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ISSUES PRETAINING TO EMPLOYMENT OF PRESONS WITH DISABILITIES IN THE
GOVERNMENT, PUBLIC SECTOR AND GOVERNMENT AIDED ESTABLISHMENTS
The issues related to employment of persons with disabilities in
Govt. Public sector and govt. aided autonomous bodies have
several aspects. In order to understand these first of all, I
would like to deal with concept of identified posts for the
disabled.

2. Identified posts for the disabled

Every employer and employee are acutely concerned with two things,
1.Productivity, and
2.Satisfaction.

Every establishment would like to appoint a person whose skills and
abilities would amount to higher or better productivity, in other
words, efficiency. Similarly, employees if are able to contribute to
the efficiency and productivity feel satisfied in job in the core of
the concept of identification of jobs for the disabled, is the idea of
job satisfaction.
 2.1Criteria Of Identification of posts

The Committee appointed by the Govt. for identifying jobs for the
disabled looks into four areas related to any post:
Nature of job: Here the committee members take into account the
nature of a given post. For example; College students one or more
subjects relating to architecture. Deliver lectures and supervise
practical work in field laboratory. Organize and go on field
trips, maintain class registers and records. Set examination
papers, conduct examinations and mark papers. May conduct or
guide research work.
Working conditions: The committee also takes into account the
conditions in which duties of a given post are performed. Again I
would illustrate this in context with the college teachers
(Architecture) work which is performed both inside and outside.
Work place in the fields is hot, humid and dusty. Field job is
hazardous.
Physical requirements: In order to perform a given job there are
certain essential physical functions required.
What are the essential physical functions required to perform the
job of college teacher of Architectures?
Standing, Hearing, walking, finger manipulation, seeing &
speaking are some physical functions critical to the efficiency
of the job of college teacher of Architecture, whether lecturer,
Assistant Professor. Since, the teacher of Architecture deals
with drawings of buildings and towns require manipulating with
fingers. The practical work involves visit to building sites,
therefore, walking in hot, dusty, humid weather is inevitable and
the teacher needs to listen to what students say and deliver
lectures. Therefore, listening and speaking are also essential
physical requirement for this post.
Category of the disabled suitable for the job: Keeping in view
the nature of job, working conditions and essential physical
requirement one determines the category of the disabled suitable
for a given post. For example, for the post of college teacher of
architecture, who would be suitable? Candidates who are partially
hearing impaired, who have disability in one leg or one arm, one
leg & one arm together, can perform the job of college teacher
(Architecture).

>From this example one would observe that the expert committee for job
identification goes into an in -depth analysis of each post for which
a very scientific approach is adopted.
2.2The Statutory Provisions on the issue of identification of jobs.

In Sec. 32 of persons with disabilities (Equal Opportunities,
Protection of Rights & Full participation Act 1995 it is stated that;

"Appropriate Governments shall -
identify posts in the establishments, which can be reserved for
the persons with disability
at periodical intervals not exceeding three years, review the
list of posts identified and up-date the list taking into
consideration the development in technology."

In relation to this section the appropriate govt. Ministry of social
Justice & Empowerment and Department of personnel and training. These
two ministries are obliged to identify jobs for the disabled and
notified the list of jobs for the disabled.
2.3Administrative Arrangements for identification of posts

In pursuance of Sec. 32, the ministry of Social justice and
Empowerment constituted an Expert Committee under the Chairmanship of
Sh. Biswas, Additional secretary in the ministry of Social justice and
Empowerment. The committee comprises of members from ministry of
labour, Department of Personnel, Ministry of Heath, Human Resources
Development, Finance, Industry, experts from field of rehabilitation,
Ngo's and disabled. In the meanwhile the list of jobs identified in
the year 1986 by the then Expert committee on identification of jobs
has been brought to force by department of personnel and training vide
office memorandum No. 36035/4/98-Estt (Res.), dated 28th August 1998
which reiterates;

"The existing identification done in the year 1986 shall remain valid,
tiff the same is modified by the Government on the recommendations of
the Expert Committee. The list of posts already identified as being
held by persons with disabilities, has already been circulated vide
this Departments OM. No. 36034/4/86 Estt (SCI) dated November 25,
1986."

