Supreme Court of India
PRAGYA PRASUN & ORS.versusUNION OF INDIA & ORS.
- Citation
- 2025 INSC 599
- Decided
- 30 April 2025
- Disposal
- Disposed off
- Bench
- B PARDIWALA
Holding
The Court held that digital KYC processes must be made accessible to persons with disabilities and directed the regulatory authorities to issue inclusive guidelines and reasonable accommodation measures.
Summary
The petitioners, including acid‑attack survivors with facial disfigurements and a blind individual, challenged the mandatory digital KYC/e‑KYC/video‑KYC procedures for being inaccessible and discriminatory. They argued that requirements such as capturing a live photograph and performing a liveness check (e.g., eye‑blinking) violated their rights under Article 21 read with Articles 14, 15 and 38, and breached the Rights of Persons with Disabilities Act, 2016. The Court examined the constitutional, statutory, and international obligations to ensure accessibility and reasonable accommodation for persons with disabilities. It held that the existing digital KYC framework creates unjust barriers and must be re‑engineered to comply with accessibility standards such as WCAG and the RPwD Act. Accordingly, the Court issued comprehensive directions to the RBI, SEBI, TRAI, PFRDA, IRDAI, and the Department of Telecommunications to formulate inclusive guidelines, conduct periodic accessibility audits, accept alternative verification methods, and establish grievance redressal mechanisms. The writ petitions were disposed of with these directions.
Issues considered
- Whether the present digital KYC/e‑KYC/video‑KYC framework is inaccessible to persons with disabilities?
- Whether the regulatory authorities (RBI, SEBI, TRAI, PFRDA, IRDAI, DoT) have failed to ensure reasonable accommodations and accessibility in digital KYC processes?
- Whether the mandatory requirement of capturing a “live photograph” and conducting a “liveness check” is discriminatory and violative of Article 21 read with Articles 14, 15 and 38 of the Constitution?
- Whether the absence of clear standards, checks and accessibility criteria in digital KYC guidelines violates the Rights of Persons with Disabilities Act, 2016 and RPwD Rules, 2017?
- Whether directions can be issued to the Respondents to formulate appropriate rules and guidelines for conducting Digital KYC/e‑KYC/Video KYC through alternative methods, to ensure inclusivity for persons with disabilities?
Legislation cited
- Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016
- Indian Telegraph Act, 1885
- Information Technology Act, 2000
- Pension Fund Regulatory and Development Authority Act, 2013
- Prevention of Money Laundering Act, 2002
- Reserve Bank of India Act, 1934
- Rights of Persons with Disabilities Act, 2016s. 12, s. 13, s. 16, s. 2(c), s. 3, s. 40, s. 42, s. 46
- Telecom Regulatory Authority of India Act, 1997
Headnote
Issue for Consideration 1. Whether the present digital KYC / e-KYC / video-KYC framework is inaccessible to persons with disabilities? 2. Whether the regulatory authorities (RBI, SEBI, TRAI, PFRDA, IRDAI, DoT) have failed to ensure reasonable accommodations KYC processes? 3. Whether the mandatory requirement of capturing a “live photograph” and conducting a “liveness check” (through blinking, reading text on screen, etc.) is discriminatory and violative of Article 21 read in conjunction with Articles 14, 15 and 38 of the
Subjects
Digital KYCDisability RightsAccessibilityReasonable AccommodationArticle 21RPwD ActEqualityNon-DiscriminationWeb Content Accessibility GuidelinesUNCRPD
Judgment
[2025] 4 S.C.R. 2851 : 2025 INSC 599
Pragya Prasun & Ors.
v.
Union of India & Ors.
(Writ Petition (Civil) No. 289 of 2024
With
Writ Petition (Civil) No. 49 of 2025)
30 April 2025
[J.B Pardiwala and R. Mahadevan,* JJ.]
Issue for Consideration
1. Whether the present digital KYC / e-KYC / video-KYC
framework is inaccessible to persons with disabilities?
2. Whether the regulatory authorities (RBI, SEBI, TRAI,
PFRDA, IRDAI, DoT) have failed to ensure reasonable
accommodations and accessibility in digital KYC processes?
3. Whether the mandatory requirement of capturing a “live
photograph” and conducting a “liveness check” (through
blinking, reading text on screen, etc.) is discriminatory and
violative of Article 21 read in conjunction with Articles 14, 15
and 38 of the Constitution?
4. Whether the absence of clear standards checks and
accessibility criteria in digital KYC guidelines violates the
Rights of Persons with Disabilities Act, 2016 and RPwD
Rules, 2017?
5. Whether directions can be issued to the Respondents to
formulate appropriate rules and guidelines for conducting
Digital KYC/ e-KYC / Video KYC process through alternative
methods, to ensure that the process is more inclusive and
accessible to all persons with disabilities?
Headnotes†
Disability Rights – Accessibility of Digital Services – Digital
KYC – Facial Recognition – “Live Photograph” and “Liveness
Check” Requirements – Reasonable Accommodation – Equality
and Non-Discrimination – Regulatory Obligations of RBI,
SEBI, IRDAI, PFRDA, TRAI, DoT – Inter-operable Accessibility
* Author
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Standards – Know Your Customer (KYC) Norms – Framework
of – Explained:
Held: In an effort to combat illegal activities and money laundering,
the Central Government through the PMLA and the Rules, 2005,
mandated that all financial and banking institutions conduct client
identity verification, maintain comprehensive records, and report
relevant information to the Financial Intelligence Unit – India
– Pursuant to the same, the Reserve Bank of India issued the
Master Direction on Know your Customer (KYC), 2016 – The
Master Direction on KYC prescribes the framework for Customer
Due Diligence (CDD) procedures and outlines the digital KYC
process under Chapter VI and Annex I, respectively. Additionally,
Clause 18 of the MD on KYC introduced the Video based-Customer
Identification Process (V-CIP) enabling remote customer verification
through secure, real-time video interaction – As a result, multiple
sectors – Including banking, telecommunications, insurance,
and mutual funds – Have adopted digital KYC as a mandatory
component of their CDD or Customer Identification Program (CIP)
obligations, thereby facilitating identity verification of prospective
customers in compliance with regulatory requirements – According
to the petitioners, many Regulated Entities refuse to conduct offline
verification even when customers submit valid proof of possession
of Aadhaar – Additionally, the requirement of capturing a live
photograph under Option 2 creates a barrier for individuals with
facial/eye disfigurements and visual impairments, rendering them
unable to complete the digital KYC process. [Paras 12 and 13]
Legal framework – Constitutional and statutory provisions
placing obligation on Government to enable persons with
disabilities to exercise rights equally – Constitution of India –
UNCRPD, Arts.9 and 12 – Information Technology Act, 2000 –
Rights of Persons with Disabilities Act, 2016, Ss.2(c), 3, 12,
13, 16, 40, 42 and 46 – Purpose of – Explained:
Held: The Rights of Persons with Disabilities Act, 2016 marks a
paradigm shift from the earlier medical and technical model of
disability under the 1995 Act, which carried a significant burden
of stigma – The new model recognizes disability as a condition
arising not only from impairments but also from physical, mental,
intellectual, social, psycho-social, and other barriers that hinder
full and effective participation in society – These barriers lie at the
heart of the exclusion experienced by persons with disabilities,
preventing them from realizing their full potential and participating
[2025] 4 S.C.R. 2853
Pragya Prasun & Ors. v. Union of India & Ors.
as full and equal members and citizens – A vision enshrined by
the framers of our Constitution. [Para 14.4.2]
Access to information and communication technology –
Section 42 of the Rights of Persons with Disabilities Act,
2016 – Scope of – Explained:
Held: Section 13(1) mandates the ‘appropriate government’ to
ensure that the persons with disabilities have right, equally with
others, to own or inherit property, movable or immovable, control
their financial affairs and have access to bank loans, mortgages,
and other forms of financial credit – Section 42 of the Rights
of Persons with Disabilities Act, 2016, deals with ‘Access to
information and communication technology’ – This section requires
the appropriate Government to take measures to ensure that: (i)
all contents available in audio, print and electronic media are in
accessible format; (ii) persons with disabilities have access to
electronic media by providing audio description, sign language
interpretation and close captioning; (iii) electronic goods and
equipment which are meant for everyday use are available in
universal design – Section 46 provides ‘time limit for accessibility
by service provides’ – According to this provision, the service
providers whether Government or private shall provide services
in accordance with the rules on accessibility formulated by the
Central Government under section 40 within a period of two years
from the date of notification of such rules: Provided that the Central
Government in consultation with the Chief Commissioner may
grant extension of time for providing certain category of services
in accordance with the said rules. [Paras 14.4.6, 14.4.9, 14.4.10]
Non-Accessibility – KYC Verification – Persons with disability –
Rights of Persons with Disabilities Act, 2016 – Purpose
defeated:
Held: Though digital KYC has benefitted the general public by
making verification processes faster and more efficient, persons
with blindness and low vision continue to face significant barriers in
accessing and completing these procedures – Many digital platforms
are not compatible or accessible to persons with various disabilities,
and collectively amount to a denial of equal access and violate the
accessibility mandates under the Rights of Persons with Disabilities
Act, 2016 and results in economic and social marginalization – To
combat this discrimination, governments and private entities must
ensure that digital services comply with Web Content Accessibility
2854 [2025] 4 S.C.R.
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Guidelines (WCAG) and other accessibility standards – Further,
legal frameworks should impose stringent requirements for digital
inclusion, ensuring that no individual is denied access to essential
services on the basis of disability – Thus, it is clear that as per
international standards and the Rights of Persons with Disabilities
Act, 2016, digital services are expected to be inclusive and
accessible to all users, regardless of ability. [Para 15]
International Law – Disabled Rights – Explained:
Held: India signed the United Nations Convention on the Rights
of Persons with Disabilities, 2006, on 30th March, 2007 and
ratified it on 1st October, 2007, and the Convention was enforced
in India from 3rd May 2008 onwards – It places the following three
important obligations on each State Party: (i) To respect the rights
and freedoms of persons with disabilities; (ii) To protect individuals
with disabilities from rights violations by others; (iii) To fulfil these
rights by taking appropriate legislative, administrative, and policy
measures – India adopted the Incheon Strategy in 2012 – It
offers the first set of regionally agreed inclusive development
goals aimed at making the rights of persons with disabilities a
reality in the Asia – Pacific region – Notably, ICT (Information and
Communication Technology) accessibility is specifically referenced
in Goal 3 of the strategy – This goal emphasizes the need to
enhance access to the physical environment, public transportation,
knowledge, information, and communication systems for persons
with disabilities. [Paras 14.2.1 and 14.3]
Interpretation – Right to Life – Article 21 – Bridging the Digital
Divide – Technological Realities – Considered:
Held: In the contemporary era, where access to essential services,
governance, education, healthcare, and economic opportunities
is increasingly mediated through digital platforms, the right to life
under Article 21 of the Constitution must be reinterpreted in light
of these technological realities – The digital divide-characterized
by unequal access to digital infrastructure, skills, and content –
Continues to perpetuate systemic exclusion, not only of persons
with disabilities, but also of large sections of rural populations,
senior citizens, economically weaker communities, and linguistic
minorities – The principle of substantive equality demands that digital
transformation be both inclusive and equitable – State’s obligations
under Article 21– Read in conjunction with Articles 14,15 and 38 of
the Constitution – Must encompass the responsibility to ensure that
[2025] 4 S.C.R. 2855
Pragya Prasun & Ors. v. Union of India & Ors.
digital infrastructure, government portals, online learning platforms,
and financial technologies are universally accessible, inclusive
and responsive to the needs of all vulnerable and marginalized
populations – Bridging the digital divide is no longer merely a matter
of policy discretion but has become a constitutional imperative to
secure a life of dignity, autonomy and equal participation in public
life – The right to digital access emerges as an intrinsic component
of the right to life and liberty, necessitating that the State proactively
design and implement inclusive digital ecosystems that serve not
only the privileged but also the marginalized, those who have been
historically excluded. [Para 17]
Directions Issued – Mandatory Incorporation of Accessibility
Standards – Periodical Accessibility Audit – Provision of
Alternative KYC Modes – Implementation of OTP Based
e-KYC authentication – Dedicated Grievance Redressal
Mechanisims — Monitoriting and enforcement:
Directions were issued to Respondent authorities/Ministries to make
the process of digital KYC accessible to persons with disabilities,
especially facial / eye disfigurements due to acid attacks and visual
impairments [Para 18]
Case Law Cited
Vikash Kumar v. Union Public Service Commission & Others [2021]
12 SCR 311 : (2021) 5 SCC 370; Rajive Raturi v. Union of India &
Others [2017] 12 SCR 827: (2018) 2 SCC 413; D Rajive Raturi v.
