Mandating Digital Accessibility and Flexible Scribe Policies in Public Examinations: Commentary on Mission Accessibility v. Union of India, 2025 INSC 1376

I. Introduction

The judgment in Mission Accessibility v. Union of India, 2025 INSC 1376, marks a significant development in India’s disability rights jurisprudence, specifically in the context of public examinations and recruitment to the higher civil services.

The Supreme Court, exercising its civil original writ jurisdiction, addressed systemic barriers faced by visually impaired candidates and other persons with benchmark disabilities (PwBD/PwD) in the Civil Services Examination (CSE) conducted by the Union Public Service Commission (UPSC).

The core issues before the Court were:

The rigidity of UPSC’s requirement that candidates furnish scribe details at the time of application (long before the exam date), and whether this violated the equality and non-discrimination guarantees of Articles 14, 16 and 21 of the Constitution and the Rights of Persons with Disabilities Act, 2016 (“RPwD Act”).
The demand that visually impaired candidates be permitted to use laptops with Screen Reader Software and receive question papers in accessible digital formats.

While the petition began with specific grievances, the Court’s response was structural: it converted an individual case into an institutional mandate, requiring UPSC and the Union of India to plan, standardise, and operationalise digital accessibility across examination cycles.

II. Background and Procedural History

1. Parties

Petitioner: Mission Accessibility – an organisation working for advancement of the rights of persons with disabilities.
Respondent No. 1: Union of India – represented through relevant Ministries, later specifically involving the Department of Personnel and Training (DoPT) and Ministry of Social Justice and Empowerment.
Respondent No. 2: Union Public Service Commission (UPSC) – the constitutional body conducting the Civil Services Examination.
Respondent No. 3: Department of Personnel and Training (DoPT) – impleaded later by order dated 6 May 2025.

2. Reliefs Sought

The petitioner sought multiple directions, principally:

A declaration that the “Impugned Requirement” – i.e., the mandatory requirement to furnish scribe details at the time of application – is arbitrary and violative of Articles 14, 16 and 21 and the RPwD Act.
Removal of the mandatory early-stage disclosure of scribe details and permission to furnish/modify such details at a reasonable time closer to the examination, including at any time before any given stage.
Permission for visually impaired candidates to:
- Use laptops with Screen Reader Software at all stages of the Civil Services Examination.
- Receive question papers in accessible digital formats.

3. Interim Developments

a. Order dated 6 May 2025

The Court allowed impleadment of DoPT as Respondent No. 3 and required:

UPSC’s counsel to confer with the ASG representing DoPT and address apprehensions of disabled candidates.
Filing of an affidavit by a competent UPSC officer regarding change of scribe.

b. UPSC’s first affidavit and order dated 9 May 2025

UPSC reported having received about 27 requests from PwBD/PwD candidates seeking change of scribe and stated these would be examined on merit, with a public notice posted on its website. The affidavit, however, was silent on Screen Reader facilities.

On 9 May 2025, the Court:

Directed that all requests for change of scribe by entitled candidates under the CSE Rules, 2025 be entertained up to 18 May 2025 and decided by a reasoned order within three working days.
Required UPSC to file a specific affidavit on the issue of using computers with Screen Reader Software in the forthcoming preliminary examination.

UPSC expressed concern that immediate universal rollout of Screen Reader-based facilities for the 25 May 2025 preliminary examination was logistically infeasible and sought time.

c. Additional affidavit dated 12 September 2025

By its additional affidavit (noted during hearing on 31 October 2025), UPSC:

Conceded, in principle, to introducing Screen Reader Software for visually impaired candidates in exams conducted under its aegis.
Emphasised that it lacked its own exam infrastructure and was dependent on State Governments, district authorities, schools and colleges for centres, thereby complicating uniform technological deployment.
Undertook to introduce Screen Reader facilities at the “earliest possible juncture” after ensuring feasibility, readiness, comprehensive testing, and safeguarding exam integrity.

d. Petitioner’s concerns

The petitioner welcomed the in-principle decision but pointed out the absence of:

a definite roadmap,
a timeframe, and
clearly defined operational modalities for implementation.

The worry was that a progressive policy declaration, without structured implementation, would leave candidates in continued uncertainty.

4. Final Hearing and Disposition

After hearing both sides and examining the materials, the Court concluded that much of the grievance had been substantively addressed in principle. Nonetheless, recognising the gap between policy and practice, it issued detailed operational directions and retained limited supervisory jurisdiction by listing the matter on 16 February 2026 for compliance affidavit.

