Fwd: Corrigendum Required for Double Decker Bus tender
Vaishnavi Jayakumar (Inclusive India)
From: Vaishnavi Jayakumar (Inclusive India) <vaishnavi...@inclusiveindia.info>
Date: Wed, 14 Jan, 2026, 12:47
Subject: Corrigendum Required for Double Decker Bus tender
To: <tra...@tn.gov.in>
Cc: <md....@tn.gov.in>
14 January 2026
1. J. Chiru
Secretary, Transport Department
Government of Tamil Nadu
Fort St. George
Chennai 600009
Email : tra...@tn.gov.in
2. Dr. T. Prabhushankar
Managing Director,
Metropolitan Transport Corporation
Pallavan House
Pallavan Salai, Chennai - 600002
Email : md....@tn.gov.in
Subject : Corrigendum and addendum required in Double Decker Bus tender (Reference Number 48003/Proj/MTC/2023, ID number 2026_MTC_640505_1)
Sir,
The tender referenced above was published on 8 January 2026 titled ‘Procurement, Supply, Operation and Maintenance of 20 Double Decker Air Conditioned Electric bus and Development of Allied Electric and Civil Infrastructure on Gross Cost Contract model in MTC Ltd’
As communicated earlier to your offices, the legal mandate of bus accessibility for citizens with disabilities necessitates (broadly),
step-free boarding (low floor vehicle or BRTS),
wheelchair docking space with safety restraints, adjacent controls and handrails, priority seats without impediments,
adequate contrast of element demarcation
and a multi-modal passenger information system.
(The Freedom Of Movement Coalition’s model bus accessibility specifications — UBS-II, Bus Body Code or better — shared earlier with your offices are annexed again for more details.)
Unfortunately, the tender is silent on these key details - the absence of which will at worst, prevent entry of passengers on wheelchairs or mobility aid users and at best negate many passengers with disabilities from experiencing bus travel on an equal basis with others.
While Vol II of the tender documents (Draft Concessionaire Agreement) references disability in 5.5.4 (Equal Opportunity in Employment), 5.9 (Aesthetic design standards), 14.1.2 (information signage) and in one place, erroneously the repealed 1995 Disability Act, but in 2.4. while on the one hand requiring ‘ease of boarding and alighting especially for ladies,children, senior citizens and Persons with Disabilities (PwDs) contradicts this mandate in Schedule AA -41 - ‘Specifications Of Pure Electric Ac Double Decker Type-I With Roof Bus’, table serial number 8 reads ‘Floor height at service doors at curb weight - Maximum 900 mm’’.
For wheelchair users of Type-I intra-city non-BRT buses, the maximum stepless entry height is 400 mm, with 900 mm floor height being high floor with 2 risers (steps). With the advantages of fewer underfloor components in electric buses, the service door entry can be even lower - in fact the Switch single deck electric buses currently running in the city can achieve 280 mm height via kneeling.
As per Switch Mobility’s electric double-decker bus website brochure, the company also offers a low-floor variant of the same model - EiV-22.
You are requested to therefore issue a corrigendum specifying the maximum GFH (ground-to-floor height) as 400 mm instead of 900 mm so as to comply with the Madras High Court’s directive in 2023:MHC:2214 (Vaishnavi Jayakumar v. The State of Tamil Nadu and Ors. (Writ Petition No.29914 of 2022 dated 18 April 2023) - G para (xi) “… all endeavour should be made to purchase only low floor buses in the ensuing years, in respect of the fleet which are to be run within the cities and its suburbs”;You are requested to therefore issue a corrigendum specifying the maximum GFH (ground-to-floor height) as 400 mm instead of 900 mm so as to comply with the Madras High Court’s directive in 2023:MHC:2214 (Vaishnavi Jayakumar v. The State of Tamil Nadu and Ors. - Writ Petition No.29914 of 2022 dated 18 April 2023) - G para (xi) “… all endeavour should be made to purchase only low floor buses in the ensuing years, in respect of the fleet which are to be run within the cities and its suburbs”;
Furthermore going by the design shortcomings (as per the Bus Body Code AIS-052 read with AIS-153) in currently running electric buses, ignored feedback in Mumbai double-decker buses, and the AIS-139 handrail deviations in the recently inaugurated double-decker tourist bus, including more details about the accessibility-specific requirements as per the Freedom of Movement model bus specifications would be essential as it appears that ARAI is failing to ensure bus safety and bus body code compliance in its type approval process.
You will appreciate that any attempt to procure non-compliant type I buses for intra-city use buses will only perpetuate the illegality of adding public service vehicles that do not meet the needs of the disabled and others with mobility issues like aged, pregnant women, medically unfit etc.
I look forward to the publishing of the detailed corrigendum and addendum at the earliest, given that the pre-bid clarification meeting was already scheduled for 13-1-2026 and the tender closing date of 7 Feb 2026 is not far away,
Sincerely,
Vaishnavi Jayakumar
Member - Freedom of Movement Coalition
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