Union of India & Others, 2024 INSC 858 : [2024] 11 SCR 970;
Disabled Rights Group & Anr. v. Union of India & Others [2017]
12 SCR 988 : (2018) 2 SCC 397; Avishek Goenka v. Union of
India [2012] 5 SCR 547 : [Supreme Court decision in W.P.(C)
No.285 of 2010] – referred to.
Other References
United Nations Convention on the Rights of Persons with
Disabilities, 2006 and Incheon Strategy to “Make the Right Real”
for Persons with Disabilities in Asia and the Pacific – referred to.
List of Acts
Persons with Disabilities Act, 2016; Information Technology Act, 2000;
Reserve Bank of India Act, 1934; Prevention of Money Laundering
2856 [2025] 4 S.C.R.
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Act, 2002; Aadhaar (Targeted Delivery of Financial and Other
subsidies, Benefits and Services) Act, 2016; Telecom Regulatory
Authority of India Act, 1997; Indian Telegraph Act, 1885; Pension
Fund Regulatory Authority and Development Authority Act, 2013.
List of Keywords
Digital KYC Process; Disabled Rights; Persons with Disability;
KYC Norms; Accessibility; Inclusivity; Dignity; Equal Participation;
Reasonable Accommodations; Disability Awareness.
Case Arising From
CIVIL ORIGINAL JURISDICTION: Writ Petition (Civil) No. 289 of
2024
Under Article 32 of The Constitution of India
With
Writ Petition (Civil) No. 49 of 2025
Appearances for Parties
Advs. for the Petitioners:
Siddharth Luthra, Sr. Adv., Nitin Saluja, Ms. Nimisha Menon,
Ms. Yamina Menon, Ms. Samarth Luthra, Ms. Ishita Soni,
Ms. Pranya Madan, Ms. Ila Shikhar Sheel.
Advs. for the Respondents:
Brijender Chahar, A.S.G., V Giri, Sr. Adv., Ramesh Babu M.R.,
Ms. Nisha Sharma, Ms. Manisha Singh, Ms. Jagrit Bharti, Rohan
Srivastava, Ankur Sood, Dhaman Trivedi, Sudarshan Lamba, Ms.
Swarupama Chaturvedi, Aaditya Dixit, Raman Yadav, Ms. Shashwat
Parihar, Arjun Krishnan.
Judgment / Order of the Supreme Court
Judgment
R. Mahadevan, J.
1. Since the issues involved in both the writ petitions are common,
interlinked, and similar, they were heard together and are disposed
of by this common judgment.
[2025] 4 S.C.R. 2857
Pragya Prasun & Ors. v. Union of India & Ors.
2. Technology has played a transformative role in reshaping India’s
economy and governance. Initiatives such as Digital India aim to
promote efficiency, transparency, and accessibility through digital
means. Central to this transformation has been the creation of a
robust digital infrastructure, including the Aadhaar program, online
KYC mechanisms, and various electronic service delivery platforms.
However, amidst this wave of digital progress, there remains a
crucial and often overlooked aspect that demands urgent attention –
ensuring that digital infrastructure and services are accessible to all,
including persons with disabilities and other marginalised groups. True
inclusion requires that technological advancements accommodate
the diverse needs of all citizens, thereby fostering an environment
where no individual is left behind. With this preface, we now proceed
to examine the key issues involved in the cases before us.
3. While the petitioners in W.P(C) No.289 of 2024 are acid attack
victims, who suffer from facial disfigurement and severe eye burns,
the petitioner in W.P(C) No.49 of 2025 is suffering from 100%
blindness. These writ petitions have been filed seeking directions
to the various respondents to formulate appropriate rules and
guidelines for conducting Digital KYC/ e-KYC / Video KYC process
through alternative methods, with a view to ensuring that the process
is more inclusive and accessible to all persons with disabilities-
particularly acid attack survivors suffering from permanent facial/eye
disfigurement and similarly placed individuals, including persons with
blindness and low vision - in accordance with the provisions of the
Rights of Persons with Disabilities Act, 20161, Rights of Persons with
Disabilities Rules, 20172, and Article 21 of the Constitution of India.
The writ petitions further seek to ensure that adequate measures
are undertaken to guarantee accessibility and provide reasonable
accommodations for persons with disabilities, in accessing financial
services, telecommunications, and government schemes.
3.1 For the sake of specificity, the prayers made in the respective
writ petitions are extracted below:
1 For short, “the RPwD Act, 2016”
2 For short, “the RPwD Rules, 2017”
2858 [2025] 4 S.C.R.
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W.P(C) No. 289 of 2024
“(i) To direct the Central Government to frame fresh
guidelines for providing alternative methods or means
to conduct the Digital KYC / e-KYC process for
acid-attack survivors suffering from permanent eye-
disfigurement or similarly placed individuals,
(ii) To direct all public and private establishments
conducting Digital KYC / e-KYC process to effectively
implement the aforesaid guidelines and frame
appropriate organizational policies to provide for
alternative methods or means that enable acid-attack
survivors suffering from permanent eye-disfigurement
or similarly placed individuals to conduct their Digital
KYC / e-KYC process,
(iii) To direct the Central Government to frame
appropriate provisions to clarify the meaning and
interpretation of “live photograph” as mentioned
under the Annexure I of the RBI – KYC Master
Directions, 2016 for conducting the Digital KYC
/ e-KYC process to expand its purview beyond
the blinking of eyes with other alternative criteria
such as movements of facial features and/or voice
recognition,
(iv) To direct the RBI to amend and / or frame suitable
alternatives for satisfying the requirement of “live
photograph” in the Digital KYC / e-KYC process
under Annexure I of the RBI – KYC Master Directions,
2016 to enable acid attack survivors suffering from
permanent eye-disfigurement and other similarly
placed individuals to conduct the KYC process
independently,
(v) To direct the Central Government, RBI, SEBI,
and TRAI to issue directions to all public and
private establishments regulated by them including
banks, financial institutions, service providers,
and intermediaries to establish account-based
relationships and /or provide other financial and
[2025] 4 S.C.R. 2859
Pragya Prasun & Ors. v. Union of India & Ors.
telecommunication services by using alternative
methods for conducting the Digital KYC / e-KYC
process that do not mandate acid attack survivors
suffering from permanent eye-disfigurement and other
similarly placed individuals to satisfy the “liveness”
criterion by blinking their eyes for the purpose of
completing the Digital KYC /e-KYC process,
(vi) To direct RBI, SEBI, and TRAI to issue instructions
to all public and private organisations and institutions
regulated by them including banks, financial
institutions, service providers, and intermediaries
wherein KYC is conducted to adopt and/or follow
offline and/or physical KYC procedures for acid attack
survivors suffering from permanent eye-disfigurement
and other similarly placed individuals who cannot
blink their eyes for conducting the Digital KYC /e-KYC
process, and
(vii) To direct the Central Government, RBI, SEBI, and
TRAI to sensitise all public and private establishments
conducting the Digital KYC / e-KYC to actively
assist acid attack survivors with permanent eye-
disfigurement and similarly placed individuals in
availing their banking, telecommunication and other
financial services.”
W.P (C) No.49 of 2025
“(i) To direct the Central Government, Reserve Bank
of India, Securities and Exchange Board of India,
Pension Fund Regulatory and Development Authority,
Insurance Regulatory and Development Authority of
India, Department of Telecommunications, Telecom
Regulatory Authority of India, to frame rules for
making the process of digital KYC/e-KYC accessible
to persons with blindness / low vision,
(ii) To direct the respondents to ensure effective
compliance of accessibility standards by all public
and private establishments conducting digital KYC/
e-KYC/ Video-KYC,
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(iii) To direct the Central Government to frame
appropriate provisions to expand or clarify the
meaning and interpretation of “live photograph”
as mentioned under the Prevention of Money
Laundering (Maintenance of Records) Rules, 2005,
Annexure I of the RBI - KYC Master Directions, 2016
for conducting the digital KYC/ e-KYC/ video-KYC
process, circulars issued by other respondents to
expand its purview beyond the blinking of eyes and
reading out text displayed on the screen with other
alternative criteria,
(iv) To direct the Reserve Bank of India to amend
and/or frame suitable alternatives for rejection of the
account opening process on account of prompting at
the end of the customer to accommodate assistance
taken by persons with blindness / low vision during
the digital KYC/e-KYC/ video-KYC process,
(v) To direct the Reserve Bank of India to amend
and/or frame suitable alternatives for satisfying the
requirement of signature verification in the digital
KYC/e-KYC process to enable persons with blindness
/ low vision to use thumb impressions,
(vi) To direct the respondents to sensitize all public
and private establishments conducting digital KYC/
e-KYC/ video-KYC to actively assist persons with
blindness / low vision in availing the services, and
(vii) To direct the respondents to consider the
accessibility needs of persons with disabilities
especially with blindness while framing any policies
for public at large.”
4. According to the petitioners in WP(C) No. 289 of 2024, who are acid
attack survivors, they have experienced difficulties in completing
the digital KYC / e-KYC process due to their inability to click a “live
photograph” by blinking, which has prevented them from opening a
bank account and purchasing a SIM card from the telecom providers.
It is the grievance of the petitioner in WP (C) No. 49 of 2025, who is
suffering from 100% blindness, that due to his disability, he faces daily
[2025] 4 S.C.R. 2861
Pragya Prasun & Ors. v. Union of India & Ors.
challenges in establishing account-based relationships, conducting
transactions, availing services and verifying his identity – whether as
a customer or as a citizen accessing government schemes. These
difficulties arise primarily because digital KYC / e-KYC / video KYC3
norms are not designed keeping in view the accessibility needs of
persons with disabilities. Thus, the digital KYC process that excludes
persons with disabilities is a violation of the fundamental rights
enshrined under Article 21 of the Constitution of India.
5. Continuing further, the learned counsel for the petitioners submitted
that vide RBI Master Direction, 2016, the digital KYC process has
been made mandatory. Following this, all major sectors - including
banking institutions, telecommunication companies, etc., require
KYC as a mandatory part of their registration processes. Accordingly,
digital KYC has now become indispensable for accessing essential
services, such as opening a bank account, demat and trading
accounts, SIM cards, pension accounts, insurance policies; any type
of financial investment, such as mutual funds, etc., obtaining Director
Identification Number from Ministry of Corporate Affairs, buying a
FASTag device for National Electronic Toll Collection, obtaining a
digital signature under the Information Technology Act, 2000, for
income tax return filing or for government tendering, and for high
value immovable property transactions involving buying, selling or
renting. It is also required for accessing government benefits such
as national scholarships, annual life certificates for pensioners, direct
benefit transfers using Aadhaar, etc. However, these processes are
not fully accessible to persons with disabilities, particularly individuals
with facial disfigurements and visual impairments.
6. Elaborating further, it is submitted by the learned counsel for the
petitioners that during the online KYC process, the following methods
are used to identify a customer:
(a) Clicking a selfie,
(b) Face recognition,
(c) Signing using pen and paper; or putting a signature on screen
using a mouse,
3 Hereinafter shortly referred to as “digital KYC”
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(d) Printing and rescanning or clicking a photo of the filled in form,
(e) Verification of OTPs in 30 seconds, displaying documents or
KYC form / signature in original, and
(f) Random question and response (e.g. flashing generic code/
text on screen for it to be read by the customer).
These methods are not accessible to persons with blindness, making
it impossible for them to complete the formalities independently without
physical assistance. For instance, the face recognition method does
not provide adequate guidance on how to correctly align one’s face
with the camera. Consequently, individuals with visual impairments
or facial disfigurements are often unable to complete the process
independently and require assistance from a sighted person. A similar
challenge exists with the selfie-based verification method, where the
lack of accessibility features prevents autonomous completion of the
process. Therefore, the learned counsel submitted that to eliminate
the barriers / difficulties faced by persons with facial disfigurements
and visual impairments, in exercising their right to live with dignity and
integrity at par with others, it is the statutory duty of the government
to implement “reasonable accommodations”, in accordance with the
provisions of the RPwD Act, 2016 read with the RPwD Rules, 2017.
7. The learned counsel also placed reliance on a catena of decisions
viz., Vikash Kumar v. Union Public Service Commission & Others4,
Rajive Raturi v. Union of India & Others5, Disabled Rights Group &
Anr. v. Union of India & Others6, etc., wherein, this Court reiterated the
fundamental duty of the State and its instrumentalities to safeguard
the welfare, dignity and autonomy of persons with disabilities, in order
to ensure their complete integration into the mainstream of society.
