[AI] proposed comments

Subramani L lsubramani at deccanherald.co.in
Fri Aug 31 03:03:56 EDT 2007

I agree with Rajesh for the simple reason that PWD identity card is not
as common as a ration card, where people are able to understand the
difference and the purpose of such cards. Unfortunately, when we can't
fully convince certain people of the value and purpose of this card, it
won't help much when you have two or three categories of it. 


-----Original Message-----
From: accessindia-bounces at accessindia.org.in
[mailto:accessindia-bounces at accessindia.org.in] On Behalf Of Rajesh
Sent: Friday, August 31, 2007 10:03 AM
To: accessindia at accessindia.org.in
Subject: Re: [AI] proposed comments

I am afraid, I can not go with the very idea of bifurcating/trifurcating

either issuance of certificate or purposes for which it is meant!

It would create innumerable problems and needless confusion in a field 
already beset with multiplicity of approaches and problems.

Suitable broadening of medical board/pannel for issuing a unified card
the proper remedy in my view.

I have sent my comments to MSJ and CCPD, without acknowledgement, as

----- Original Message ----- 
From: "Harish Kotian" <harish at accessindia.org.in>
To: <accessindia at accessindia.org.in>
Sent: Thursday, August 30, 2007 9:02 PM
Subject: Re: [AI] proposed comments

> Hi
> Strangely, my mail did not hit the list and hence I am resending it
> Please read on for it.
> Harish.
> Hello Rajesh
> Infact am appreciative of the move of the CCPD in making 2 type of
> disability certificate. One should look at it like the ration card, I 
> think
> it is the green card and the white card. Where the privelledges
> The type 1 card is very substantive touching things like legal claims,
> employment, university admissions etc. Here the users can certainly
> extra effort to obtain this type of card.
> The type 2 card gives monetary benefitsand hence the procedure for 
> obtaining
> is kept simple. Besides, suitable kits would be made to operationalise
> The loss occuring out of misuse is borne by the service providers
where as
> in type 1 card it is effecting the blind persons as a whole.
> It should be made very clear in the type 1 card that the holder need
> obtain type 2 card and all priveleges of type 2 would be available to 
> them.
> The CCPD should maintain a National register database of all
> issued and each certificate should have a unique ID number which
should be 
> a
> running number.
> The extent of disability should be strictly as defined in PWD and no
> defination like percentage of disability  be adopted.
> Any person who issues a false certificate should be severely punished
> debarred from issuing certificates.
> Any person claiming benifits using false certificates should be taken
> a
> criminal act and punished  accordingly.
> The type 1 certificate should also be optionally available as a smart
> with additional fee  with details captured in it.
> Harish.
> ----- Original Message ----- 
> From: "Rajesh Asudani" <
> rajeshasudani at rbi        .org.in>
> To: <
> accessindia at accessindia.org.in>
> Sent: Wednesday, August 29, 2007 5:27 PM
> Subject: [AI] proposed comments
>> Here are my tentative comments on the draft procedure of issuing
>> disability certificate.
>> They contain my basic contentions for simplification of the same.
>> Would be grateful for suggestions/improvements, as well as  after
>> adoption of the same by group tomorrow or so, for forwarding the same
>> individually by as many individuals as possible as well as
>> by
>> NGOs etc.
>> Rajesh
>> 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
>> Sir
>> I, a totally blind person, serving as class I officer in the Reserve
>> of India, associated with a number of NGOs working in the field of
>> disability, wish to submit following comments on the draft procedure
>> issuing disability certificates as published by your ministry for
>> kind perusal and considered implementation:
>>  1.. Purpose:
>> The said draft procedure is purportedly being designed to simplify
>> 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 view, to:
>> i. enormous difficulty in obtaining a valid disability certificate by
>> 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
>> grate pains for the purpose;
>> iv. multiplicity of authorities apart from medical board who are
>> 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
>> availing various facilities Such ignorance and resulting
arbitrariness is
>> the consequence of non existence of single authority for issuing a
>> 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
>> structure consisting of PHC doctor, panel of specialists/paramedics
>> 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;,
>> disabilities like low vision, mental retardation, valid for purposes
>> specified again in Para ii; and 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
>> by PHC doctor, but not for other purposes, say by the medical board.
>> multiplicity of authorities would become overwhelming even for
>> government clerks/supervisors to comprehend, let alone the disabled
>> persons themselves. To tell you the ground realities, I have been
>> on numerous occasions, 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
>> facility/concession.
>> The intention behind delegating powers to PHC doctors is indeed 
>> admirable,
>> as it is supposed to ameliorate difficulties faced by rural
>> in
>> obtaining certificate for various schemes etc. However, in actuality,
>> move would give rise to widespread corruption defeating the very
>> of the move and various government schemes. From another point of
>> 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
>> cup of tea, given non-availability/absence of doctor, or absence of
>> infrastructure like stationary, to take advantage of the proposed
>> Bifurcation/trifurcation of the purposes for which disability
>> 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
>> individual being a person with a disability is material. Bifurcation
>> 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
>> purposes.
>>  4.. Full faith and credit clause:
>> In addition to above, the requirement of separate endorsement by
>> authorities for availing concessions like travel concession by road 
>> [Depot
>> manager endorsing] rail [railway doing so] etc. should be done away
>> The fact that disability certificate has been issued by a competent
>> authority, is enough to establish the disability and should be
>> duly. The jurisdictional conflict/variety like road and rail travel
>> falling under state and centre respectively has to be taken care of.
>> 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
>> areas, which has seemingly prompted the move to empower PHC doctors
>> issue certificates for discernible disabilities for some purposes,
>> needs to be given due importance. For accomplishing this, the 
>> constitution
>> of the medical board which should be the authority for issuing the
>> certificate valid for all the purposes should be broadened so as to
>> include relevant specialists at Taluka/tahaseel/village level. It may
>> accomplished by hiring the services of private
>> practitioners/specialists/paramedical staff, as contemplated in the 
>> draft.
>> The three-tiered structure should be replaced by such a broad based
>> medical board which could assess the applicants at the taluka level
>> 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
>> with grater vigor.
>> In addition to above, in the present era of deployment of technology
>> 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
>> employed for assessing the individual.
>> 6. Simple drafting:
>> The certificate so issued should be drafted in as simple a language
>> possible to avoid any misconstruction on the part of all involved.
>> draft may read like:
>> "I, the Head of medical board for district ---, hereby being
>> upon examination of Shree smt kum --- by specialist, certify that
>> is having [name of disability] to the extent ---. This certificate is
>> proof of his/her disability wherever such proof is called to be
>> furnished." The certificate may contain necessary particulars of the
>> holder to easily identify her/him.
>>  6.. Permanent/temporary certificate:
>> According to current guidelines, permanent certificate is to be
issued in
>> cases where disability is irreversible and temporary in all other
>> However, medical boards have at least in some places, virtually
>> 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
>> 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
>> and any RMP practitioner be strictly forbidden from meddling
>> himself/herself in the process of issuance.
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