Accessibility Audit of the Mumbai Suburban Railway Stations

Audit Conducted between 2nd November – 2nd December 2016 as directed by the Bombay High Court, by Collective for Spatial Alternatives (CSA) and Indian Center for Human Rights and Law (ICHRL). Click to download full report


Introduction: Accessibility and Barrier Free Built Environments

Mumbai’s Suburban Railway Network provides an affordable and efficient mode of transport to more than 7.5 million commuters daily, but suffers from severe overcrowding, unsafe conditions, and poor accessibility for persons with disabilities. In October 2016, the Bombay High Court directed the petitioners of a PIL (No. 27 of 2007) filed by the Indian Center for Human Rights and Law & Others to undertake an accessibility audit of all the Suburban Railway stations in Mumbai. It was undertaken by the Collective for Spatial Alternatives (CSA), an urban research and planning group, along with the Indian Center for Human Rights and Law (ICHRL).

The purpose of this audit is to identify all the obstacles and barriers to accessibility for persons with disabilities and senior citizens on the Suburban Railway network, in order to assist the Railway authorities in improving its facilities and services, and produce an environment that enable all people to access its transit infrastructure independently and on an equal basis.

The survey was conducted based on the guidelines prepared and published by the Ministry of Urban Development in 2016, called the Harmonised Guidelines and Space Standards on Barrier Free Built Environment for Persons With Disabilities and Elderly Persons, 2015 (HG2015) and the Railway Board guidelines for passenger amenities for persons with disabilities, 2013 (RBG2013).

The Findings in Brief:

The accessibility audit of the Mumbai Suburban Railway stations reveals a very low general level of compliance to the Ministry of Urban Development and Railway Board guidelines. The overall compliance level is 37.7% for all stations, and a slightly higher 39.4% for all the major stations. The Western Line (40.6%) fares better than the Central Line (38.6%) for all their stations overall, but the major stations of the Central Line (42.5%) do marginally better than the major stations of the Western Line (41.9%). The Harbour Line is well below the average at 33.8% overall compliance, with its major stations (32.8%) doing worse than the overall Harbour Line score.

Stations of the Island City and Suburbs fare similarly for all lines. The major stations of the Suburbs do better (44.6%) than those of the Island City (42.1%). While the stations of the Central Line in Mumbai’s Suburbs do better than others (47.5%), the Harbor Line stations in the MMR Region and beyond do most abysmally at 27.9%.

Of all the 122 stations, only 16 (or 13%) have achieved compliance of over 50%, however, none of them crosses the 60% mark. While 106 stations score less than 50% in compliance, 48 stations (or 40% stations) have compliance levels of less than 35%. Of all stations, Matunga Road, Dadar (Central) and Kanjurmarg do best comparatively with 57.8%, 57.7% and 57.6% respectively.

General Observations:

Most of the entrance areas are inaccessible for persons with disabilities. The quality of construction is extremely poor generally, with uneven surfaces, broken tiles, and improper details. Rarely does one find guiding paths from drop-off points to entrance areas, or ramps for ingress into the station buildings. Booking offices have shown some improvements due to construction of special counters for wheelchair users and visually impaired persons, but almost no station has trained personnel to assist persons with disabilities. No station has provided tactile schedules. Though some platforms have guiding paths and audio signals to assist persons with disabilities, in many cases the location of these were improper, making it difficult if not dangerous for commuters. Most platforms did not have toilets for persons with disabilities. Circulation features are often provided without a clear understanding of the needs of persons with disabilities and without an overall conception. Almost always, stairs have inconsistent tread and riser ratios, as no edge indicators. Ramps, where provided, have to steep a slope for a wheelchair user. In most stations toilets for persons with disabilities are absent, and wherever these are built, they are insufficient in number, and almost always locked.


Survey Approach and Grading Method:

The audit was devised based on two guidelines – the HG2015 and RBG2013. To identify the barriers and obstacles to accessibility, the survey methodology was developed based on the way commuters use the railway stations and its various services, as a set of spaces and features. Spaces are understood as well defined areas or areas that serve a broad function – such as approach & entrance, ticket purchase, horizontal movement, vertical movement, waiting, resting, administration, etc. By features we mean the set of properties, elements or objects that constitute, are contained within, or help transition through these spaces, such as counters, booths, stairs, paths, audio or visual signs, illumination, surfaces, etc. These spaces and features were then investigated for their presence / absence and accessibility in the form of 104 queries, that were recorded as graded responses. The findings were eventually assessed as compliance (percentage) with the above mentioned guidelines. The findings were also analysed and compared along the three lines – Western, Central and Harbor (including Trans-Harbour) – and along three regions – Island City, Mumbai Suburbs and the Metropolitan Region (MMR and Beyond). Here is an overview of the 8 Spaces and some of the Features surveyed, and some of the survey findings (for the detailed findings and analysis, download the full report here).