Further, it emphasized the need for economic empowerment and
inclusion of persons with disabilities.
8. Ultimately, the learned counsel for the petitioners submitted that
considering the difficulties and barriers faced on account of the
inaccessibility of the digital KYC process, this Court may pass
appropriate directions to the respondent authorities.
4 (2021) 5 SCC 370
5 (2018) 2 SCC 413
6 (2018) 2 SCC 397
[2025] 4 S.C.R. 2863
Pragya Prasun & Ors. v. Union of India & Ors.
9. Upon notice, learned counsel for the various respondents appeared
before us and submitted their responses, both orally and in writing.
For the sake of convenience, the same are summarised as under:
9.1 Respondent No.2 - Reserve Bank of India
9.1.1 It is submitted that the Central Government with an
intention to prevent money laundering and to combat
and prevent channelizing of money into illegal activities,
terror funding and other economic crimes, enacted
Prevention of Money Laundering Act, 20027. The PMLA
and its Rules, more specifically Prevention of Money
Laundering (Maintenance of Records) Rules, 2005 8
notified thereunder by the Central Government, make
it mandatory for the Banking Companies and Financial
Institutions, who are Reporting Entities to verify identity
of their clients, maintain records and furnish information
in the prescribed format to the Financial Intelligence
Unit India.
9.1.2 It is further submitted that under Section 11A(1) of the
PMLA, the Banking Companies and Financial Institutions
are under obligation to verify the identity of its clients, by-
(a) authentication under the Aadhaar (Targeted
Delivery of Financial and Other Subsidies,
Benefits and Services) Act, 2016 if the reporting
entity is a banking company; or
(b) offline verification under the Aadhaar
(Targeted Delivery of Financial and Other
Subsidies, Benefits and Services) Act, 2016; or
(c) use of passport issued under section 4 of
the Passports Act, 1967; or
(d) use of any other officially valid document
or modes of identification as may be notified
by the Central Government in this behalf:
7 For short, “the PMLA”
8 For short, “the Rules, 2005”
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9.1.3 It is further submitted that under Rule 9 of the Rules,
2005, every Banking Company is required to conduct
Client Due Diligence at the time of commencement of an
account-based relationship and identify its clients, verify
their identity, and obtain information on the purpose and
intended nature of the business relationship. In terms of
Rule 2(b) of the Rules, 2005, the Client Due Diligence
means ‘due diligence carried out on a client’. Further,
where client is an individual, then he is mandated under
Rule 9(4) to submit the following –
(a) the Aadhaar number where-
(i) he is desirous of receiving any benefit or
subsidy under any scheme notified under
Section 7 of the Aadhaar (Targeted Delivery
of Financial and Other subsidies, Benefits and
Services) Act, 2016
(ii) he decides to submit his Aadhaar number
voluntarily to a banking company or any
reporting entity notified under first proviso to
sub-Section (1) of Section 11A of the Act; or
(aa) The proof of possession of Aadhaar
number where offline verification can be
carried out; or
(ab) The proof of possession of Aadhaar
number where offline verification cannot
be carried out or any officially valid
document or the equivalent e-document
thereof containing the details of his
identity and address; and
(b) The Permanent Account Number or the equivalent
e-document thereof or Form No. 60 as defined in
Income-Tax Rules, 1962; and
(c) Such other documents including in respect of the
nature of business and financial status of the client,
or the equivalent e-documents thereof as may be
required by Reporting Entity.
[2025] 4 S.C.R. 2865
Pragya Prasun & Ors. v. Union of India & Ors.
9.1.4 It is further submitted that as per Rule 2(ab) of the Rules,
2005, “authentication” means the process as defined
under Section 2(c) of the Aadhaar (Targeted Delivery of
Financial and other subsidies, Benefits and Services) Act,
2016, which means the process by which the Aadhaar
number along with demographic information or biometric
information of an individual is submitted to the Central
Identities Data Repository (CIDR) for its verification with
respect to the correctness, or the lack thereof, on the
basis of information available with it.
9.1.5 It is further submitted that under Rule 2(bba) of the Rules,
2005, “digital KYC” means capturing the live photo of the
client and the officially valid documents or the proof of
possession of Aadhaar where offline verification cannot
be carried out along with the latitude and longitude of
the location where such live photo is being taken by an
authorized officer of the reporting entity.
9.1.6 It is further submitted that under Regulation 2(j) of the
Aadhaar (Authentication) Regulations, 2016, e-KYC
authentication means a type of authentication facility
in which the biometric information and/ or OTP along
with the Aadhaar number securely submitted with
the consent of the Aadhaar number holder through a
requesting entity, is matched against the data available
in the CIDR, and the authority returns a digitally
signed response containing the e-KYC data along with
other technical details related to the authentication
transaction.
9.1.7 Furthermore, in Annexure 1 to the Rules, 2005, the Central
Government has prescribed the process of Digital KYC,
as per which, the following is mandated:
(a) The Reporting Entities shall develop an application
for digital KYC process which shall be made
available at customer touch points for undertaking
KYC of their customers and the KYC process shall
be undertaken only through this authenticated
application of the Reporting Entities.
2866 [2025] 4 S.C.R.
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(b) The access of the Application shall be controlled by
the RE and it should be ensured that the same is not
used by unauthorized persons. The Application shall
be accessed only through login-id and password or
Live OTP or Time OTP controlled mechanism given
by REs to its authorized officials.
(c) The customer, for the purpose of KYC, shall visit the
location of the authorized official of the Reporting
Entities or vice-versa. The original Officially Valid
Document (OVD) shall be in possession of the
customer.
(d) The Reporting Entities must ensure that the
Live photograph of the customer is taken by the
authorized officer and the same photograph is
embedded in the Customer Application Form (CAF).
Further, the system Application of the RE shall put
a water-mark in readable form having CAF number,
GPS coordinates, authorized official’s name, unique
employee Code (assigned by REs) and Date
(DD:MM:YYYY) and time stamp (HH:MM:SS) on
the captured live photograph of the customer.
(e) The Application of the Reporting Entities shall
have the feature that only live photograph of the
customer is captured and no printed or video-
graphed photograph of the customer is captured.
The background behind the customer while
capturing live photograph should be of white
colour and no other person shall come into the
frame while capturing the live photograph of the
customer.
(f) Similarly, the live photograph of the original
OVD or proof of possession of Aadhaar where
offline verification cannot be carried out (placed
horizontally), shall be captured vertically from above
and water-marking in readable form as mentioned
above shall be done. No skew or tilt in the mobile
device shall be there while capturing the live
photograph of the original documents.
[2025] 4 S.C.R. 2867
Pragya Prasun & Ors. v. Union of India & Ors.
(g) The live photograph of the customer and his original
documents shall be captured in proper light so that
they are clearly readable and identifiable.
(h) Thereafter, all the entries in the CAF shall be filled
as per the documents and information furnished
by the customer. In those documents where Quick
Response (QR) code is available, such details can
be auto-populated by scanning the QR code instead
of manual filing the details. For example, in case
of physical Aadhaar/e-Aadhaar downloaded from
UIDAI where QR code is available, the details like
name, gender, date of birth and address can be
auto-populated by scanning the QR available on
Aadhaar/e-Aadhaar.
(i) Once the above-mentioned process is completed,
a One Time Password (OTP) message containing
the text that ‘Please verify the details filled in form
before sharing OTP’ shall be sent to customer’s
own mobile number. Upon successful validation of
the OTP, it will be treated as customer signature
on CAF. However, if the customer does not have
his/her own mobile number, then mobile number
of his/her family/relatives/known persons may be
used for this purpose and be clearly mentioned in
CAF. In any case, the mobile number of authorized
officer registered with the Reporting Entities shall
not be used for customer signature. The Reporting
Entities must check that the mobile number used in
customer signature shall not be the mobile number
of the authorized officer.
(j) The authorized officer shall provide a declaration
about the capturing of the live photograph of
customer and the original document. For this
purpose, the authorized official shall be verified
with One Time Password (OTP) which will be sent
to his mobile number registered with the Reporting
Entities. Upon successful OTP validation, it shall
be treated as authorized officer’s signature on the
2868 [2025] 4 S.C.R.
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declaration. The live photograph of the authorized
official shall also be captured in this authorized
officer’s declaration.
(k) Subsequent to all these activities, the Application
shall give information about the completion of the
process and submission of activation request to
activation officer of the Reporting Entities, and also
generate the transaction-id/reference-id number of
the process. The authorized officer shall intimate the
details regarding transaction-id/reference-id number
to customer for future reference.
(l) The authorized officer of the Reporting Entities shall
check and verify that:-
(i) information available in the picture of document
is matching with the information entered by
authorized officer in CAF;
(ii) live photograph of the customer matches with
the photo available in the document; and
(iii) all of the necessary details in CAF including
mandatory field are filled properly.
(m) On Successful verification, the CAF shall be digitally
signed by authorized officer of the RE who will take
a print of CAF, get signatures/thumb-impression
of customer at appropriate place, then scan and
upload the same in system. Original hard copy may
be returned to the customer.
9.1.8 Thus, the requirement to conduct due diligence of its
clients by the banking companies and the financial
institutions is mandated under the provisions of the PMLA
and the Rules, 2005, and that, the process of verifying
the documents submitted by the clients is also included
in various rules and regulations as well as Acts as stated
above. Hence, the Reserve Bank of India in compliance
with Rule 9(14) of the Rules 2005, has issued the Reserve
Bank of India (Know Your Customer KYC) Directions,
2016, thereby reproducing and reiterating the process
and procedure prescribed in the PMLA Rules, 2005.
[2025] 4 S.C.R. 2869
Pragya Prasun & Ors. v. Union of India & Ors.
9.1.9 In reply to the submissions made on the side of the
petitioners, it is submitted by the learned counsel for
the RBI as under:
(a) RBI is not an appropriate authority to carry
out amendments so as to include the specific
suggestions of the petitioners in the already
elaborated and described process of digital KYC
in the PML Rules. However, it is reiterated that the
digital KYC process outlined in Annex I of the MD
on KYC and the V-CIP outlined in the MD on KYC
does not mandate Regulating Entities to necessarily
undertake ‘blinking eye’ test and the bank official
can ask varied questions to establish the liveness
of the customer during the V-CIP.
(b) In terms of paragraph 16 of the MD on KYC, when a
customer submits the proof of possession of Aadhaar
number where offline verification can be carried
out, the Regulating Entities shall carry out offline
verification. Further, when a customer submits any
OVD or proof of possession of Aadhaar where offline
verification cannot be carried out, the Regulating
Entities shall carry out verification through Digital
KYC. However, for a period not beyond such date
as may be notified by the Government for a class
of Regulating Entities, instead of carrying out Digital
KYC, the Regulating Entities pertaining to such
class may obtain a certified copy of the proof of
possession of Aadhaar number or the OVD and a
recent photograph where an equivalent e-document
is not submitted. Thus, RBI has already issued
comprehensive guidelines prescribing different
modes to carry out customer due diligence in terms
of respective PML Rules.
(c) As per the instructions regarding V-CIP outlined
under paragraph 18 of the MD on KYC, Regulated
Entities may undertake V-CIP to carry out CDD in
case of new customer on-boarding for individual
customers, proprietor in case of proprietorship
2870 [2025] 4 S.C.R.
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firm, authorized signatories and Beneficial Owners
(BOs) in case of Legal Entity (LE) customers. In
terms of paragraph 18(b)(i) of MD on KYC, each
Regulated Entity shall formulate a clear workflow
and standard operating procedure for V-CIP and
ensure adherence to it. The V-CIP process shall be
operated only by officials of the Regulated Entities
specially trained for this purpose. The official should
be capable to carry out liveness check and detect
any other fraudulent manipulation or suspicious
conduct of the customer and act upon it. Further, as
per paragraph 18(b)(iii), the sequence and/or type
of questions, including those indicating the liveness
of the interaction, during video interactions shall be
varied in order to establish that the interactions are
real-time and not pre-recorded. Furthermore, as
per para 11, Customer Acceptance Policy should
not result in denial of banking/financial facility to
members of the general public, especially those,
who are financially or socially disadvantaged.
(d) According to RBI, the guidelines regarding V-CIP
are already in place. As per paragraph 4 of the
MD on KYC, the Regulated Entities are directed to
have a KYC policy duly approved by the Board of
Directors. Furthermore, the Regulated Entities are
also mandated under the MD on KYC to ensure that
they comply and follow the directions issued by RBI.
