Auditing Delhi’s Heat Action Plan: A Ground Study | Part II

This is the second of a two-part series on how extreme heat governance in India discounts informal workers’ experiences.

The Anatomy of Administrative Heat Relief

THE ADMINISTRATION delivers where it can record delivery. Relief reaches the places that are easy to count, supervise and photograph, and does not reach workers who move through the day. India released its first Heat Action Plan thirteen years ago, national guidelines have been revised twice since 2016, and more than a hundred cities have adopted some version of the template. 

Across those same years the informal workforce the plans exist to protect has grown faster than the plans covering it. This is an experienced bureaucracy that has spent over a decade refining the same instruments against a heat load rising in step with the urban expansion the state calls progress. Thirteen years of practice have not widened the State's picture of who is vulnerable, and what this audit finds is not a bureaucracy lagging behind a moving target but one whose picture has never moved.

The Delhi Heat Action Plan 2026 delivers mainly relief through three mechanisms. They are fixed cooling centres, the distribution of objects at those centres, and the rescheduling of outdoor work. Each assumes that a worker can stop, travel to a listed location, wait there, receive what is being handed out, and return. Almost no one the Action Plan claims to protect can do this.

Women’s safety at cooling centres

Domestic and home-based workers are the clearest case. Their worksite is the private household, and every provision in the Action Plan is placed in public space, so they sit outside its spatial imagination altogether. The record shows the same absence. On June 6, 2026 we filed an application with the Revenue Department and District Disaster Management Authority, REVEN/R/2026/61640, asking six questions about women's safety at cooling centres. We asked for the standard operating procedures, whether female staff were posted, whether any women-only sections existed, whether closed-circuit cameras were installed, how many complaints had been received, and what coordination there was with the police and the Delhi Commission for Women. 

East district replied by dispatch 5801 to 5802, marking every question not applicable. West district replied by dispatch 2201, saying the first question did not pertain to its office and returning ‘nil’ against the rest. Of the 70 workers we interviewed, six were domestic workers. All six worked indoors with only a fan. All four carried drinking water from home. Three held an eShram card and one held nothing at all. None had received any alert, advisory or any equipment, and three of the four had dizziness, headaches and severe exhaustion this summer and rested at home. Sara*, thirty, working out of the jhuggi opposite Model Town metro, was asked what would help. She said cooler housing and a stable income.

How active and accessible are Delhi’s ‘Cooling Centres’?

Laakhan* sells at Majnu ka Tila. His locomotor disability already limits the days he can work, and through the extreme heat he works with no shelter within reach. Under Section 8 of the Rights of Persons with Disabilities Act, 2016, district disaster management authorities must include persons with disabilities in their safety planning and maintain a register of persons with disabilities in the district so they can be reached with early warnings. Our cooling centres application, REVEN/R/2026/61639, asked for the list of activated centres with their dates, hours, capacity, facilities, footfall and accessibility provisions. East district answered by dispatch 5803 to 5804, attaching 16 sites with hours, capacity and footfall, and nothing against accessibility. West district listed one centre – Hari Nagar Depot 3.

Homeless people are excluded by the hours and by the door. Of the seven cooling centres we audited, three closed before night falls – Delhi Cantt at 6 p.m., GTB Nagar at 7 p.m., Dhaula Kuan at 8 p.m. AIIMS stays open through the night but requires an Aadhaar card from 10 p.m., and the staff explained the rule by reference to the people who come after dark. At GTB Nagar, District Disaster Management Authority staff had tied the chairs together to stop students gathering, and the chairs have armrests, so nobody can lie down on them. The category the Action Plan writes as universal, outdoor workers and vulnerable persons, describes one kind of worker. He is male, able-bodied, housed, and free to leave his post. 

The misrecognition starts before the list of beneficiaries. The April 29, 2026 order issued by the Government of the National Capital Territory of Delhi justifies itself in its opening lines by reciting that Delhi's temperatures frequently exceed 44 to 47 degrees, posing serious health risks to outdoor workers and vulnerable populations.That is the trigger and the object of protection in a single sentence, and the trigger is dry-bulb temperature. 

Our own readings show what it misses. At Jama Masjid on May 30, 2026, the air read 31 degrees with humidity at 50 per cent, which put the heat index in the Action Plan's caution band. At Dhaula Kuan Bus Stand on June 8, 2026, at around noon, the air was 37 degrees with humidity at 61 per cent, which put the heat index in extreme danger, the most severe reading recorded across all seven site audits. Neither morning came anywhere near 44 degrees. Humidity is what makes the difference, because a body cannot shed heat by sweating into air that is already saturated, and the shade thermometer does not register it. Six of the 55 workers interviewed in the second round reported fainting or collapsing this summer, either being affected themselves or knowing others who were affected. Suraj*, a vendor at Model Town, had fainted that morning and travelled some distance to get medicine. A threshold set this high assumes the bodies working under it can take more heat than other bodies.