(1) Entrance Areas: which includes the approach to the buildings and their visibility. The features that were inspected were steps, ramps, handrails, signages and surface quality of the floor. Some findings:


(2) Ticketing Counters: include the booking offices, and were inspected for features such as accessible counters, interfaces, communication of schedules and prices, and illumination of the area. Some findings:


(3) Platforms: the most conspicuous space of every station, platforms are the one or many areas to board and alight trains, and were assessed for its various features such as guiding paths, safety indicators and elements, sound signals, directions, schedules and other signs, quality of floor surfaces, entry and exit points, toilets, etc. Some findings:


(4) Circulation: in this case is understood as the spaces that help commuters move horizontally in every station, and were inspected for sizes, obstructions, guiding paths, signs, surface quality, benches, etc. Some findings:



(5) Level Changes: are spaces that enable to move people vertically – using features such as stairs, ramps, lifts, etc. These were evaluated for safety, surface quality, communication, sizes, guides, etc. Some findings:

level changes.jpg

(6) Toilets: were be assessed for their suitability for persons with disabilities. Features such as signs, mirrors, handles, doors, grab bars, alarm systems, faucets, surfaces, etc. will be assessed for safety, communication, location, sizes, etc.:


(7) Waiting Areas / Offices / Eateries: consist of the spaces for administrative and service functions, and features such as counters, tables, seats, audio and visual aids, etc. were inspected:


(8) Parking / Drop Off Areas: were evaluated for adequacy in terms of number of parking spaces for persons with disabilities, visual indicators, seamless approaches and distances:



Special care was taken to understand the constraints within which the Railways operate while formulating the survey. Through various affidavits, the Railways has expressed its difficulty in implementing accessibility guidelines due to congestion, heavy flow of passengers and space constraints. It is with an understanding of these constraints that the questions have been framed. For instance, since ramps may not be possible due to limited space on some stations except with considerable expense and restructuring, the survey accepts accessible lifts as an alternative. Similarly, it may quite difficult for the Railways to provide parking spaces on some stations, hence the survey assumes well designed drop off points and approach areas as an acceptable substitute. However, none of these constraints can be considered too severe to prevent the Railways from finding any solutions to make spaces or features accessible.

Click to download full report


Discriminatory Living Standards: FSI, Tenement Densities and Building Controls for Low Income Housing in the RDDP 2016

By Hussain Indorewala | Shweta Wagh

Published on BlogURK 

With an explicit desire to champion the interests of the real estate industry (“ease of doing business”) the recently released Revised Draft Development Plan (RDDP) proposes unprecedented dilutions of development control regulations in the city, especially for rehabilitation projects. In this essay, we will discuss the prescribed norms for Floor Space Index (FSI), tenement densities and environmental controls for low income housing as proposed in the RDDP, and point out how these will create sub-standard living conditions for rehabilitated households. We will show how proposals of the Plan are discriminatory in terms of the access to infrastructure they will provide, as well as the quality of the physical environment they will create.

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Does Mumbai have a shortage of housing? : Scroll Article

Does Mumbai really need 11 lakh more houses?

published in | by Hussain Indorewala

22nd March 2016

It is striking how policy debates on housing devolve very quickly into what can be called the numbers game. The notion of scarcity shapes the assumptions and the approach to the question of housing. This notion is very useful – developers need it, the state can exploit it and architects and designers love it. Numerous seminars and conferences are organised to address this problem of affordable housing which seems to be aimed at understanding not what housing is or what inhabitants need, but to figure out how to make intractable urban dwellers accept the sort of housing that the state-enabled private enterprise can profitably produce.

Let us indulge for the moment in this numbers game….

[read full article here]

Right to the City Course: Ideas, Movements, Possibilities

Presented by KRVIA Design Cell Academy and CSA
Nov 2–8, 2015 @Studio X Mumbai and KRVIA



The RIGHT TO THE CITY Course is an initiative to explore the concept, practice and possibilities of the Right to The City framework. Rooted in the history and socio-spatial development of the city of Mumbai, it will seek to understand how social movements have always claimed their right to the city, to resist, to create new imaginations and practical alternatives for urban life, based on solidarity and mutual aid. The program will also explore the origins and nature of urban struggles around the world, and explore the scope and scale of the movement towards the building of democratic, egalitarian and environmentally just cities. The program will include city walks, seminars, presentations and conversations – and is open students, researchers, activists, and anyone who is interested in these, and related questions. Read or download more information here.


The course will include presentations, guest lectures, seminars, film screenings and city walks. Each day will begin with a presentation that will set up the seminar and subsequent sessions. Take a look at the schedule here.



CALL: +91 9819987998



Deposition at the Independent People’s Tribunal on the Coastal Road : Hussain Indorewala


This presentation will try to show why the Coastal Road Project (CRP) is sure to be counter-productive from the perspective of traffic congestion management, wasteful in terms of public expenditure, disruptive in terms of ecology and livelihoods, and ignores cheaper and more efficient alternatives. The project will increase the number of vehicles on the road, cause considerable environmental damage and adversely impact livelihoods of fishing communities. Moreover, as a project that serves to transport not more than 1.5% of the city’s population on any given day it is more of a private amenity than a public good. And despite doing nothing to ease the burden on the congested public transport network, the public will be made to finance this fundamentally in-egalitarian project.

Download full document here

Heritage in the Post-Industrial City

Discourses on Architectural Heritage, De-politicisation of Space and Issues of Socio-cultural Continuity in Mumbai’s Historic Neighbourhoods

By Shweta Wagh | Published in the Intach Journal of Heritage Studies Vol 1

In the context of the economic restructuring of the city from a landscape of production to a landscape of consumption, there has been a general shift in the theory and practice of conservation. This paper will look at discourses centred around heritage conservation in Mumbai with the particular intent of examining how these play out in a post-industrial city attempting to demystify some of the rhetoric adopted by conservationists. It will try to show how conservation discourses and practices tend to align with the interests of dominant groups in the city, often insensitive to the interests of marginalized groups. In this process, landscapes of the city such as its industrial cores, places of workers housing, inner cities, gaothans and koliwadas which once were landscapes of manufacturing, commerce and productivity are relegated to the margins. As histories are constructed around imagined communities, landscapes are commodified, transforming traditional neighbourhoods into consumable artefacts and aestheticised enclaves. The paper argues for the need for alternative frameworks which are inclusive and accommodative of the needs and interests of local communities and address issues related to sociocultural continuity in historic landscapes.

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