In other words, section 32 is fully in force since the list of
identified jobs in Group 'A', `B`, `C`& `D` posts has been notified by
the Govt.
2.4Critical Question In Identification of Jobs

In context with the identifications of jobs for the disabled some
other important issues.
Whether establishments independently need to identify jobs or
they rely on the list of jobs notified by the appropriate Govt.?
The answer to this is, it is the appropriate Govt. which notifies
the list of identified jobs not the individual establishments,
therefore, the freedom of individual establishments is limited to
selection of jobs from the list of jobs notified by the
appropriate govt. for the purpose of effecting reservation.
It is observed that there are certain posts in public sector
undertakings and autonomous bodies which have functions identical
to those posts which are included in the list of identified jobs
but have a different nomenclature. Under such circumstances the
establishment in public sector ideally should earmark such posts
for the disabled which are otherwise by the same name does not
exist in the identified list of jobs, but whose functions are
similar to one which has been included in the list of jobs, under
different nomenclature. For example, the term probationary
officer has been substituted with executive trainees, therefore,
notwithstanding the name or title of the post the job will remain
identified if the functions of the job prescribed have not
undergone any change.
3. 3% Reservation in Jobs for the disabled
3.1 Administration And Statutory Provisions

Reservation in jobs to the extent of 3% for persons with disabilities
came into force in the year 1977, this was done by way of an executive
order issued by DOPT vide O.M. NO. 39016/6/77-Estt(SCT), dated
4.11.1977. Later reservation for persons with disabilities got legal
backing and section 33 of the PD Act stipulates;

"Every appropriate Government shall appoint in every establishment
such percentage of vacancies not less than three percent for persons
or class of persons with disability of which one percent each shall be
reserved for persons suffering from
blindness or low vision:
bearing impairment:
locomotor disability or cerebral policy, in the posts identified
for each disability provided that the appropriate government may,
having regard to the type of work carried on in any department or
establishment, by notification subject to such conditions, if
any, as may be specified in such notification, exempt any
establishment from the provisions of this section."

In pursuance of sec. 33 of the disabilities act 1995 Govt. extended
reservation to group `A` AND `B` posts too. DOPT vide OM No.
36035/16/91-Estt (SCT)dated 18.2.97 notified at para2;

"With the enactment of this law, the reservation to physically
handicapped stood extend to identified Group `A` & `B` posts filled
through Direct Recruitment"
3.2 Method for Effecting 3% Reservation For Disabled
It is clarified that, the reservation for the disabled is called
horizontal reservation and it is inter locked in vertical categories
in accordance with the principles of interlocking of Vertical and
Horizontal reservations laid down in the supreme Court Judgement in
Indira Sawhney Vs Union of India (W.P. No. 930 of 1990). The
reservation for SC/ST/OBCs, which is additive, is called vertical
reservation and the reservation for physically handicapped persons is
termed as Horizontal reservation. The Horizontal reservation cuts
across the vertical reservation (What is called inter-locking
reservation) and the person selected against the physically
handicapped quota will have to be placed in the appropriate category
i.e. if he belongs to SC category he will be placed in that quota by
making necessary adjustment and similarly, if he belongs to open
competition category he will be placed in that category. These
instructions are in force at Govt. of India level notified by
department of personnel and Training vide it's OM No. 36035/16/91-Estt
(SCT), dated 18.2.97.
4. 100 Point Roster for Effecting Reservation
4.1Method Of Maintaining 100 point post based roster for the disabled

For effecting 3% reservation all establishments are obliged to
maintain a 100 point roster. Since out of 100, 3 posts are reserved
for the disabled in all the grades which means A, B, C & D. Therefore,
a separate 100 point roster for each grade of service will be
maintained in which 3 points are earmarked for the disabled. Govt. of
India and several other state govts had ear-marked point no. 33, 66 &
100 in a 100 point roster for the disabled, but later this has been
changed point roster for the disabled, but later this has been changed
to point No. 1, 34 and 67 as the disabled were getting the first
opportunity to reservation after waiting for a very long time. In fact
several qualified disabled lost the benefit of reservation due to over
age as they had to wait for a considerably long period to avail their
chance - perhaps for this reason the change has been made in the
roster.
4.2 Principles of Operating Roster

Principles of operation roster in case of disabled are same as in the
case of SC/ST etc. These have been prescribed as per the criteria laid
down by the Hon'ble Supreme Court in the case of R.K. Sabharwal Vs
State of Punjab. The method for allocating a roster point for a given
category is as under the "the method for making a roster is to
multiply each post by the prescribed percentages of reservation for
the different reserved categories. The point at which the multiple for
a community obtains a complete number or oversteps the number is to be
reserved for that community-while taking care to evenly space out the
different reserved categories."

