The Supreme Court in Maniyar Iliyaz v. P. Ayyappan & Ors. recognised the right to walk on footpaths as a fundamental right under Article 21 of the Constitution. The Court held that while street vendors have a constitutionally protected right to livelihood under Article 19(1)(g), this right cannot override pedestrians' right to use public walkways. Both rights must be balanced. Vendors encroaching on footpaths violate the fundamental right to walk, which is integral to life and personal liberty.

This judgment sits at the intersection of three constitutional provisions: Article 21 (right to life and personal liberty), Article 19(1)(g) (right to practise any profession or carry on any trade), and Article 300A (right to property, relevant to vending spaces). The Court's reasoning follows the proportionality doctrine — no fundamental right is absolute, and when two rights collide, courts must balance them by examining which restriction is the least invasive while achieving a legitimate state aim.

The right to livelihood as part of Article 21 was first firmly established in Olga Tellis v. Bombay Municipal Corporation (1985), where pavement dwellers challenged eviction. The Court held that livelihood is integral to life, but subject to procedure established by law. Street vendors' rights were later codified in the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014, which mandates Town Vending Committees and designated vending zones.

Maniyar Iliyaz adds a counter-right: the pedestrian's right to walk is equally rooted in Article 21 as a component of the right to move freely and with dignity. This creates a horizontal conflict between two Article 21 claimants. The resolution lies in the regulatory framework — vendors in designated zones are protected; those encroaching on footpaths are not. The judgment reaffirms that Article 19(1)(g) rights are subject to reasonable restrictions under Article 19(6) including public order and the rights of others. CLAT PG examiners frequently test the hierarchy of precedents in Article 21 expansion cases and the specific statutes governing street vending.