Owner of Jabbar Travels, Shakeel Jabbar and driver Feroze were arrested from Kothakota in Mahabubnagar district, Wanaparthy DSP Srinivas Reddy told PTI over phone.
The owner and the driver were booked under various sections of Indian Penal Code (IPC) and Motor Vehicles Act, he said.
The owner failed to have a second driver in the bus, allowed excess passengers, failed to maintain a list of passengers and allowed unaccounted-for cargo, the DSP said.
Forty-five passengers, including a baby girl, were charred to death and seven others were injured when the luxury bus was engulfed in flames near Palem village early hours yesterday.
Fifty-two persons including 50 passengers were travelling in the ill-fated Volvo bus.
Bangalore-based Jabbar Travels had leased the bus, which has Andhra Pradesh number plate and sitting capacity of 43+2.