Therefore, the roster for the disabled on the principle of 3%
reservation in practical terms would mean 100 divided by 3 equal to
33.33 which means that in a 100 point roster three slabs of 33.33 each
will be created in which either the first or the last point of each
blick will be earmarked for the disabled. By this method the
interlocking of horizontal reservations meant for the disabled would
be achieved and question of overstepping the stipulated limit of 50%
reservation would never come in question. In concrete terms the three
slabs in 100 point roster would look like this:

1.... 33/34...... 66/67......100

An establishment can choose to reserve point No. 1.../34...../67....
Or point No. ....33/ ....66/ .... 100. This strictly is in accordance
with the criteria laid down in the case of R.K Sabarwal vs Govt. of
Punjab.
4.3Disabled To Mark Both Main Category And Sub Category In the Application Form

It is further clarified that selected disabled candidates are placed
under their respective vertical category such as General/Sc/ST/OBC
after the completion of the selection process. In other words, the
reserved posts for the disabled are not predetermined by their
vertical category rather placement in the vertical categories is
determined post selection. To avoid any ambiguity for this purpose of
DOPT vide it's OM No. 36035/16/98- Estt (Res.), dated 13th July 1999
at para 3 clarified

"It has now been decided that while inviting applications for filling
up of vacancies meant. For persons with disabilities, the following
information in the notice inviting applications should be invariably,
indicated:
Sub-Categories of disability for which the vacancies are
reserved:
The exact percentage of disability for being eligible for applies
for the vacancy proposed to be filled up.

Further, there should be a column in the application stating the
category to which the candidate applying under the quota reserved for
persons with disabilities belongs to viz. SC/ST/OBC/General"

5. PROMOTION

It is needless to mention that reservation for the disabled is
applicable even in the matters of promotion, since recruitment to
certain posts is made both by open competition & promotion. In order
to maintain element of reservation upto 3% at all levels a separate
100 point roster is required to be maintained for effecting
reservation in promotion on the lines of direct recruitment.

5.13 CRITICAL QUESTIONS REGARDING PROMOTION

There are three main issues pertaining to promotion to next grade for
disabled employees.
Whether there is reservation in promotion?

Yes, there is reservation in promotion upto 3% for disabled in Group
`D` to `D` and within `D` to `C` and within `C` to `C`. This provision
by way of an executive order came in force as far back as 1989. DOPT
in the OM No. 36035/8/89-Estt (SCT) dated 20.11.1989 at para ---

b)Whether there is reservation in promotion from Group `C` to Group
`B` and Group `B` to Group `A`?

There is at present some ambiguity regarding this issue but it is
abundantly clear that a disabled employee upon fulfilling the
eligibility for promotion to next grade cannot be denied promotion.
Sec. 47 (2) clearly stipulates that;
"No promotion shall be denied to a person merely on the ground of his
disability. Provided that the appropriate Government may, having
regard to the type of work carried on in any establishment, by
notification and subject to such conditions, if any, as may be
specified in such notification, exempt any establishment from the
provisions of his section for the purpose of according exemption same
inter departmental committee."

It must be made clear that the employee who is disabled has the right
to promotion to next grade, denying promotion on ground of disability
at one hand would perpetuate discrimination. In today`s context where
reservation in group `A` and `B` has got extended and jobs have been
identified, denying promotion appears illogical because mode of
recruitment cannot determine the merit for holding a post. So it is
logical that a disabled upon fulfilling the eligibility and upon
having the necessary qualification if can hold an identified post
through direct recruitment, promotion to the same post cannot be
denied on grounds of X or Y mode of appointments. The main issue is
that appointment

Of the disabled whether through direct recruitment or promotion has to
be on an identified post. Hence the disabled has same right to
promotion as the non-disabled employee.

C) If the post in the line of promotion is not the one identified for
the disabled?

 The statute lays down in section 47 that;

"no establishment shall dispense with, or reduce in rank an employee
who acquires a disability during his service. Provided that, if an
employee, after acquiring disability is not suitable for the post with
the same pay scale and service benefits; Provided further that if it
is not possible to adjust the employee against any post he may be kept
on a supernumerary post until a suitable post is available or he
attains the age of superannuating, whichever is earlier."

In conclusion one can say that provision of lateral posting is one
remedy provided in the Act. In protection of the right to career
enhancement for employees with disabilities in case where
establishment is exempted from the provisions of sec.47 the disabled
employer`s seniority and enhanced pay would be protected , ofcourse
creation of supernumerary post would be used as last option. These
arrangements can sufficiently ensure dignity of workers and as well as
efficiency of the organization.

