Section 161(2) in The Orissa Motor Vehicles Rules, 1993
(2)No motor vehicle shall be drawn or towed by any other motor vehicle unless there is, in the driver's seat of the motor vehicle being drawn or towed a person holding a licence authorising him to drive the vehicle or unless the steering wheels of the motor vehicle being towed are firmly and securely supported clear of the road surface by some crane or other device on the vehicle which is drawing or towing it.