III. Summary of the Judgment

The Supreme Court:

Acknowledged the constitutional mandate of substantive equality and the requirement that legal rights of persons with disabilities be translated into lived realities, particularly in high-stakes public examinations.
Recognised UPSC’s in-principle decision to introduce Screen Reader Software and accessible digital formats for visually impaired candidates as a “significant policy advancement”.
Held, however, that such a decision could not remain abstract; it required a concrete plan, timeline, and standardised guidelines.

To that end, the Court:

Mandated flexible scribe policies
UPSC must, in every examination notification:
- Permit candidates eligible for a scribe to request change of scribe up to at least seven days prior to the examination date.
- Objectively consider each such request and decide it by a reasoned order within three working days.
Required a detailed Screen Reader implementation plan
Within two months, UPSC must file a comprehensive compliance affidavit specifying:
- Plan of action and timeline for deployment and use of Screen Reader Software for visually impaired candidates.
- Steps for testing, standardisation, and validation of software and related infrastructure across all or designated examination centres.
- The feasibility of making this facility operational for all eligible candidates from the next examination cycle.
Directed formulation of uniform guidelines and protocols
UPSC, in coordination with:
- the Department of Empowerment of Persons with Disabilities (DEPwD), and
- the National Institute for the Empowerment of Persons with Visual Disabilities (NIEPVD),
must formulate uniform guidelines and protocols for:
- use of Screen Reader Software, and
- other assistive technologies,
ensuring standardisation, accessibility, and security of the examination process.
Obligated the Union of India to provide full support
The Union of India (through DoPT and Ministry of Social Justice and Empowerment) must extend all necessary administrative and technical support to UPSC and facilitate coordination with State Governments and examination authorities.
Emphasised twin goals: accessibility and integrity
The implementation must ensure:
- full accessibility for eligible candidates; and
- maintenance of sanctity, confidentiality and fairness of the examination process.

The Court explicitly linked these directions to the enforcement of Articles 14 and 21 read with the RPwD Act, and reaffirmed that rights of persons with disabilities are not benevolent concessions but constitutional entitlements under Articles 14, 19 and 21.

IV. Detailed Analysis

A. Constitutional and Statutory Framework

1. Constitutional Provisions

Article 14 – Equality before the law and equal protection of the laws. The Court stresses that equality “demands not uniformity but the removal of barriers”. This is a classic articulation of substantive equality, acknowledging that identical treatment can perpetuate inequality when persons face structural disadvantages.
Article 16 – Equality of opportunity in matters of public employment. While not elaborated in depth in the excerpt, any barrier preventing PwBD candidates from effectively competing in recruitment examinations directly undermines Article 16.
Article 19 – Freedom-related rights, here invoked in para 13 to underscore that participation in public life and governance is part of the citizen’s broader civil and political freedoms.
Article 21 – Right to life and personal liberty, expansively interpreted to include dignity. The Court squarely links accessibility in examinations with the “right to live with dignity”.

2. Rights of Persons with Disabilities Act, 2016

The RPwD Act gives concrete statutory form to the constitutional promise of equality and non-discrimination for persons with disabilities. Although the judgment does not quote specific sections, its reasoning is anchored in:

Section 3 – Equality and non-discrimination: the State shall ensure that persons with disabilities enjoy rights equally with others and are not discriminated against on the ground of disability.
Concept of “reasonable accommodation” (Section 2(y)): modifications and adjustments not imposing a disproportionate burden, needed to ensure that persons with disabilities can enjoy rights on an equal basis. The directions on scribe flexibility and Screen Reader facilities operationalise this principle.
Sections related to education and employment (e.g., Sections 16, 17, 19, 20): these contemplate removal of barriers in the process of education, assessment and public employment. Examinations are a crucial bridge between education and employment; inaccessible exams undermine the entire scheme.

The Court’s insistence on concrete planning and standardisation is, in substance, a demand that UPSC discharge its obligations as a “public authority” under the RPwD Act to ensure universal design and reasonable accommodation in its processes.

B. Issues Before the Court

The key legal and practical questions were:

Whether UPSC’s then-existing scribe-related procedures – especially the requirement to fix scribe details at the application stage – violated the constitutional and statutory rights of disabled candidates by denying them flexibility to respond to real-life contingencies.
Whether persons with visual disabilities are entitled to modern assistive technologies like Screen Reader Software and accessible digital question papers in high-stakes public examinations, and if so, how quickly and in what manner such facilities must be rolled out.
How to balance:
- the rights of candidates with disabilities to equal opportunity and accessibility, and
- the administrative and logistical constraints of UPSC in conducting large-scale exams across numerous centres.

