Dear All, Hope all of your doing great there!
At the outset, I would like to commend the Ministry of Social Justice & Empowerment and the Department of Empowerment of Persons with Disabilities (DEPwD) for issuing these Revised Comprehensive Guidelines dated 01.08.2025. The document reflects a forward-looking and techno-positive approach, encouraging the independent participation of candidates with disabilities through technological aids such as software-enabled laptops/desktops, screen readers, voice recognition, Braille/large print materials, and other assistive technologies. The emphasis on gradually shifting from scribe dependency to technology-based support is a progressive step in ensuring both inclusivity and exam integrity, while aligning with the evolving skill requirements of professional and technical fields. The provisions also clearly seek to harmonize implementation with the RPwD Act, 2016, the Public Examination (Prevention of Unfair Means) Act, 2024, and recent Supreme Court directions, which is a commendable legal alignment. That said, I kindly seek/consider the following observations/suggestions for possible clarity and smoother implementation: 1. Transition to “Pool of Scribes” – Implementation Clarity • While the Guidelines provide a two-year non-negotiable timeframe to develop a vetted pool of scribes, some Examining Bodies (EBs) — particularly state-level or smaller institutions — may need interim milestones or periodic monitoring to ensure compliance. • It may be advisable to prescribe a half-yearly compliance reporting mechanism to DEPwD during the two-year transition to prevent last-minute rush or non-compliance. 2. Technology Infrastructure Standardisation • The document itself mentions multiple software examples but leaves procurement and compatibility decisions to EBs. A centrally maintained panel of approved assistive software/hardware that meets accessibility standards for Indian languages could reduce procurement delays and ensure uniform quality. This can be supported by government-negotiated licensing for cost efficiency. 3. Real-Time Tech Stupport During Exams • Candidates using technology such as JAWS or voice recognition may face runtime glitches. It is suggested to mandate that EBs provide on-site technical support staff during the examination to avoid technology failures affecting candidate performance. 4. Fairness in Scribe Qualification Criteria • The “two to three academic years below” criterion for scribe qualification is logical for neutrality, but clarification may be needed for open-format online recruitment exams (where no fixed academic stream is prescribed) to avoid confusion during eligibility checks. 5. Complaint Resolution Mechanism • While the Guidelines mandate a dedicated complaint resolution system, it would be beneficial to prescribe maximum turn-around times (TAT) for addressing PwD grievances, especially in the pre-exam stage, where delays could deny candidates their rightful accommodations. 6. Uniformity in Medical Certification Formats • Appendix-I medical certification validity is up to one year. For chronic/ permanent disabilities, a validity of up to three years or permanent certification for exam purposes may be considered to reduce repetitive procedural burden on candidates. 7. Data Privacy Implementation • The Guidelines rightly align with the Digital Personal Data Protection Act, 2023. However, a minimum security compliance checklist for EBs handling disability data could be included to ensure that sensitive information is not stored insecurely. 8. Accessibility in CBT Centres • With greater move towards CBT mode, physical accessibility measures must also be complemented by digital accessibility audits of the exam interface software to ensure compatibility with assistive technologies. In sum, these Guidelines are a progressive step towards balancing inclusion and examination integrity, and with a few refinements in implementation and monitoring, they can significantly improve the experience and fairness for Persons with Disabilities in competitive public examinations. Kind regards, Kallem Pavan Advocate Link: https://cdnbbsr.s3waas.gov.in/s3e58aea67b01fa747687f038dfde066f6/uploads/2025/08/20250804901462826.pdf -- Thanks and regards, Pavan Kallem -- Disclaimer: 1. Contents of the mails, factual, or otherwise, reflect the thinking of the person sending the mail and AI in no way relates itself to its veracity; 2. AI cannot be held liable for any commission/omission based on the mails sent through this mailing list.. Search for old postings at: http://www.mail-archive.com/[email protected]/ --- You received this message because you are subscribed to the Google Groups "AccessIndia" group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected]. To view this discussion visit https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CAPGc7vU7hYByWBuZozf8ihFARZ6qLBe1CDkq%2B2EjYVgqCD6jFg%40mail.gmail.com.
