[AI] final comments on draft procedure for disability certificate

Rajesh Asudani rajeshasudani at rbi.org.in
Thu Aug 30 07:49:52 EDT 2007


As tomorrow is the deadline for sending the comments on the above mentioned subject, at least by e mail, I am posting below final draft of comments after receiving some feedback to my yesterday's mail. However, the feedback may be considered, only sparse by all counts, and yes, once again, none of NGOs, "stake holders" probably consulted, even responded to my mail.

The following comments may please be forwarded after filling necessary details, individually as well as collectively by NGOs etc. by e mail as well as regular mail, as they would enable us to voice our demand in unison for single bilingual disability certificate valid for all purposes to be issued by broad based medical board, minimizing misuse, instead of proposed three tiered structure issuing the same for various purposes which would leave us repenting for time to come.





Ashish Kumar, Secretary of the Committee and Deputy Director General, 

Room No. 610, 'A' Wing, Shastri Bhawan, New Delhi - 110001 (Phone & 

Fax No. 23383853, E-mail: 

kmashish at nic.in).


Comments on the draft procedure of issuing disability certificate




I/we [write your introduction]   wish to submit following comments on the draft procedure for issuing disability certificates as published by your ministry for your kind perusal and considered implementation:


  1.. Purpose:
The said draft procedure is purportedly being designed to simplify and streamline the issuance of disability certificate. It indicates that existence of problems and anomalies in the procedure is acknowledged. Such difficulties and irregularities, pertain, in my/our view, to:

 i. enormous difficulty in obtaining a valid disability certificate by the deserving; 

ii. Misuse of the procedure by undeserving by obtaining false certificates or by obtaining certificates of lesser/grater disability than actual; 

iii. Obtention of certificate by inhabitants of villages who have to take grate pains for the purpose;

iv. multiplicity of authorities apart from medical board who are required to endorse the said certificate before it may be used for various purposes like travel concession, employment etc. 

v. lack of knowledge and utter ignorance on the part of governmental people like railway clerks etc. who actually deal with the disabled while availing various facilities Such ignorance and resulting arbitrariness is the consequence of non existence of single authority for issuing a valid disability certificate for all purposes.

The aim of revised procedure should be to obviate these and all other difficulties.


  2.. Simplification!!!
Reading of draft procedure as a whole makes it clear that a three-tier structure consisting of PHC doctor, panel of specialists/paramedics and the medical board is proposed for issuing disability certificates respectively for:

i.                     Readily discernible disabilities like total blindness, etc. valid for purposes specified in Para ii;, ii] non-discernible disabilities like low vision, mental retardation, valid for purposes specified again in Para ii; and iii] all disabilities valid for purposes specified in Para I like employment etc.

The whole set-up would inevitably result in a host of different authorities issuing disability certificates creating an all round confusion. The situation would be chaotic and far from simple. It may even result in the same person being certified disabled for some purposes say, by PHC doctor, but not for other purposes, say by the medical board. The multiplicity of authorities would become overwhelming even for educated government clerks/supervisors to comprehend, let alone the disabled persons themselves. To tell you the ground realities, many blind/disabled persons have been asked, on numerous occasions, such foolish questions as why the certificate has been signed by three doctors when it should be signed by one only!!!!!! In actuality, a disabled person would have to obtain all the two/three different disability certificates from various authorities in order to obtain any facility/concession.

The intention behind delegating powers to PHC doctors is indeed admirable, as it is supposed to ameliorate difficulties faced by rural inhabitants in obtaining certificate for various schemes etc. However, in actuality, the move would give rise to widespread corruption defeating the very purpose of the move and various government schemes as well. From another point of view, the utility of empowering PHC doctors is seriously jeopardized by the fact that more than half of country's primary health centers do not have functioning doctor at any given time. Naturally, it is not a villager's cup of tea, given non-availability/absence of doctor, or absence of basic infrastructure like stationary, to take advantage of the proposed move.

Bifurcation/trifurcation of the purposes for which disability certificate issued by various authorities would be valid, is also disconcerting and a potential contributor to conflicting interpretations and consequent discord and denial of services to the disabled. Confusion it would create, may only be imagined. The proposed aim of facilitating rural folk in obtaining the certificate may be served by employing mobile teams and also by the moves proposed in following paras of this comment.


  3.. All-purpose disability certificate:

It goes without saying, after perusal of the above paras that the disability certificate, issued in any manner, should be a certificate valid for all practical and theoretical purposes, where the factum of an individual being a person with a disability is material. Bifurcation of the purposes would serve no purpose in the long run and is self-defeating. It adds to the harassment of the persons seeking certificates for varying purposes.


  4.. Full faith and credit clause:

In addition to above, the requirement of separate endorsement by various authorities for availing concessions like travel concession by road [Depot manager endorsing] rail [railway doing so] etc. should be done away with. The fact that disability certificate has been issued by a competent authority, is enough to establish the disability and should be accepted duly. The jurisdictional conflict/variety like road and rail travel falling under state and centre respectively has to be taken care of. For this, full faith and credit clause contained in article 261 of our constitution which accords full faith and credit to all public acts, records and judicial proceedings of any state throughout India may be invoked.


  5.. Broadening medical board: The question of reaching far-flung and rural areas and making all facilities available to inhabitants of such areas, which has seemingly prompted the move to empower PHC doctors to issue certificates for discernible disabilities for some purposes, also needs to be given due importance. For accomplishing this, the constitution of the medical board which should be the authority for issuing the single certificate valid for all the purposes should be broadened so as to include relevant specialists at Taluka/tahaseel/village level. It may be accomplished by hiring the services of private practitioners/specialists/paramedical staff, as contemplated in the draft. However, The three-tiered structure should be replaced by such a broad based medical board which could assess the applicants at the taluka level at least, and forward the certificate for signature to civil surgeon/head of medical board.
The practice of dispatching mobile teams to remote areas may be continued with grater vigor.

In addition to above, in the present era of deployment of technology for various purposes, after examination of the concerned person by a specialist/paramedic staff, the subsequent process of routing the certificate may also be e-enabled. Even telemedicine/conferencing may be employed for assessing the individual.


6. Simple drafting:


The certificate so issued should be drafted in as simple a language as possible to avoid any misconstruction on the part of all involved. The draft may read like:


"I, the Head of medical board for district ---, hereby being satisfied upon examination of Shree smt kum --- by specialist, certify that he/she is having [name of disability] to the extent ---. This certificate is the proof of his/her disability wherever such proof is called to be furnished." The certificate may contain necessary particulars of the holder including photograph to easily identify her/him.


7. Permanent/temporary certificate:


According to current guidelines, permanent certificate is to be issued in cases where disability is irreversible and temporary in all other cases. However, medical boards have at least in some places, virtually stopped issuing permanent certificates. This practice should be strictly forbidden, and appropriate certificates be issued.


8.  Language:

The certificate should be bilingual, i.e. in English as well as in Hindi, which would serve the purpose throughout India.


9. If at all, the above suggestions do not find favor with decision makers and it is decided to retain bifurcation/trifurcation of purposes and authorities, The lists of purposes should be as exhaustive as possible, and any RMP practitioner be strictly forbidden from meddling himself/herself in the process of issuance.

Any purpose not mentioned in the lists may fall into Para I, i.e. certificate to be issued by medical board.


10. In summery, a single bilingual disability certificate valid for all purposes be issued by a broad based medical board so as to avoid any inconvenience to the deserving and undue advantage to the undeserving. 


More information about the AccessIndia mailing list