C. The Court’s Legal Reasoning

1. From formal to substantive equality

The judgment opens with a powerful conceptual framing: equality is not mere formal sameness, but the “removal of barriers” that prevent individuals from standing on equal footing. This sets the tone:

The Court recognises that visually impaired candidates may “technically” be allowed to sit for exams, but structural barriers (inflexible scribe rules, lack of assistive technology) negate effective access.
The Constitution is read as demanding substantive inclusion, i.e., transforming written rights into “lived realities”.

2. Accessibility in examinations as a constitutional obligation

The Court repeatedly characterises the case as about enforcing rights, not granting concessions. Para 1 and para 13 underscore that:

Participation of persons with disabilities in the nation’s “collective journey” must be with dignity.
Measures like scribes and Screen Readers are integral to equal opportunity, not optional generosity.

By explicitly invoking Articles 14, 19 and 21 in para 13, the Court situates disability rights squarely within the core of India’s constitutional identity, not at its margins.

3. Recognition of UPSC’s progressive shift, but insistence on operational detail

The Court adopts a nuanced stance toward UPSC:

It acknowledges UPSC’s in-principle resolution to introduce Screen Reader Software as a “significant policy advancement”.
At the same time, it stresses that a policy without an implementation mechanism risks remaining a “laudable objective” on paper.
The Court notes UPSC’s dependencies (state infrastructure, external centres) but does not allow this to become a reason for indefinite delay; instead, it orders a structured, time-bound planning process.

4. Structural, not purely individualized, relief

Rather than decide only on the rights of the presently affected candidates (e.g., for the 2025 cycle), the Court issues forward-looking directions that:

Reform all future notification processes regarding scribes.
Require systemic adoption of Screen Reader technologies, with uniform guidelines, protocols and coordination with specialised disability institutions.
Keep the matter under continuing supervision by listing it for a compliance affidavit.

This is an example of structural adjudication, where courts address systemic failures through process-based remedies rather than one-off orders.

5. Balancing exam integrity with accessibility

UPSC repeatedly expressed concern about maintaining the “sanctity, confidentiality, and security” of the examination. The Court neither dismisses these concerns nor allows them to trump fundamental rights:

Direction E explicitly requires that implementation “ensure full accessibility … while maintaining the sanctity, confidentiality, and fairness of the examination process.”
The insistence on comprehensive testing, standardisation, and validation of software is a way of aligning technological rollout with exam integrity.

This balanced approach strengthens the judgment’s institutional legitimacy: it does not micro-manage technical details, but insists that exam integrity and accessibility be pursued together.

6. Flexibility in scribe policies as a component of reasonable accommodation

On scribes, the Court moves beyond the earlier, more rigid framework:

Earlier UPSC practice of requiring scribe details at the time of application failed to account for:
- personal unavailability of scribes at a later date,
- medical emergencies, or
- candidate’s later choice to opt for a different scribe (including Commission’s scribe).
The Court’s earlier interim order of 9 May 2025 already insisted that all such change requests be entertained up to 18 May and decided within three working days.
The final judgment institutionalises this flexibility by mandating, for all future exams, that candidates can seek a change of scribe up to at least seven days before the exam, with timely, reasoned decisions.

This recognises that disability-related support needs are dynamic and may change closer to the exam date. Timely, reasoned orders ensure transparency and guard against arbitrary rejection.

7. Judicial deference and enforceable accountability

The Court walks a careful line between:

Respecting UPSC’s expertise and logistical constraints, and
Imposing enforceable obligations to protect fundamental rights.

It does not:

Dictate the exact model of hardware, software, or configuration.
Force immediate deployment in the current cycle despite infrastructural unreadiness.

It does, however:

Require a time-bound plan and a compliance affidavit.
Mandate institutional coordination with DEPwD and NIEPVD, using specialised expertise rather than purely bureaucratic judgment.
Embed these obligations in the language of constitutional rights, not mere administrative discretion.

D. Precedents and Jurisprudential Context

The excerpt of the judgment provided does not expressly cite prior case law. Nonetheless, its reasoning sits firmly within, and extends, an evolving line of disability rights jurisprudence under the Constitution and the RPwD Act. It is helpful to read this decision in the light of earlier Supreme Court pronouncements, even if they are not explicitly quoted here.

1. Vikash Kumar v. UPSC (2021)

In Vikash Kumar v. Union Public Service Commission, (2021) 5 SCC 370, the Supreme Court held that a candidate with a specified disability (writer’s cramp) was entitled to a scribe in the Civil Services Examination, emphasising:

The centrality of reasonable accommodation under the RPwD Act.
That denying accommodations in high-stakes exams effectively excludes persons with disabilities from public employment opportunities.