(e) Referring to Clause 3(ii) of the Aadhaar
(Authentication and Offline Verification) Regulation
2021, it is submitted that in terms of proviso (i) to
paragraph 16 of the MD on KYC, when a customer
submits Aadhaar number under paragraph 16(a),
the Regulated Entities shall carry out authentication
of the customer’s Aadhaar number using e-KYC
authentication facility provided by the Unique
Identification Authority of India. e-KYC authentication
can be carried out through biometric e-KYC
authentication or OTP based e-KYC authentication
(face to face).
[2025] 4 S.C.R. 2871
Pragya Prasun & Ors. v. Union of India & Ors.
9.1.10 Thus, it is submitted by the learned counsel, adherence
to the guidelines/ notifications/directions issued by RBI
and other regulatory/ statutory bodies are monitored
and checked during the supervisory review process
carried out by the supervisory departments of RBI; and
that, RBI has conducted public awareness campaigns
and issued press-releases in respect of various KYC /
re-KYC issues. Besides this, RBI has been conducting
workshops/ training programmes for its Regulated
Entities to sensitize them about the instructions issued
through MD on KYC.
9.2 Respondent No.4 - Telecom Regulatory Authority of India (TRAI)
It is submitted that TRAI draws its powers and functions from the
Telecom Regulatory Authority of India Act, 19979 and the rules/
regulations framed thereunder. It has no statutory role in the
formulation or implementation of Digital KYC/e-KYC guidelines.
The issues concerning subscriber verification, including KYC
norms, fall exclusively within the domain of the Department
of Telecommunications, which is the licensing authority for
telecom service providers. Therefore, according to TRAI, it lacks
jurisdiction or authority to frame any policy or issue directions
concerning Digital KYC/e-KYC processes.
9.3 Respondent No.5 - Deparment of Telecommunications
9.3.1 It is submitted that the Central Government grants licenses
under Section 4 of the Indian Telegraph Act, 1885, for
various types of telecom services including Access
Services, Internet Services, etc. Access Services cover
collection, carriage, transmission and delivery of voice
and/or non-voice messages over licensee’s network in the
designated service area, and includes mobile, wireline and
internet services. An Internet Service Provider provides
data services.
9.3.2 It is submitted that the relevant KYC condition as
contained in clause 39.17(i) of the Unified License
9 For short, “the TRAI Act”
2872 [2025] 4 S.C.R.
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Agreement mandates that the Licensee shall ensure
adequate verification of each and every customer
before enrolling him as a subscriber and shall follow
instructions issued by the Licensor in this regard from
time to time. The Licensee shall make it clear to the
subscriber that the subscriber will be responsible for
proper and bona fide use of the service. Pursuant to
the same, the Department of Telecommunications has
been issuing KYC guidelines / instructions, which are
being followed by the licensees for the purpose of
issuing new mobile connections to subscribers and for
SIM replacement.
9.3.3 It is further submitted that as per the direction of this Court
in Avishek Goenka v. Union of India in W.P.(C) No.285
of 2010, a Joint Expert Committee was constituted in the
Department of Telecommunications and based on the
report submitted by the Committee, instructions dated
09.08.2012 in Letter No. 800-09/20010-VAS titled as
“Instruction on Verification of New Mobile subscribers
(Pre-paid and Post-paid)” came to be issued. The said
instructions laid down KYC provisions for issuing mobile
connections to individual, outstation, foreign and business
category customers. There are also additional provisions
dealing with mobile connections obtained on fake / forged
documents, timely disconnections in case of KYC non-
compliance or directions of Law Enforcement Agencies,
etc. That apart, various documents have been allowed
as valid proof of identity/ proof of address documents for
obtaining mobile connections.
9.3.4 It is further submitted that on 03.04.2019 vide Letter
No. 800-26/2016-AS.II, Instructions for Alternate Digital
KYC process for issuing new mobile connections to
subscribers were introduced by the Department of
Telecommunications, wherein it was stated that the
Customer Acquisition Form (CAF) is to be embedded
with the live photograph of the subscriber along with the
original proof of Identity / Proof of Address document,
thereby making the KYC process fully digital and
paperless.
[2025] 4 S.C.R. 2873
Pragya Prasun & Ors. v. Union of India & Ors.
9.3.5 After the amendment of the Indian Telegraph Act, in July,
2019, the identification of a person through Aadhaar
authentication cannot be made mandatory as the use
of modes of identification under Section 4(3) is the
voluntary choice of the person and no person can be
denied any service for not having an Aadhaar Number.
Further, the Telecom Regulatory Authority of India has
made the following recommendation dated 09.07.2018
on “Making ICT accessible for Persons with Disabilities”:
(a) All TSPs should identify existing mobile/landline
numbers of their customers who are eligible to be
classified under persons with disabilities. Provision
should be made in the CAF for registering new
customers as ‘Persons with disabilities’ in case he/
she is a person with disability. All such numbers
should be assigned a special category.
(b) TSPs, MSOs and DTH Operators should have
a special desk in their Call Centres / Customer
Support Centres where calls received from special
category numbers are routed to this specialized
desk which should be manned by person(s) to
receive calls from Persons with disabilities using
assistive technologies.
9.3.6 After consultation with the Department of Empowerment
of Persons with Disabilities (DEPwD), the Department of
Telecommunications issued a letter dated 16.12.2020,
wherein, priority and specialized services in respect of
customer support services have been incorporated for
persons with disabilities customers. Thus, regarding
mobile services to persons with disabilities customers,
the Department of Telecommunications has already
made special provisions and additional safeguards
for persons with disabilities customers to the extent
possible.
9.3.7 It is submitted that the Department of Telecommunications
reintroduced Aadhaar based e-KYC process vide Letter
No. 800-12/2019–AS II dated 21.09.2021 wherein
the use of Aadhaar based e-KYC service of Unique
2874 [2025] 4 S.C.R.
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Identification Authority of India (UIDAI) has been
adopted as an alternate process for issuing mobile
connections to individual customers including outstation
customers and bulk connection. In Aadhaar based
e-KYC, the subscriber is authenticated biometrically
and demographic details are fetched from the UIDAI
database. Live photograph of the customer is taken and
matched with the photo received from UIDAI.
9.3.8 Pursuant to the instructions issued by the Department of
Telecommunications vide Letter No. 800-09/2023-AS II
dated 31.08.2023, additional strict measures have been
incorporated into the KYC process viz., (a) end user
KYC in business connections, (b)use of Digital-KYC/e-
KYC process in case of SIM swap / replacement, and
(c) other enhanced safeguards.
9.3.9 It is submitted that the Department of Telecommunications
is continuously committed to improving the KYC
process and make it user friendly. With passage of
time, the KYC process has improved, attaining better
verification norms and maintaining the orderly growth
of the telecommunications sector. In order to enhance
security and authenticity of the KYC process adopted
by licensees, the Department of Telecommunications
issued instructions on 05.12.2023 for the discontinuation
of the paper - based KYC process with effect from
01.01.2024.
9.3.10 Pursuant to the grievance expressed by the first petitioner
in WP(C) No. 289 of 2024 vide communication dated
12.02.2024, the Department further issued instructions
dated 19.03.2024 whereby, paper - based KYC process
was allowed in certain exceptional cases for obtaining
new mobile connections and SIM replacements. PwD
customers have been included among those exceptional
cases and may obtain mobile connections and do SIM
replacements using paper - based KYC process, which
does not require live photography or blinking of the eyes.
Further, additional benefits viz., priority and specialized
customer support services have also been provided to
PwD customers.
[2025] 4 S.C.R. 2875
Pragya Prasun & Ors. v. Union of India & Ors.
9.3.11 It is further submitted that Telecom Service Providers
(TSPs) and financial entities are distinct entities, each
governed by the relevant law that applies to them.
TSPs do not maintain Central KYC registry. As per the
provisions of licensing framework notified by DoT, each
TSP has to ensure adequate verification of each and
every customer before enrolling them as subscribers
and sharing of KYC information among different entitles,
is not permitted.
9.3.12 Thus, it is submitted that the Department of
Telecommunications has not mandated eye - blinking
as the sole mechanism to determine the liveliness of
the customer’s photograph during enrolment.
9.4 Respondent No.7 – Securities Exchange Board of India (SEBI)
9.4.1 It is submitted that SEBI, being the regulator of
securities market, has always been committed to the
cause of making the securities market accessible to
all by catering to the special requirements of persons
with disabilities, while at the same time balancing the
need of providing secure digital platforms and effectively
managing the risk of money laundering and terrorist
financing through securities market. It is also submitted
that the SEBI is ready to take necessary measures as
mandated by law.
9.4.2 It is further submitted that Clauses 33 to 48 of the Master
Circular dated 12.10.2023 deal with the procedure
prescribed for Digital KYC. According to Clause 46, a
cropped signature affixed on the online KYC form under
electronic / digital signature, including Aadhaar e-sign, will
also be accepted as a valid signature. Thus, the Master
Circular provides for an alternative to electronic / digital
signature, which can be availed of by any person, who
is unable to do electronic / digital signature.
9.4.3 It is further submitted that SEBI permits registered
intermediaries to use online application for completing
digital KYC to enable seamless, real-time, secured,
end-to-end encrypted audio-visual interaction with the
2876 [2025] 4 S.C.R.
Supreme Court Reports
client. Digital KYC is an additional option available to the
investors, along with the option of physical KYC. Thus,
a person who, due to blindness or low vision is unable
to e-sign a document, can opt for offline/ physical KYC
and affix a thumb impression instead of signature.
9.4.4 Further, as mentioned in para 5 of the FAQs titled as
“FAQs on Demat Account and Trading Account by
Persons with Disability” issued by Respondent No.7, if
a person with disability is unable to sign for himself /
herself, the account can be opened with the signature
of the guardian.
9.4.5 It is further submitted that Clause 47 provides for cancelled
cheque for capturing bank details of the client. It also
provides that verification of the bank account details
can be carried out through Penny Drop Mechanism or
any other mechanism using the API of the Bank. SEBI
is open to include other possible documents that may
be used by the registered intermediaries for capturing
the bank details of the clients.
9.4.6 Regarding the requirement of liveliness check as
provided under clause 52, it is submitted that the same
is done in order to guard against spoofing and other
fraudulent practices. The securities market intermediaries
use various parameters to check the client’s liveliness
which not only involves checking the movement of
eyelid and eyeball or blinking, but also, includes other
factors viz., live facial expressions, nodding of head,
client showing OTP while being clearly visible on the
screen, real time video recording and displaying copies
of documents on the screen, etc. Further, on request
of a client, the registered intermediaries are required
to extend all possible assistance for capturing video
in live environment to facilitate online/digital KYC to
persons with disabilities. It is further submitted that the
website maintained by the SEBI is in compliance with
the requirements of the RPwD Act, 2016 and the RPwD
Rules, 2017. The website also complies with World
Wide Web Consortium (W3C) Web Content Accessibility
[2025] 4 S.C.R. 2877
Pragya Prasun & Ors. v. Union of India & Ors.
Guidelines (WCAG) 2.0 level AA and has assistive
technologies to enable people with visual impairment
to access the website. In addition, SEBI is in process
of seeking an accessibility audit by an International
Association of Accessibility Professionals certified
auditor. Further, SEBI has also advised all the Market
Infrastructure Intermediaries (MIIs) who fall within the
regulatory regime of SEBI to bring to the attention of all
their members/ intermediaries for necessary compliance,
the provisions of Sections 42 and 46 of the RPwD Act,
2016 r/w Rule 15 of the RPwD Rules, 2017.
9.4.7 It is further submitted that Clause 60 of the Master Circular
provides for the option of Video in Person Verification
(VIPV) of the investor as one of the methods of doing
In-Person Verification. This option is in addition to/ as
an alternative to physical In-Person Verification. Further,
this clause clearly states that the VIPV process can be
carried out by any of the many methods including random
question and response from the investor; displaying
officially valid document; KYC form and signature; or it
could also be confirmed by an OTP.
9.4.8 It is further submitted that Clause 61 of the Master
Circular provides that in person verification shall not be
required in certain cases where (a) KYC of the client
has been completed using the Aadhaar authentication /
verification of UIDAI; (b) KYC form has been submitted
online, documents have been provided through Digilocker
or any other source which could be verified online. These
are additional options available to all investors including
persons with blindness/ low vision.
9.4.9 It is further submitted that the FAQs have been put in
place to guide the investors and market participants.
Such interpretations are valid being transparent and
applied consistently without discrimination. It is reiterated
that SEBI is committed to the cause of enabling equal
access of services of its registered intermediaries to
persons with disabilities, including persons with visual
impairments and has complied with the directions issued
2878 [2025] 4 S.C.R.
