recognising PGs as a land use will collide with residents, property values and the Master Plan’s logic. Formal recognition of PGs and coaching centres as mixed-use legitimises commercial conversion in residential colonies, which neighbours and RWAs often resist because of crowding, parking and noise. Delhi’s history of mixed use — the 2006 sealing drive and the widening of mixed-use rules in MPD-2021 — shows that such changes are politically fraught and slow. Yet refusing recognition has not stopped the market; it has only kept it outside safety rules. The counter-view deserves weight: the better answer may be supply — purpose-built student housing and more university hostels — which removes the pressure to convert family homes at all. A serious reform needs both a category for what exists and a plan for what should replace it.
3. Enforcement by crisis is itself a policy, and a bad one. The pattern the author describes — suspensions, arrests of landlords, sealing drives, then quiet — punishes after the fact and teaches everyone that the risk of enforcement is episodic. Post-disaster sealing also displaces students in mid-preparation and pushes rents up in surviving buildings, shifting the cost to those the drive is meant to protect. Periodic audits with published annual reports on buildings shut and rehabilitated convert enforcement from a reaction into a routine that can be measured. The counter-view is that Delhi already has many overlapping agencies, and one more task force without statutory powers or budget will repeat the failure; the proposal works only if the committee has legal backing and a single accountable chair.
4. The compliance-resolution plan is the most important idea and the least glamorous. The suggestion that enforcement should support owners — identify gaps, judge whether they can be fixed, close only where danger is alarming — follows the logic of responsive regulation described by Ian Ayres and John Braithwaite (1992), in which regulators begin with persuasion and escalate to sanctions only when needed. Blanket rules with no path to correction invite bribes, which the author calls rent-seeking, whereas graded enforcement lifts the bulk of buildings to standard instead of sealing a few for the cameras. Its risk is indefinite forbearance, where every gap becomes “capable of being addressed”; the plan must have deadlines, public disclosure and non-negotiable red lines such as blocked exits and occupied basements.
5. Students are consumers without information, and disclosure can do what inspection cannot. A student arriving from a small town chooses a PG or coaching centre on price, distance and word of mouth, with no way to know whether the building has two exits or a certified capacity. Registering buildings in a separate category would allow a public register showing each building’s audit status, which students and parents could check before paying. The state already polices misleading coaching advertisements through the Central Consumer Protection Authority; safety disclosure is the missing half of consumer protection. The counter-view is that price-sensitive students will still choose cheap and unsafe rooms, so disclosure complements minimum standards rather than replacing them.

Administrator's brainstorm