The present case can be seen as a natural progression:

Vikash Kumar dealt with scribe entitlement and the recognition of reasonable accommodation.
Mission Accessibility addresses the next frontier: large-scale, systemic deployment of digital assistive technologies, particularly Screen Reader Software and accessible digital formats, and flexibility in scribe administration.

2. National Federation of the Blind v. UPSC (2014)

In National Federation of the Blind v. Union Public Service Commission (2014), the Supreme Court examined the rights of visually impaired persons in the context of competitive examinations and public employment. That case:

Asserted the right of visually impaired candidates to fair and equal access to public employment processes.
Set the stage for broader reforms in examination practices and recognition of access needs (such as scribes, extra time, and accessible materials).

The 2025 decision advances this line by:

Moving from basic physical accommodations (e.g., scribes alone) to digital accessibility through Screen Readers and accessible digital question papers.
Insisting on institutional coordination and standardised guidelines, not merely case-specific relief.

3. Dignity jurisprudence: Jeeja Ghosh v. Union of India (2016)

In Jeeja Ghosh v. Union of India, (2016) 7 SCC 761, concerning the ill-treatment of a passenger with cerebral palsy, the Supreme Court strongly affirmed the dignity of persons with disabilities and condemned paternalistic, exclusionary behaviour.

The language in para 13 of the present judgment – that disability rights are “not acts of benevolence” but expressions of the constitutional promise of equality, dignity and non-discrimination – is squarely in this tradition.

Thus, although the text provided does not cite cases, Mission Accessibility clearly:

Builds upon the principles of reasonable accommodation, dignity, and substantive equality articulated in earlier disability-rights decisions.
Extends them into the realm of digital accessibility and standardised exam practices for UPSC and, by implication, other examination bodies.

E. Nature of the Directions and Remedial Technique

1. Mandamus with continuing oversight

Although the Court states that the writ petition “stands disposed of”, it simultaneously:

Directs UPSC to file a compliance affidavit within two months, and
Lists the matter again on 16 February 2026 to receive that affidavit.

This is effectively a form of continuing mandamus:

The core issues are decided in principle, but judicial oversight continues to ensure that the rights recognised are actually implemented.
This encourages administrative compliance without putting the entire burden on disabled individuals to bring fresh litigation for every lapse.

2. Process-based rather than hyper-detailed orders

The Court does not specify:

the precise exam centres to have Screen Readers,
the brand or type of Screen Reader or hardware, or
the exact digital format of question papers.

Instead, it requires:

A plan of action with timelines and feasibility assessments.
Standardisation of software and infrastructure through testing and validation.
Inter-agency coordination with DEPwD and NIEPVD for expert-driven guidelines.

This respects institutional competence while ensuring accountability.

3. Measured acceptance of logistical constraints

UPSC argued that introducing Screen Readers for all eligible candidates in the immediate preliminary examination was not feasible. The Court:

Does not compel immediate, universal deployment for the then-imminent examination.
Instead, ties deployment to the next examination cycle, subject to feasibility and readiness, but requires a concrete plan and standardisation.

This approach both acknowledges operational reality and prevents open-ended postponement. It converts a vague “at the earliest possible juncture” into a structured, reviewable obligation.

F. Impact and Likely Future Significance

1. Immediate impact on UPSC examinations

Flexible scribe changes – The requirement that every UPSC notification allow candidates to change scribes up to at least seven days before the exam is a game-changer. It institutionalises flexibility as a right, not a discretionary accommodation.
Screen Reader and digital accessibility roadmap – UPSC is now under an enforceable mandate to design and roll out Screen Reader-based facilities and accessible digital question papers, backed by expert consultation.
Reasoned decision-making – The demand for reasoned orders on scribe-change applications introduces administrative transparency and reduces arbitrariness.

2. Persuasive precedent for other examining bodies

Although the directions are formally directed at UPSC and the Union of India, the principles invoked – equality, non-discrimination, dignity under Articles 14, 19 and 21 and compliance with the RPwD Act – are general.

This judgment will likely be cited to:

Challenge inaccessible practices in other competitive examinations (Staff Selection Commission, State Public Service Commissions, entrance tests for professional courses, etc.).
Argue that digital accessibility (Screen Readers, accessible formats) is not an optional extra but a necessary component of constitutionally compliant examination systems.
Push for standardised guidelines on assistive technologies across educational and recruitment bodies.

3. Consolidating a rights-based, not charity-based, disability regime

The explicit rejection of benevolence-based framing (para 13) strengthens the doctrinal shift toward a rights-based disability law in India:

It will make it harder for public authorities to treat accommodations as favours that can be granted or withdrawn at will.
It reinforces the idea that non-provision of necessary accommodations is itself a form of discrimination.

