'Wheeling Not An Act Of Bravado': Karnataka High Court Suggests Amending IPC, MV Act To Bring Stringent Provisions Against Bike Stunts

The Karnataka High Court recently suggested the State government and its law enforcement agencies to legislate necessary legal provisions and take stringent measures to suppress the perilous activity of "wheeling" by two wheeler riders.

A single judge, Justice V Srishananda said, “Legislature has to take into consideration that existing statutory provisions relating to reckless and negligent driving is hardly sufficient to curb the menace and therefore, to fill up the legislative vacuum, suitable and stringent provisions are to be incorporated by amending the Indian Penal Code and Motor Vehicles Act to complement each other.”

Emphasising that younger generation riders of the motorcycle are under the misconception that the act of wheeling is bravado and indulge in such perilous stunts being unaware of the grave risks involved in the said act.

Furthermore, the act of wheeling was initially confined to urban areas on sufficiently wide and arterial roads and over passage of time, this hazardous and perilous practice had extended its tentacles even to rural areas.

The court said, “Wheeling not only results in endangering the life and safety of the rider or pillion rider but may as well pose a serious threat to the general public at large. Thus, the act of a few unscrupulous and unmindful youths in indulging the wheeling would definitely disturb the public order and tranquility.”

Stating that provisions of Motor Vehicles Act, 1988 and the Indian Penal Code, 1860, are not adequate for enforcement agencies to effectively curb the menace of "wheeling" as offence of reckless driving is bailable in nature, the court suggested, “Taking note of the galloping trend and alarming rise in such incidents, it is now the bounded duty of the State and its law enforcement agencies to legislate necessary legal provisions and to take stringent measures to suppress the perilous activity.”

The suggestion was made while dismissing a bail petition filed by one Arbaz Khan who has been arrested for the offences punishable under Sections 132, 109(1), 121(1), 115(1), 352, 351(2), 238 read with Section 3(5), 281, 125, 125(a) of the Bharatiya Nyaya Sanhita, 2023 (for short, 'the BNS') Sections 183, 184, 192, 196 and 177 of the Indian Motor Vehicles Act.

The police have alleged that the accused along with two others indulged in adventure activity namely 'Wheeling' or 'wheelies' (lifting the front wheel while the motorcycle is moving) in October 2024.

When they fell down and the Police went to help them, they started abusing the complainant and sub-staff in filthy language. They even went to the extent of manhandling the Police personnel and the mobile telephone possessed by sub-staff was snatched and thrown into Tungabhadra canal.

Rejecting the petition the court took judicial notice of the galloping trend of such perilous misadventure. It said “In curbing the acts of a few unscrupulous elements that have a deleterious impact upon society at large, thereby disturbing public order and endangering the safety and security of citizens. Under such circumstances, this Court is of the considered opinion that the discretionary power vested in it cannot be exercised in favour of the applicant resulting in rejecting the request for grant of bail.”

It added “The petitioner is the habitual offender. In the case on hand, when he fell down while he had indulged in the act of wheeling, police went to help them out; but the petitioner and other two persons picked up the quarrel with the police personnel and they not only abused the police in filthy language but also high handedly caused injuries to the police personnel besides throwing away the mobile telephone of sub-staff of the police, this Court is of the considered opinion that petitioner is not entitled for grant of bail.”

Finally it said, “Mere filing of the charge sheet, by itself, cannot be held sufficient to entitle the petitioner to an order of bail.”

Appearance: Advocate Sadiq N. Goodwala for Petitioner.

HCGP Girija S. Hiremath for Respondent

Citation No: 2025 LiveLaw (Kar) 174

Case Title: Arbaz Khan AND State of Karnataka

Case No: CRIMINAL PETITION NO. 101267 OF 2025

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