Supreme Court Reports
by the Chief Commissioner for PwD from time to time in
this regard. At the same time, it is imperative for SEBI
as the Regulator of securities market to build in / retain
necessary checks to ensure that the securities market
platforms are secured.
9.5 Respondent No.8 – Pension Fund Regulatory & Development
Authority (PFRDA)
9.5.1 It is submitted that PFRDA is a statutory authority
established by the Government of India under the
Pension Fund Regulatory Authority and Development
Authority Act, 201310 to regulate, promote and ensure
orderly growth of the National Pension System11 and to
protect the interests of subscribers of such system and
schemes of pension funds.
9.5.2 It is further submitted that Circular no. PFRDA/2020/46/
SUP-CRA/18 dated 06.10.2020 prescribes the norms
for V-CIP for the National Pension System (NPS) which
is regulated by this respondent. Some of the important
norms are as follows:
Mobile Application based VCIP
(a) Points of Presence (PoPs) shall carry out the
liveliness check in order to guard against spoofing
and other fraudulent manipulations.
(b) PoPs can add additional safety and security features,
other than prescribed above.
(c) PoPs should ensure Instant bank account verification
through penny drop, to verify the beneficiary bank
details is mandatory.
(d) The photo/signature of the subscriber is to be
uploaded during VCIP while On-boarding.
10 For short, “the PFRDA Act”
11 For short, “the NPS”
[2025] 4 S.C.R. 2879
Pragya Prasun & Ors. v. Union of India & Ors.
Non-Mobile Application based VCIP
(a) PoPs through their authorized official, specifically
trained for this purpose, may undertake live VCIP
of an individual subscriber/applicant, after obtaining
their informed consent.
(b) The VCIP shall be only in a live environment.
(c) The VCIP shall be clear and undisturbed. Further,
the NPS subscriber/applicant in the video shall be
easily re-cognizable and shall not be covering their
face in any manner.
(d) The VCIP process shall include random question
and response from the NPS subscriber/applicant
including displaying the OVD as specified by PFRDA
in its CSRF/Exit Form/Service request forms.
(e) PoPs shall ensure that photograph of the subscriber
provided in KYC documents/PRAN card/CSRF,
as the case may be, matches with the Subscriber
during VCIP.
(f) PoPs should ensure instant bank account verification
through penny drop, to verify the beneficiary bank
details is mandatory.
(g) PoPs can add additional safety and security features,
other than prescribed above.
9.5.3 It is further submitted that according to section 40 of
the RPwD Act, 2016, the Central Government vide
Gazette notification dated 16.08.2024 has issued the
Accessibility Standards and Guidelines (for Creating
Infrastructure for Persons with Disabilities) for PFRDA-
Regulated Intermediaries to address accessibility needs
of persons with disabilities in respect of the facilities
and services pertaining to pension schemes regulated
by PFRDA. Clause 3.1 of the said Guidelines pertaining
to Accessibility of website and application for visually
impaired persons, mandate the intermediaries to design
and develop user-friendly website and app (with the
enablement of text-to-speech software) in such a way
2880 [2025] 4 S.C.R.
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that they are accessible by all persons including visually
impaired. Further, these Guidelines have been sent
to intermediaries for ensuring compliance. That apart,
the said Guidelines also mandate PFRDA regulated
intermediaries to implement the following:
(a) ‘Guidelines for India Government Websites and
Apps’ (GIGW) as amended issued by Ministry of
Electronics and Information Technology (MEITY)
which prescribes accessibility standards for websites
and apps.
(b) Indian standards IS 17802 (Part 1), 2021 and IS
17802 (Part 2), 2022, issued by MEITY and notified
by the Bureau of Indian Standards (BIS) which
prescribes accessibility standards for Information
and Communication Technology (ICT) products
and services.
9.5.4 In response to the submissions made by the petitioners
regarding the challenges faced by them, it is submitted
as follows:
(a) The circular dated 06.10.2020 on VCIP for NPS
prescribes that a ‘liveness check’ must be conducted,
but does not prescribe blinking as the only method
and that, there is a requirement under PML Rules
2005 of displaying/capturing the live photo of
‘Officially Valid Document’ (OVD) where offline
verification cannot be carried out.
(b) In the said circular dated 06.10.2020 for VCIP for
NPS, there is a requirement of “random action
initiation for subscriber response” as part of the
liveliness check in cases of Mobile Application based
VCIP. The application shall also have features of
random action initiation for subscriber’s response
to establish that the interactions are not recorded.
Further, the application should have time stamping
and geo-location tagging to ensure physical location
in India, etc. However, presently provision of audio
captcha as an alternative to visual captcha is not
specified in the circular.
[2025] 4 S.C.R. 2881
Pragya Prasun & Ors. v. Union of India & Ors.
(c) As per clause 4 of PFRDA Accessibility Guidelines,
this respondent is taking steps for training of
personnel and sensitization towards needs of
persons with disabilities and for assisting them in
use of various available services.
(d) PFRDA has through Clause 5(ii) of PFRDA
Accessibility Guidelines specified that intermediaries
must give a special focus to grievances raised by
persons with disabilities. The grievance redressal
officer nominated by the intermediary under the
PFRDA (Redressal of Subscriber Grievance)
Regulations, 2015, shall be the nodal officer for
addressing the issues related to persons with
disabilities.
(e) Under Circular no. PFRDA/2020/23/SUP-CRA/10
dated 15.06.2020, NPS permits paperless
onboarding through OTP verification as one of the
acceptable methods and hence it is not necessary
for signature to be made physically or on screen.
Presently, only during physical application mode,
thumb impression is being accepted, whereas in
Digital KYC and VCIP thumb impression is not
prescribed/accepted. This thumb impression must
be attested by two individuals, one of whom should
be an authorized official of the intermediary (Point
of Presence), who must certify it under their official
seal and stamp.
9.5.5 Thus, it is submitted that this respondent is committed
to ensuring the provision of services in a manner that is
equally accessible to persons with visual impairments,
including taking all reasonable measures to comply with
existing accessibility norms. This respondent is further
committed to complying with any directions issued by this
court to enhance accessibility in the digital KYC process
for persons with disabilities.
9.6 Respondent No.9 – Insurance Regulatory and Development
Authority of India
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9.6.1 It is submitted that in terms of the provisions of the
Prevention of Money Laundering Act, 2002, and the
Prevention of Money Laundering (Maintenance of
Records) Rules, 2005, this respondent has issued
Master Guidelines on Anti Money Laundering/Counter
Terrorist Financing (AML/CFT) 2022 on 01.08.2022, which
provides framework related to KYC for issuance sector.
9.6.2 It is further submitted that as per the regulatory framework
put in place, this respondent did not make digital KYC and
VBIP mandatory and it is being provided as one among
many options for customer identification process. Both
digital and VBIP are assisted by Authorised Officials /
Persons of REs. These officials / persons can assist
customers in completing KYC by taking photos, aligning
camera, aligning documents, etc. Further, paragraph
M of digital KYC process provides for obtaining either
signature or thumb impression of customer.
9.6.3 It is further submitted that paragraph 12 of the IRDAI
Master Guidelines permit use of Central KYC Records
Registry (CKYCR) for KYC. Moreover, vide IRDAI circular
dated 12.08.2024, REs are mandated to seek KYC
Identifier from customer which eliminate the requirement
to submit the KYC documents. Alternatively, if KYC ID is
not available with customers, REs are required to search
the CKYC ID and download the records from CKYCR,
if available.
9.6.4 It is submitted that an option of Aadhaar based e-KYC is
also in place wherein KYC details are downloaded from
UIDAI with customer consent. Framework for the same
is prescribed by UIDAI and as per this framework, in
addition to biometric, OTP based authentication is also
available for KYC. Submission of physical copy of Officially
Valid Documents or e-documents are also permitted for
KYC purposes. That apart, there are provisions available
for disabled persons to nominate a person to submit
declaration on their behalf.
9.6.5 Thus, according to this respondent, they have put in
necessary provisions for seamless completion of KYC
[2025] 4 S.C.R. 2883
Pragya Prasun & Ors. v. Union of India & Ors.
for visually disabled persons in the insurance sector
in the form of other alternate modes/methodologies of
KYC for ensuring equal access to persons with visual
impairment / blindness.
10. We have considered the submissions made by the learned counsel
appearing for all the parties and perused the materials placed before
us.
11. At the outset, it is to be pointed out that the respondent authorities
have not raised any adverse remarks regarding the grievances
expressed by the petitioners and they are committed to assist us
in arriving at a just and effective solution to advance the rights and
enhance the quality of life of persons with disabilities, particularly
those with facial disfigurements and visual impairments or blindness.
12. As stated earlier, in an effort to combat illegal activities and money
laundering, the Central Government through the PMLA and the Rules,
2005, mandated that all financial and banking institutions conduct
client identity verification, maintain comprehensive records, and report
relevant information to the Financial Intelligence Unit – India. Pursuant
to the same, the Reserve Bank of India issued the Master Direction
on Know your Customer (KYC), 201612. The Master Direction on
KYC prescribes the framework for Customer Due Diligence (CDD)
procedures and outlines the digital KYC process under Chapter VI
and Annex I, respectively. Additionally, Clause 18 of the MD on KYC
introduced the Video based - Customer Identification Process (V-CIP)
enabling remote customer verification through secure, real-time
video interaction. As a result, multiple sectors – including banking,
telecommunications, insurance, and mutual funds – have adopted
digital KYC as a mandatory component of their CDD or Customer
Identification Program (CIP) obligations, thereby facilitating identity
verification of prospective customers in compliance with regulatory
requirements.
13. According to the petitioners, while it is mandatory for Regulated
Entities to conduct offline verification at the ground level, many
Regulated Entities have refused to do so, even when customers
submit valid proof of possession of Aadhaar in compliance with
12 For short, “MD on KYC”
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sub-clause (aa) of paragraph 16 of the MD on KYC. Secondly,
under Option 2, if a customer submits an Offline Based Document
(OBD) or an equivalent e-document, the Regulated Entities are
required to verify the customer’s digital signature and capture a live
photograph as specified under Annex I of the MD on KYC. However,
this requirement creates an unintended barrier for individuals with
facial / eye disfigurements and visual impairments like the petitioners
herein, as they are unable to fulfill the condition of providing a live
photograph due to their inability to blink, thereby rendering them
unable to complete the digital KYC process under this option.
13.1 The petitioners further detailed the problems faced by them,
with the existing guidelines as under:
(i) Absence of definition of the term “liveness” and
accessibility issues in liveness checks — No criterion
for gauging “liveness” of a customer has been defined
in any of the guidelines pertaining to the digital KYC
process. In practice, Regulated Entities have developed
methods such as requiring eye-blinking, reading a random
code displayed on screen, or handwriting the displayed
code and clicking a photograph of themselves with the
handwritten code. However, persons with blindness
would, in the majority of cases, be unable to comply with
these procedures.
Many Regulated Entities either directly capture a selfie as
soon as a face and eye-blinking are detected, or provide
a button to allow the user to click a selfie. However,
the digital KYC providers do not follow accessibility
standards while designing their websites or applications,
including providing features to assist in clicking a picture
through the camera. As a result, persons with blindness
have no guidance regarding camera alignment, face
focusing, lighting adequacy, or other parameters used to
assess the quality of the picture. Similarly, persons with
blindness are unable to distinguish the front or back side
of documents for uploading purposes, or adjust lighting
and angles appropriately.
Further, the majority of such persons use thumb
impressions, being unable to consistently draw signatures
[2025] 4 S.C.R. 2885
Pragya Prasun & Ors. v. Union of India & Ors.
using pen and paper. At present, none of the digital KYC
providers accept an image of a thumb impression as
a valid signature, although they accept an image of a
signature drawn using pen and paper. Furthermore, PAN
cards issued based on thumb impressions are also not
accepted by entities.
The Regulated Entities also fail to comply with the
standards of accessibility prescribed in the “Standards
of Accessibility for ICT Products and Services” (Part I &
II) issued in 2021 and 2022, as notified by the Central
Government under Section 40 of the Rights of Persons
with Disabilities Act, 2016, by way of amendment to Rule
15(1) of the Rights of Persons with Disabilities Rules,
2017, notified on May 10, 2023.
(ii) Inaccessibility of biometric devices — All biometric
devices presently designed for Aadhaar authentication,
where the Aadhaar number is captured or information
is displayed on screen, do not comply with IS 17802
Accessibility Standards for ICT Products and Services.
As a result, there is no text-to-speech facility or other
accessibility features available to assist persons with
blindness in inputting relevant information or in verifying
the information entered or displayed on screen.