4. Normalising the use of assistive technology in high-stakes contexts

By explicitly endorsing Screen Reader Software and accessible digital question papers in the UPSC context, the Court helps:

Normalize the idea that technology is a right-enabler for persons with disabilities, not a suspicious addition that inherently threatens exam integrity.
Catalyse investment by public authorities in accessible digital infrastructure, with ripple effects on education, employment and governance.

V. Complex Concepts Simplified

1. Persons with Benchmark Disability (PwBD)

Under the RPwD Act, a “person with benchmark disability” is someone with at least a specified degree (often 40% or more) of a particular type of disability, as certified under the Act. Many statutory benefits, reservations and specific exam accommodations apply to PwBD.

2. Scribe

A scribe is a person who writes or types exam answers on behalf of a candidate who cannot write or type independently due to a disability (such as blindness, low vision, or certain physical or learning disabilities). The candidate dictates the answers; the scribe records them.

Inaccessible or rigid scribe policies can:

Force candidates to rely on unsuitable scribes.
Penalise them for last-minute emergencies (illness, unavailability, etc.).
Discourage them from appearing in exams altogether.

3. Screen Reader Software

A Screen Reader is assistive software that converts text displayed on a computer screen into synthesised speech or Braille output, enabling blind or low-vision users to access digital content.

In an examination context, Screen Readers:

Allow visually impaired candidates to “listen” to question papers and on-screen content.
Potentially allow them to type their answers, depending on exam design.
Provide greater independence, privacy and control than relying solely on a human scribe.

4. Accessible Digital Formats

Accessible digital formats are electronic versions of question papers and exam materials that are compatible with assistive technologies like Screen Readers. This typically means:

Properly structured files (e.g., tagged PDFs, accessible Word formats) without image-only text.
Usable with keyboard navigation and Screen Readers.

Without such formatting, even “digital” documents can be effectively inaccessible.

5. Reasonable Accommodation

Reasonable accommodation refers to necessary and appropriate modifications and adjustments that ensure persons with disabilities can enjoy or exercise their rights on an equal basis with others, without imposing a disproportionate or undue burden on the provider.

In this case, reasonable accommodation includes:

Allowing flexible changes of scribes.
Providing Screen Reader Software and accessible question papers.
Designing exam-related procedures sensitive to disability-related contingencies.

6. Structural (or Continuing) Mandamus

A writ of mandamus is a judicial order directing a public authority to perform a legal duty. In structural or continuing mandamus:

The Court does not simply issue a one-time order and close the file.
It requires ongoing compliance reports, reviews progress, and may issue further directions.

Listing this case for a future compliance hearing, even after formal disposal, is an example of such continuing oversight.

VI. Conclusion: Key Takeaways and Broader Significance

Mission Accessibility v. Union of India is a landmark in the slow but steady transformation of India’s examination and recruitment systems toward genuine inclusion of persons with disabilities.

Its key contributions can be distilled as follows:

From policy intent to enforceable obligation
The Court recognises UPSC’s progressive in-principle decision on Screen Readers but insists that constitutional promises must be operationalised through:
- time-bound planning,
- standardised guidelines, and
- inter-agency coordination.
Embedding digital accessibility into equality jurisprudence
By mandating Screen Reader facilities and accessible digital formats, the judgment explicitly incorporates digital accessibility into the right to equality, non-discrimination and dignity under Articles 14, 19 and 21 read with the RPwD Act.
Reframing disability accommodations as rights, not charity
The Court’s categorical statement that disability-related measures are “not acts of benevolence” but expressions of constitutional equality and dignity strengthens a rights-based approach and will resonate in future litigation.
Setting systemic standards for examinations
The directions on:
- flexible scribe-change policies,
- reasoned administrative decisions, and
- uniform protocols for assistive technologies
will likely influence examination practices across India, well beyond UPSC.
Adopting a balanced, process-oriented judicial role
The Court avoids micromanaging technical choices, but strongly asserts its role in ensuring that fundamental rights shape institutional design. Its process-based remedy, combined with ongoing oversight, is a model for handling complex, technology-infused rights questions.

Ultimately, this judgment affirms that a “just and inclusive society” must dismantle not only overt discrimination but also structural and technological barriers that prevent persons with disabilities from competing on equal terms. By mandating digital accessibility and flexible scribe policies in one of India’s most prestigious examinations, the Supreme Court moves the system a step closer to making the constitutional vision of equal opportunity a “living, enforceable, and enduring reality” for persons with disabilities.