6. SPECIAL PROVISIONS AT THE TIME OF RECRUITMENT STAGE
ADDITIONAL SAFEGUARD

There are a number of establishments in Govt. and Public Sector, which
commission specialist agencies to conduct recruitment on their behalf.
These recruitment agencies publish advertisement on behalf of the
identing departments. It is quite logical that the advertisement would
be issued as per the indent submitted by the requisitioning agencies.
So the oversight at the agency goes unchecked , therefore, the Govt.
felt necessary to provide an extra safeguard by entrusting recruitment
agencies with a pro-active role. Therefore, DOPT vide OM No.
36035/17/99- Estt (Res.), dated 16th August 99 notified on the subject
" Reporting of vacancies to the recruiting agencies while making
recruitment to the posts identified as suitable for being manned by
persons with disabilities. "

6.2 SCRIBE/ WRITER

At the time of recruitment and promotion sometimes candidates are
required to take written tests. So far as blind/ low vision and
persons having problems in hands are concerned they often require
assistance of a scribe. Sec. 31 of the PD Act stipulates;
"All educational institutions shall provide or cause to be provided
amanuensis to blind students and students with or few vision."

It would be most logical that the disabled candidates are given
similar assistance in writing tests in schools and colleges.
Examination and Test whether for passing a course or entrance to
professional institute or promotion or recruitment would remain a test
in the last instance. Therefore, all the blind, partially blind and
persons having disability in the hands would be permitted to use the
services of a scribe or writer who is one grade junior in academic
qualification, whose marks are not more than 50% and who is from a
different discipline than that of the disabled candidate. Such a
person can either be provided by the establishment conducting the exam
or the examining body can entrust the disabled candidate with the
responsibility of brining the scribe or writer on terms and conditions
mentioned earlier.

6.3 EXTRA TIME FOR WRITING TEST FOR RECRUITMENT AND PROMOTION

The candidates who rely on the assistance of scribe or writers need
extra time in completing the written test. Obviously they have to
first listen to the questions then at time of writing they speak and
the scribe listens and then writes. In the process the speed of
writing gets lowered in comparison to those who write by themselves,
therefore , for a one-hour paper at least 20 minutes extra are given
and at times 30 minutes are also given to disabled candidates.

6.4 MODIFICATION IN THE EXAMINATI0N SYSYTEM

As per the Section 30 (f) of the PD Act,

"Without prejudice to the foregoing provisions, (be appropriate
Governments shall by notification prepare a comprehensive education
scheme which shall make Provision for suitable modification in the
examination system to eliminate purely mathematical questions for the
benefit of blind students and students with low vision."

Since blind/low - vision candidates due to the nature of their
disability cannot negotiate purely visual section in the question
paper such as sections involving pictures, graphs, geometrical
drawings or filling up maps are some which persons having absence of
vision or impaired vision cannot comprehend. Therefore, either
alternative questions of equal value to pictorial and graphic
questions be provide or some criteria for awarding grace marks in
proportion to the performance of such candidate in other sections of
the paper can be worked out by the examining authority. This is a
practice followed by U.G.C for UGC-Net exam.

6.5 INTERPRETERS FOR HEARING IMPAIRED PERSON

Interview is an important part of any recruitment process. Persons
with hearing impairment and speech impairment, though having excellent
communication skills must use services of an interpreter during the
interview this would ensure smooth and better communication between
interviewers and the hearing impaired and speech impaired
interviewees. Presence of the interpreter would rule out possibility
of miscommunication. Interpreter should be ideally of the disabled
persons choice from the same city because in the sign language there
are as many dialects as in the spoken language. Interpreter from one
language zone cannot interpret for another linguistic zone. For utmost
efficiency it is better that the interpreter is of the candidates own
choice.

6.6 RELAXATION OF AGE-LIMIT

Age relaxation upto 10 years shall be granted to candidates with
disabilities as per DOPT O.M No 43019/28/86-Estt (D) . dated 1.2.99.
6.7 TRANSPORT ALLOWANCE

The transport allowance to disabled employees who are blind, low
vision and locomotor impaired in the lower extremities has been fixed
at double the normal rate ; since these categories of the disabled
encounter barrier in the built environment and transport system. The
current rate of transport allowance is as per DOPT.
6.8 POSTING OF PHYSICALLY HANDICAPPED CANDIDATES NEAR THEIR NATIVE PLACES

Holders of Group `C` and Group `D` posts who have been recruited on
regional basis and who are physically handicapped, may be given
posting , as far as possible , subject to administrative constraints,
near their native places within the region. Requests for transfer to
or near their native places may also be given preference.



-- 
Mukesh Jain
  email: [EMAIL PROTECTED]
  mobile: 09977165123
  "happiness and joy are the wealth of prosperous life"

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