(iii) Lack of awareness — Officials and third-party agents
deployed by regulated entities, including officials
responsible for concurrent audits, are not adequately
trained or sensitized to assist persons with blindness in
performing digital KYC or in facilitating the digital KYC
process for them. Many persons with blindness are either
asked to physically visit the office of the entity (which,
in the case of new-age entities operating only through
digital platforms, may not even exist near their place of
residence or work) or have their digital KYC applications
rejected on technical grounds.
(iv) Prohibition on prompting — The RBI Master Directions
on KYC prohibit prompting while performing digital KYC,
thereby leaving persons with blindness without any
effective remedy, as they are neither provided assistance
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by the officials of the regulated entities nor permitted to
take help from any third party.
Thus, the petitioners, who suffer from facial or eye
disfigurements caused by acid attacks and from 100%
blindness, are unable to independently complete digital
KYC processes due to the inaccessibility of the current
digital KYC regulations. This results in their exclusion
from accessing services provided by both public and
private establishments.
LEGAL FRAMEWORK
14. Various constitutional and statutory provisions place an obligation on
the appropriate Government to ensure that necessary modifications
and adjustments are made to enable persons with disabilities to
enjoy and exercise their rights equally with others. Some of the key
provisions under the Constitution and laws are outlined below :
14.1 Constitution of India, 1950
14.1.1 The Preamble to the Constitution of India, enshrines
the objective of securing for all citizens Justice -
social, economic, and political – and liberty of thought,
expression, belief, faith and worship. Part III of the
Constitution provides for a set of six Fundamental
Rights to all citizens, and in some cases, to non-
citizens as well. These rights include: the Right to
Equality, the Right to Freedom, the Right against
Exploitation, the Right to Freedom of Religion,
Cultural and Educational Rights, and the Right to
Constitutional Remedies. All these rights are equally
available to persons with disabilities, even though
they are not specifically mentioned in this part of
the Constitution.
14.1.2 The Directive Principles of State Policy are incorporated
in Part IV of the Constitution. Although they are not
justiciable, they have been declared fundamental
to the governance of the country. These principles
are intended to serve as the essential basis of state
policy and act as guidance for future legislatures and
[2025] 4 S.C.R. 2887
Pragya Prasun & Ors. v. Union of India & Ors.
executives in framing laws and policies. Article 41 of
the Constitution refers to cases of disablement and
reads as under:
“The State shall, within the limits of its economic
capacity and development, make effective
provision for securing the right to work, to
education, and to public assistance in cases
of unemployment, old age, sickness and
disablement, and in other cases of undeserved
want.”
14.2 United Nations Convention on the Rights of Persons with
Disabilities (UNCRPD)
14.2.1 India signed the United Nations Convention on the
Rights of Persons with Disabilities (UNCRPD), 2006,
on 30th March, 2007 and ratified it on 1st October,
2007. The Convention came into force in the country
with effect from 3rd May 2008. It places the following
three important obligations on each State Party:
(i) To respect the rights and freedoms of persons
with disabilities.
(ii) To protect individuals with disabilities from rights
violations by others.
(iii) To fulfil these rights by taking appropriate
legislative, administrative, and policy measures.
14.2.2 Article 9 of the UNCRPD deals with Accessibility and
reads as follows:
“(1) To enable persons with disabilities to
live independently and participate fully in
all aspects of life, States Parties shall take
appropriate measures to ensure to persons
with disabilities access, on an equal basis
with others, to the physical environment,
to transportation, to information and
communications, including information and
communications technologies and systems,
and to other facilities and services open or
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provided to the public, both in urban and in
rural areas. These measures, which shall
include the identification and elimination of
obstacles and barriers to accessibility, shall
apply to, inter alia:
a) Buildings, roads, transportation and
other indoor and outdoor facilities, including
schools, housing, medical facilities and
workplaces;
b) Information, communications and other
services, including electronic services and
emergency services.
(2) States Parties shall also take appropriate
measures to:
a) develop, promulgate and monitor the
implementation of minimum standards and
guidelines for the accessibility of facilities
and services open or provided to the
public;
b) ensure that private entities that offer
facilities and services which are open or
provided to the public take into account all
aspects of accessibility for persons with
disabilities;
c) provide training for stakeholders on
accessibility issues facing persons with
disabilities;
d) provide in buildings and other facilities
open to the public signage in Braille and in
easy-to-read and understand forms;
e) provide forms of live assistance
and intermediaries, including guides,
readers and professional sign language
interpreters, to facilitate accessibility to
buildings and other facilities open to the
public;
[2025] 4 S.C.R. 2889
Pragya Prasun & Ors. v. Union of India & Ors.
f) promote other appropriate forms of
assistance and support to persons with
disabilities to ensure their access to
information;
g) promote access for persons with disabilities
to new information and communications
technologies and systems, including the
Internet;
h) promote the design, development,
production and distribution of accessible
information and communications
technologies and systems at an early stage,
so that these technologies and systems
become accessible at minimum cost.
14.3 Incheon Strategy
India adopted the Incheon Strategy in 2012. It offers the
first set of regionally agreed inclusive development goals
aimed at making the rights of persons with disabilities a
reality in the Asia – Pacific region. Notably, ICT (Information
and Communication Technology) accessibility is specifically
referenced in Goal 3 of the strategy. This goal emphasizes the
need to enhance access to the physical environment, public
transportation, knowledge, information, and communication
systems for persons with disabilities.
14.4 RPwD Act, 2016 and RPwD Rules, 2017
14.4.1 The Government of India had enacted The Rights of
Persons with Disabilities Act, 2016 to give effect to the
United Nations Convention on the Rights of Persons
with Disabilities and for matters connected therewith
or incidental thereto.
14.4.2 The RPwD Act, 2016 marks a paradigm shift from
the earlier medical and technical model of disability
under the 1995 Act, which carried a significant burden
of stigma. The new model recognizes disability as a
condition arising not only from impairments but also
from physical, mental, intellectual, social, psycho-
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social, and other barriers that hinder full and effective
participation in society. These barriers lie at the heart of
the exclusion experienced by persons with disabilities,
preventing them from realizing their full potential and
participating as full and equal members and citizens –
a vision enshrined by the framers of our Constitution.
14.4.3 Section 2(c) of the RPwD Act, 2016 defines “barrier”,
as follows:
“barrier” means any factor including
communicational, cultural, economic,
environmental, institutional, political, social,
attitudinal or structural factors which hampers
the full and effective participation of persons
with disabilities in society”.
14.4.4 As a significant development, the RPwD Act,
2016 incorporates the principle of ‘reasonable
accommodation’ which is defined in section 2(y) as
follows:
“Reasonable accommodation” means
necessary and appropriate modification
and adjustments, without imposing a
disproportionate or undue burden in a
particular case, to ensure to persons with
disabilities the enjoyment or exercise of
rights equally with others.”
14.4.5 Section 3 of the RPwD Act, 2016 deals with equality
and non-discrimination and reads as follows:
“(1) The appropriate Government shall
ensure that the persons with disabilities
enjoy the right to equality, life with dignity
and respect for his or her integrity equally
with others.
(2) The appropriate Government shall take
steps to utilise the capacity of persons
with disabilities by providing appropriate
environment.
[2025] 4 S.C.R. 2891
Pragya Prasun & Ors. v. Union of India & Ors.
(3) No person with disability shall be
discriminated on the ground of disability,
unless it is shown that the impugned act
or omission is a proportionate means of
achieving a legitimate aim.
(4) No person shall be deprived of his or
her personal liberty only on the ground of
disability.
(5) The appropriate Government shall take
necessary steps to ensure reasonable
accommodation for persons with disabilities.”
14.4.6 Section 13(1) mandates the ‘appropriate government’
to ensure that the persons with disabilities have right,
equally with others, to own or inherit property, movable
or immovable, control their financial affairs and have
access to bank loans, mortgages, and other forms of
financial credit.
14.4.7 That apart, Section 21(1) of the RPwD Act, 2016
states that every establishment shall notify equal
opportunity policy detailing measures proposed to
be taken by it in pursuance of the provisions of this
Chapter in the manner as may be prescribed by the
Central Government.
14.4.8 Section 40 deals with ‘Accessibility’ and the same
reads as under:
“The Central Government shall, in
consultation with the Chief Commissioner,
formulate rules for persons with disabilities
laying down the standards of accessibility
for the physical environment, transportation,
information and communications, including
appropriate technologies and systems, and
other facilities and services provided to the
public in urban and rural areas.”
14.4.9 Section 42 of the RPwD Act, 2016, deals with ‘Access
to information and communication technology’. This
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section requires the appropriate Government to take
measures to ensure that- (i) all contents available in
audio, print and electronic media are in accessible
format; (ii) persons with disabilities have access to
electronic media by providing audio description, sign
language interpretation and close captioning; (iii)
electronic goods and equipment which are meant for
everyday use are available in universal design.
14.4.10 Section 46 provides ‘time limit for accessibility by
service provides’. According to this provision, the
service providers whether Government or private
shall provide services in accordance with the rules on
accessibility formulated by the Central Government
under section 40 within a period of two years from
the date of notification of such rules: Provided that
the Central Government in consultation with the
Chief Commissioner may grant extension of time for
providing certain category of services in accordance
with the said rules.
14.4.11 Rule 8 of the RPwD Rules, 2017 deals with the
manner of publication of equal opportunity policy
and the same reads as under:
“(1) Every establishment shall publish
equal opportunity policy for persons with
disabilities.
(2) The establishment shall display the
equal opportunity policy preferably on their
website, failing which, at conspicuous places
in their premises.
(3) The equal opportunity policy of a
private establishment having twenty or
more employees and the Government
establishments shall inter alia, contain the
following, namely:-
(a) facility and amenity to be provided to
the persons with disabilities to enable them
[2025] 4 S.C.R. 2893
Pragya Prasun & Ors. v. Union of India & Ors.
to effectively discharge their duties in the
establishment;
(b) list of posts identified suitable for persons
with disabilities in the establishment;
(c) the manner of selection of persons
with disabilities for various posts, post-
recruitment and pre-promotion training,
preference in transfer and posting, special
leave, preference in allotment of residential
accommodation if any, and other facilities;
(d) provisions for assistive devices, barrier-
free accessibility and other provisions for
persons with disabilities;
(e) appointment of liaison officer by the
establishment to look after the recruitment
of persons with disabilities and provisions of
facilities and amenities for such employees.
(4) The equal opportunity policy of the
private establishment having less than
twenty employees shall contain facilities
and amenities to be provided to the
persons with disabilities to enable them
to effectively discharge their duties in the
establishment.”
14.4.12 Rule 15 of the RPwD Rules, 2017, lays down ‘rules
for accessibility’ and the same states as follows:
“(1) Every establishment shall comply with
the following standards relating to physical
environment, transport and information and
communication technology. namely:
(a) standard for public buildings as specified
in the Harmonised Guidelines and Space
Standards for Barrier Free Built Environment
for Persons With Disabilities and Elderly
Persons as issued by the Government of
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Supreme Court Reports
India, Ministry of Urban Development in
March, 2016;
(b) standard for Bus Body Code for
transportation system as specified in the
notification of the Government of India in the
Ministry of Road Transport and Highways,
vide number G.S.R. 895(E), dated the 20th
September, 2016;
(c) Information and Communication
Technology-
(i) website standard as specified in the
guidelines for Indian Government websites,
as adopted by Department of Administrative
Reforms and Public Grievances, Government
of India;
(ii) documents to be placed on websites
shall be in Electronic Publication (ePUB)
or Optical Character Reader (OCR) based
pdf format:
Provided that the standard of accessibility in
respect of other services and facilities shall
be specified by the Central Government
within a period of six months from the date
of notification of these rules.
(2) The respective Ministries and Departments
shall ensure compliance of the standards
of accessibility specified under this rule
through the concerned domain regulators
or otherwise.”
POLICIES AND GUIDELINES
14.5 National Policy on Universal Electronic Accessibility,
2013
14.5.1 Recognising that access to technologies and the
Internet is fundamental for ensuring democratic,
[2025] 4 S.C.R. 2895
Pragya Prasun & Ors. v. Union of India & Ors.
effective, efficient and equitable participation in an
information society, the Government of India released
the National Policy on Universal Electronic Accessibility
in 2013 to eliminate discrimination on the basis of
disabilities as well as to facilitate equal access to
electronics and Information and Communication
Technologies (ICTs). It proposes universal access to
electronic and ICT products and services and sets out
implementation guidelines for the policy.
14.5.2 The Web Content Accessibility Guidelines (WCAG) are a
set of internationally recognized standards developed by
the World Wide Web Consortium (W3C) to ensure that
web content is accessible to all users, including persons
with disabilities. These guidelines provide technical
and design recommendations to make websites,
applications, and digital content more inclusive. India has
recognized the importance of web accessibility and has
taken legal and policy measures to ensure compliance
with the Web Content Accessibility Guidelines (WCAG).
The Indian government has adopted WCAG principles
to promote digital inclusion, especially for persons with
disabilities, in line with both national and international
commitments. The GIGW, issued by the Ministry of
Electronics and Information Technology (MeitY), aligns
with WCAG 2.0 Level AA standards.
14.5.3 Guidelines of Indian Government Websites (GIGW)
National Informatics Centre (NIC) has released three
versions of Guidelines of Indian Websites – the first
version was released in 2009, the second version
in 2019, and the latest third version was released in
March 2023. These guidelines serve as a single point
of reference for all three aspects of digital systems
of the internet i.e., quality, accessibility and security:
GIGW 1.0 – The 2009 version, based on the Web
Content Accessibility Guidelines (WCAG) 1.0, provided
detailed information on various accessibility features
such as text alternatives for images, resizable text,
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and colour contrast. The guidelines also mandated
that all government websites should be compatible
with assistive technologies such as screen readers
and provided guidelines for testing the accessibility
of government websites.
GIGW 2.0 – A significant improvement over the previous
version, the 2019 version was based on WCAG 2.0
and covered a wider range of disabilities including
visual, auditory, physical, and cognitive impairments.
The guidelines included detailed information on various
accessibility features such as keyboard accessibility,
colour contrast, and text resizing. It mandated that
all new government websites should comply with the
WCAG 2.0 Level AA accessibility standards.
GIGW 3.0 – Released in March 2023, this is the
most advanced version of GIGW formulated jointly
with Standardisation Testing and Quality Certification
(STQC), Directorate of the Ministry of Electronics
and Information Technology and Indian Computer
Emergency Response Team (CERT-In). It is aimed at
improving the user interface and user experience of
government websites. These guidelines are especially
designed to incorporate features like intuitive page
loading (using AI and analytics) based on user profile.
It takes special cognisance of mobile revolution
and seeks to enhance accessibility and usability of
mobile apps developed by government agencies.
The guidelines have been designed keeping in mind
the public digital infrastructure initiatives that will
enhance government’s delivery of services, benefits
and information. It also includes critical aspects such
as API level integration with social media, India Portal,
DigiLocker, Aadhaar-based identity, single sign-on and
data sharing on open formats.
14.6 CASE LAWS
This court has delivered several judgments affirming and
strengthening the rights of Persons with disabilities particularly
[2025] 4 S.C.R. 2897
Pragya Prasun & Ors. v. Union of India & Ors.
emphasizing the importance of accessibility. Some of the
notable decisions are as follows:
14.6.1 In Rajive Raturi v. Union of India & Others13, this
Court held that accessibility is a fundamental right
integral to the rights to life, dignity, and freedom of
movement under Article 21 of the Constitution. It further
criticized the non-mandatory nature of Rule 15 of the
RPwD Rules, 2017, deeming it ultra vires the parent
Act. It ultimately, directed the Union Government to
establish enforceable accessibility standards across
public infrastructure, digital platforms, and services,
reinforcing the state’s obligation to ensure inclusivity.
The relevant paragraphs are extracted below:
‘12. Accessibility refers to the design of
products, services, environments, and
systems to ensure that all individuals,
including those with disabilities, can access,
use, and benefit from them fully and
independently. This encompasses physical
access, such as entry to buildings and
transport, as well as access to information,
communication, and digital platforms.
It is essential for promoting inclusion and
enabling participation in all aspects of
public life.
13. The World Report on Disability published
by the World Health Organization and World
Bank stresses that inaccessibility within the
built environment, transport systems, and
communication channels severely limits the
opportunities for PWDs to live fully in society.
This inaccessibility leads to exclusion from
education, employment, healthcare, and
public services, effectively reinforcing the
13 2024 INSC 858
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social and economic marginalisation of
PWDs. Moreover, the lack of accessibility
exacerbates inequalities, as it limits the
ability of PWDs to engage in community life,
and often results in dependence on others,
restricting their autonomy and opportunities
for self-determination. This, in turn, results
in broader societal costs, as PWDs are
often prevented from contributing to the
workforce and society, thus perpetuating
a cycle of poverty and isolation. 5 World
Health Organization and World Bank, World
Report on Disability (2011). See Summary,
pp. 10. The report provides the best available
evidence about what works to overcome
barriers to health care, rehabilitation,
education, employment, and support
services, and to create the environments
which will enable people with disabilities
to flourish.
………
15. Accessibility is woven throughout the
United Nations Convention on the Rights
of Persons with Disabilities as a cross-
cutting right, reinforcing its critical role in
achieving social inclusion. It is highlighted
in paragraph (e) of the Preamble, which
calls for an environment that supports
full personal development and societal
participation. Article 3 sets out accessibility
as a general principle, which highlights the
necessity of removing both tangible and
intangible barriers to ensure that PWDs can
fully exercise their rights. These barriers
can be physical, such as inaccessible
buildings and transportation systems,
or intangible, such as discriminatory
[2025] 4 S.C.R. 2899
Pragya Prasun & Ors. v. Union of India & Ors.
attitudes or inaccessible digital
content.…
16. …Article 9(1) mandates that States
take proactive steps to ensure persons
with disabilities have equal access to
public spaces, transportation, information,
communication systems, and services. This
directive encompasses the development,
implementation, and monitoring of standards
and guidelines that promote access. Article
9(2)(a) elaborates on these obligations by
detailing the areas that require targeted
action, such as ensuring that the design and
construction of buildings and public facilities
adhere to universal design principles. This
commitment extends to digital spaces
and information technologies.
.......
Accessibility as a Human Right
19. The right to accessibility is not a
new or separate human right, but rather
an integral part of existing human rights
frameworks. Accessibility is embedded within
several international human rights treaties,
reinforcing its foundational role in ensuring
equality and dignity for all individuals,
including those with disabilities. For example,
access to the physical environment and
public transportation is essential for the
realisation of freedom of movement, which is
guaranteed under Article 13 of the Universal
Declaration of Human Rights and Article 12
of the International Covenant on Civil and
Political Rights…
Similarly, access to information and
communication is crucial for exercising the
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right to freedom of opinion and expression,
as articulated in Article 19 of the UDHR.
These rights are foundational for enabling
PWDs to live independently, participate in
society, and enjoy their rights on an equal
basis with others.”
14.6.2 In Re: Recruitment of visually impaired in Judicial
Services14, this Bench, after an extensive analysis
of the issue concerning the recruitment of visually
impaired persons as judges in the district judiciary, held
that the RPwD Act, 2016, possesses the sanctity of a
super-statute, and consequently, any denial of rights
guaranteed under this legislation amounts to a violation
of fundamental rights enshrined in the constitution. The
relevant paragraphs are extracted below:
“35... the United Nations Convention on
the Rights of Persons with Disabilities
was adopted in 2006 to which India is a
signatory. Pursuant thereto, the RPwD Act,
2016 came to be passed. While it is true
that the RPwD Act, 2016 came to be passed
as part of fulfilment of India’s obligations
under the treaty implementation regime
and was enacted by the Parliament under
Article 253 of the Constitution, the fact that
‘disability’ as a ground is not specifically
stated under Article 15 of the Constitution,
would not mean that the same is not part of
the constitutional obligations of the State.
The provisions under section 32 and section
34 of the RPwD Act, 2016 would also be a
clear indication that similar to the State’s
obligations to provide for special protection
including in the form of reservation for
socially and educationally backward
14 2025 SCC OnLine SC 481
[2025] 4 S.C.R. 2901
Pragya Prasun & Ors. v. Union of India & Ors.
classes in educational institutions as well
as in employment as stated in Articles
15 and 16 of the Constitution, the State
has taken up the obligation of providing
similar protection including reservation in
respect of PwD. In view of the same, it
can now be said that it is high time that
an anti-discrimination clause be included
in the Constitution with a specific provision
that the State shall not discriminate on the
grounds of mental or physical disability
in line with the principles as stated in the
RPwD Act, 2016. At this juncture, it is
relevant to point out that as many as 70
countries out of 189 contain ‘disability’ as
one of the grounds mentioned specifically
in the constitutional provisions containing
the anti-discrimination clause.
36. In this context, it is also relevant to
mention that the RPwD Act, 2016 today
has acquired the status of a ‘super statute’.
The term ‘super statute’ was first applied in
2001 by William N. Eskridge and John A.
Ferejohn to characterise an ordinary statute
that not only reveals intention but also
establishes a new normative or institutional
framework in the public culture and has
a broad effect on the law. As a result,
such statutes have a quasi-constitutional
significance that exceed its former status
as a statute. In the words of the authors,
“these super-statutes penetrate the public
normative and institutional and institutional
culture”. Applying this test, it can safely be
said that the RPwD Act, 2016 has acquired
the status equal to that of a ‘super-statute’
and hence, contains the ingredients of a
quasi-constitutional law.”
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14.6.3 In Re: Distribution of Essential Supplies and Services
During Pandemic 15, in the context of COVID-19
universal vaccination drive, this Court recognized
the critical importance of digital accessibility for
persons with disabilities. This court emphasized that
digital platforms related to vaccination and other
essential services must be designed in a manner
that is accessible to all, ensuring that no individual is
excluded due to disability. The relevant paragraphs
are extracted below:
“40. It has been brought to our notice that
the CoWIN platform is not accessible to
persons with visual disabilities. The website
suffers from certain accessibility barriers
which should be addressed. These include:
(i) Audio or text captcha is not available;
(ii) The seven filters, which inter alia, include
age group, name of vaccine and whether
the vaccine is paid or free, are not designed
accessibly. This issue can be addressed by
creation of a drop-down list;
(iii) While visually challenged persons
can determine the number of available
vaccine slots, one cannot find out the day
those slots correspond to. This can be
resolved by ensuring that table headers
correspond to associated cells;
(iv) Keyboard support for navigating the
website is absent;
(v) Adequate time should be given to
disabled users to schedule their appointment
without the possibility of being automatically
logged off; and
15 Suo Motu Writ Petition (Civil) No.3 of 2021, dated 31.05.2021
[2025] 4 S.C.R. 2903
Pragya Prasun & Ors. v. Union of India & Ors.
(vi) Accessibility protocols, such as use
of appropriate colour contrasts, should be
adhered to.”
14.6.4 This Court in Disabled Rights Group & Another v. Union
of India & Ors.16, emphasized the need for inclusive
education and the removal of barriers that hinder
access and participation. The relevant paragraphs
are extracted below:
“14)…Section 40 mandates the Central
Government to frame Rules and laying
down the standards of accessibility for
physical environment, transportation system,
information & communication system and
other facilities & services to be provided to
the public in urban and rural areas. Rule 15
deals with accessibility standards for public
buildings, passenger bus transport and
information and communication technology.
As regards public buildings, the accessibility
standards prescribed under the Harmonised
Guidelines and Space Standards for barrier-
free built environment for persons with
disabilities and elderly persons issued by
Ministry of Urban Development have been
adopted. This implies that all the public
buildings are now required to conform to
these standards.
15) It hardly needs to be emphasised
that Disabilities Act is premised on the
fundamental idea that society creates the
barriers and oppressive structures which
impede the capacities of person with
disabilities. Capability theorists like Martha
Nussbaum are of the opinion that there
16 (2018) 2 SCC 397
2904 [2025] 4 S.C.R.
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cannot be a different set of capacities
or a different threshold of capabilities for
persons with disabilities. This raises the
critical issue of creating a level playing field
whereby all citizens to have equality of fair
opportunities to enable them to realise their
full potential and experience well-being. To
ensure the level playing field, it is not only
essential to give necessary education to the
persons suffering from the disability, it is
also imperative to see that such education
is imparted to them in a fruitful manner.
That can be achieved only if there is proper
accessibility to the buildings where the
educational institution is housed as well
as to other facilities in the said building,
namely, class rooms, library, bath rooms
etc. Without that physically handicapped
persons would not be able to avail and utilise
the educational opportunity in full measure.
16) Various theories on different models
of disability have emerged, namely, the
Social Model of Disability, the Medical
Model of Disability, the Rights Base Model
of Disability, the Model of Ethical and
Philosophical Status, the Economic Model
of Disability etc. It is not necessary to delve
into these different models of disabilities.
However, for the purpose of the present case,
some comments are required on the Social
Model of Disability. The Social Model of
Disability locates disability as being socially
constructed through the creation of artificial
attitudinal, organisational and environmental
barriers. Impairment is regarded as being
a normal part of the human condition,
with everyone experiencing impairment
differently and having different access
[2025] 4 S.C.R. 2905
Pragya Prasun & Ors. v. Union of India & Ors.
needs. Life is accepted as including negative
experiences, and impairment may be – but
is not necessarily – on of them. Disabled
people are defined as being people who
experience the unnecessary barriers created
by society within their daily life. Social
Model of disability has gained ground in the
international debate. This views disability
as a social construct and emphasizes
society’s shortcomings, stigmatization and
discrimination in its reaction to persons
with disability. It distinguishes between
functional impairments (disability) both
of a physical and psychological nature,
and the loss of equal participation in
social processes that only arises through
interaction with the social setting (handicap).
These developments have contributed to
a new (WHO) model, which bears in mind
social as well as functional and individual
factors in its classification of health and
health-related areas. Keeping in view the
above, proper facilities are need to be
provided to differently-abled persons while
having higher education.
17) Insofar as the rights base approach is
concerned, that has been narrated in detail
in Rajive Raturi’s judgment. We may add that
a basic underline assumption, which is well
recognised, is that everyone can learn; there
is no such person as one who is ineducable;
and that, accordingly, all disabled persons
(from whatever disability they are suffering)
have right to get not only minimum education
but higher education as well. Not making
adequate provisions to facilitate proper
education to such persons, therefore, would
amount to discrimination. Such requirement
2906 [2025] 4 S.C.R.
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is to ensure that even a student with disability,
after proper education, will be able to lead
an independent, economically self-sufficient,
productive and fully participatory life. This
rights-based approach is an inclusive
approach which calls for the participation
of all groups of the population, including
disadvantaged persons, in the development
process. Inclusive development builds
on the idea of ‘Society for All’ in which
all people are equally free to develop
their potential, contribute their skills and
abilities for the common good and to take
up their entitlements to social services.
It emphasises strengthening the rights of
the people with disabilities, and foster their
participation in all aspects of life. A disability
is only actually a disability when it prevents
someone from doing what they want or need
to do. A lawyer can be just as effective in a
wheelchair, as long as she has access to
the courtroom and the legal library, as well
as to whatever other places and material
or equipment that are necessary for her to
do her job well. A person who can’t hear
can be a master carpenter or the head of
a chemistry lab, if he can communicate
with clients and assistants. A person with
mental illness can nonetheless be a brilliant
scholar or theorist. The aforesaid discussion
amply justifies right of access to students
with disabilities to educational institutions in
which they are admitted.”
Further, in the above case, Justice A.K. Sikri, speaking for the bench,
issued comprehensive directions to the Government to ensure
accessibility across all levels of educational infrastructure. This
included not only physical spaces – such as classrooms, libraries,
hostels, and laboratories – but also the pedagogy itself. This court
[2025] 4 S.C.R. 2907
Pragya Prasun & Ors. v. Union of India & Ors.
emphasized that teaching methods and learning materials must be
adapted to be fully accessible to all persons with disabilities, including
those who are visually impaired and those with hearing impairments.
This aligns with the broader mandate of the RPwD Act, 2016, to
foster an inclusive and barrier free education system.
FINDINGS AND CONCLUSION
15. The overall analysis would clearly establish that KYC formalities
are needed to verify a customer’s identity, prevent fraud and money
laundering, and comply with legal regulations. Consequently, several
sectors have currently shifted their KYC formalities to digital means.
Though digital KYC has benefitted the general public by making
verification processes faster and more efficient, persons with blindness
and low vision continue to face significant barriers in accessing and
completing these procedures. Many such digital platforms are not
compatible with screen readers, and crucial information is often
presented in visual formats without alternative text. CAPTCHA
tests, unlabeled form fields, and biometric verification methods
such as facial recognition further exclude individuals with visual
impairments. Moreover, those platforms often require fine motor
control (e.g., precise selfie or signature capture) which is not feasible
for individuals with mobility impairments. Additionally, interfaces are
frequently overly complex and lack cognitive accessibility, thereby
posing significant challenges for users with intellectual or learning
disabilities. For instance, videos without captions prevent users from
accessing information. Given the troubling state of government-
run websites, it is easy to conjecture that the situation with private
service providers is even worse. Such barriers significantly hinder
the ability of persons with disabilities to work, learn, and engage
with society, thereby violating their right to equal opportunity and full
participation as guaranteed under the UNCRPD and national disability
laws. These barriers collectively amount to a denial of equal access
and violate the accessibility mandates under the RPwD Act, 2016
and results in economic and social marginalization. To combat this
discrimination, governments and private entities must ensure that
digital services comply with Web Content Accessibility Guidelines
(WCAG) and other accessibility standards. Further, legal frameworks
should impose stringent requirements for digital inclusion, ensuring
2908 [2025] 4 S.C.R.
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that no individual is denied access to essential services on the basis
of disability. Thus, it is clear that as per international standards and
the RPwD Act, 2016, digital services are expected to be inclusive
and accessible to all users, regardless of ability.
16. Admittedly, the petitioners herein who suffer from facial and eye
disfigurements due to acid attacks and from visual impairment,
are recognized as persons with disabilities as per the schedule
appended to the RPwD Act, 2016. They have also highlighted their
inability to complete KYC processes, which require them to perform
visual tasks such as blinking, moving the head, or positioning their
face within specified frames — tasks, which they are unable to
accomplish due to their visual impairments and facial disfigurements.
As a result, they encounter delays or are entirely unable to establish
their identity, open bank accounts, or access essential services
and government schemes. As indicated earlier, the constitutional
and legal provisions mentioned above confer upon the aggrieved
petitioners a statutory right to demand accessibility and appropriate
reasonable accommodations in the digital KYC process. Moreover,
the respondents have, fairly, expressed their commitment to ensuring
that accessibility guidelines and standards are duly met. Therefore,
it is imperative that the digital KYC guidelines are revised with
accessibility at the core.
17. At this juncture, we may also wish to observe that in the contemporary
era, where access to essential services, governance, education,
healthcare, and economic opportunities is increasingly mediated
through digital platforms, the right to life under Article 21 of the
Constitution must be reinterpreted in light of these technological
realities. The digital divide – characterized by unequal access to
digital infrastructure, skills, and content – continues to perpetuate
systemic exclusion, not only of persons with disabilities, but also
of large sections of rural populations, senior citizens, economically
weaker communities, and linguistic minorities. The principle of
substantive equality demands that digital transformation be both
inclusive and equitable. As already pointed out, persons with
disabilities encounter unique barriers in accessing online services
due to the lack of accessible websites, applications and assistive
technologies. Similarly, individuals in remote or rural areas often face
poor connectivity, limited digital literacy, and a scarcity of content in
[2025] 4 S.C.R. 2909
Pragya Prasun & Ors. v. Union of India & Ors.
regional languages, effectively denying them meaningful access to
e-governance and welfare delivery systems. In such circumstances,
the State’s obligations under Article 21– read in conjunction with
Articles 14,15 and 38 of the Constitution – must encompass the
responsibility to ensure that digital infrastructure, government
portals, online learning platforms, and financial technologies are
universally accessible, inclusive and responsive to the needs of all
vulnerable and marginalized populations. Bridging the digital divide
is no longer merely a matter of policy discretion but has become
a constitutional imperative to secure a life of dignity, autonomy
and equal participation in public life. The right to digital access,
therefore, emerges as an intrinsic component of the right to life and
liberty, necessitating that the State proactively design and implement
inclusive digital ecosystems that serve not only the privileged but
also the marginalized, those who have been historically excluded.
DIRECTIVES
18. Thus, in order to make the process of digital KYC accessible to
persons with disabilities, especially facial / eye disfigurements due to
acid attacks and visual impairments, we issue the following directions:
(i) The respondent authorities/Ministries shall direct all REs,
whether government or private to follow accessibility standards
as prescribed from time to time. The respondents shall appoint
a nodal officer in every department responsible for digital
accessibility compliance.
(ii) All regulated entities must mandatorily undergo periodical
accessibility audit by certified accessibility professionals and
involve persons with blindness in user acceptance testing
phase while designing any app or website or in case of any
new feature being launched.
(iii) Respondent No. 2/ RBI shall issue guidelines to all regulated
entities to adopt and incorporate alternative modes for verifying
the “liveness” or capturing a “live photograph” of the customers,
as mandated under Annex-I of the MD on KYC, 2016, for
the purpose of conducting Digital KYC / e-KYC beyond the
traditional “blinking of eyes” to ensure inclusivity and user-
convenience.
2910 [2025] 4 S.C.R.
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(iv) Respondent No. 2 / RBI shall issue appropriate clarifications /
guidelines / directions to all regulated entities that they have
Customer Due Diligence (CDD) and on-boarding of new
customers can be done using the video-based KYC process
or the “V-CIP” procedure, in accordance with the provisions
of the MD on KYC, 2016, wherein blinking of the eyes is not
a mandatory requirement.
(v) The respondent authorities must design their KYC templates
or customer acquisition forms to capture disability type and
percentage of the customer and appropriately record as part of
the account records so as to provide them accessible services
or reasonable accommodations.
(vi) The respondent authorities should provide clear directions
to all regulated entities to accept image of thumb impression
during Digital KYC process.
(vii) Respondent No. 2 / RBI shall amend the MD on KYC so as
to enhance the implementation of the ‘OTP based e-KYC
authentication’ (face-to-face) to customers.
(viii) Respondent No.3 shall make the necessary amendments and/
or modifications to its notification dated 05.12.2023 thereby
ensuring that the paper-based KYC process for verification of
customers shall continue, enabling the petitioners and other
similarly placed individuals to avail an accessible alternative
for completing the KYC procedure.
(ix) The respondent authorities shall provide options for sign
language interpretation, closed captions, and audio descriptions
for visually and hearing-impaired users.
(x) The respondent authorities shall develop alternative formats
including Braille, easy-to-read formats, voice-enabled services,
to disseminate government notifications and deliver public
services, ensuring accessibility for all.
(xi) All regulated entities should procure or design devices or
websites / applications / software in compliance of accessibility
standards for ICT Products and Services as notified by Bureau
of Indian Standards.
[2025] 4 S.C.R. 2911
Pragya Prasun & Ors. v. Union of India & Ors.
(xii) The respondent authorities shall ensure that online services
including e-governance platforms, digital payment systems,
and e-launching platforms, are accessible to persons with
disabilities, thereby fostering a barrier-free digital environment.
(xiii) The respondent authorities are directed to ensure that all
websites, mobile applications and digital platforms comply with
the Web Content Accessibility Guidelines (WCAG) 2.1 and
other relevant national standards, such as the Guidelines for
Indian Government Websites (GIGW). It shall be mandatory
for all Government websites to adhere to Section 46 of the
RPwD Act, 2016, which requires both electronic and print
media to be accessible to persons with disabilities.
(xiv) The respondent authorities shall issue appropriate guidelines
to develop and implement a mechanism where customers who
have already completed their KYC process with one regulated
entity may authorize the sharing of their KYC information with
other entities through the Central KYC Registry (CKYCR).
(xv) The respondent authorities shall establish a dedicated
grievance redressal mechanism for persons with disabilities
to report accessibility issues.
(xvi) The respondent authorities shall establish a mechanism for
human review of rejected KYC applications in cases where
accessibility-related challenges prevent successful verification.
A designated human officer shall be empowered to override
automated rejections and approve applications on a case-
by-case basis.
(xvii) The respondent authorities shall establish dedicated helplines
for persons with disabilities, offering step-by-step assistance in
completing the KYC process through voice or video support.
(xviii) Respondent No. 2 / RBI shall routinely initiate public campaigns
through press release/ advertisement in electronic/ print
and social media portals and to raise awareness, increase
sensitization, and ensure effective dissemination of information
about alternative methods of conducting Digital KYC / e-KYC
and circulate standardized materials and mandate all regulated
entities to display notices containing such information.
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(xix) The respondent authorities should mandate inclusion of
disability awareness and training modules as part of e-learning
modules for officials of regulated entities for better sensitization
of officials.
(xx) Respondent No. 2 / RBI shall monitor and ensure strict
adherence by all regulated entities to the guidelines /
notifications / directions issued by it, including those in terms
of directions issued by this Court in the instant Writ Petition.
19. With the aforesaid directions, both the writ petitions stand disposed
of. No costs.
20. Connected Miscellaneous application(s), if any, shall stand disposed
of.
Result of the case: Writ petition disposed of with directions.
†
Headnotes prepared by: Raghav Bhatia, Hony. Associate Editor
(Verified by: Liz Mathew, Sr. Adv.)
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