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All India Disability Alliance   Plot No. 21, Sector-VI, M.B. Road,

Hon. Coordinator: Sr. Adv. Shri. S. K. Rungta  Pushp Vihar, New Delhi - 110017

Mob: 9312607540   Phone: 011-29562316, 29562318

Fax : 011-29564198

[email protected]

Dated:  24.2.14

To



Hon'ble Smt. Sonia Gandhi

Chair Person

UPA

New Delhi



Subject: -           Reconsideration of declaration made by Hon'ble
Rahul Gadhi to promulgate ordinance in respect of rights of persons
with disabilities Bill 2014 pending in Rajya Sabha and referred to
Standing Committee.



Madam,



The majority of persons with disabilities and their organizations were
shocked and anguished by the declaration made by Shri Rahul Gandhi
that an Ordinance will be promulgated to bring into force Rights of
Persons With Disabilities Bill 2014 which is pending consideration by
the Standing Committee after introduction in Rajya Sabha.  Various
vital issues having been raised against the provisions of the Bill by
all major disability organizations.  Such a declaration seems to be
result of misrepresentation of the position of disability
organizations and persons with disabilities by a small group under the
banner of DRG in the leadership of Mr. Javed Abidi who is now claiming
that due to his proximity with Your goodself, he has been able to
persuade for promulgation of an ordinance to give effect to the flawed
bill on the rights of persons with disabilities pending in Rajya
Sabha.    We are aware that you have always stood by the call of
persons with disabilities and have never been a party to the
curtailment of their rights and to support any legal provision or
policy which may perpetuate discrimination on the ground of
disability.



As an alliance of disability organizations we have also submitted to
the Govt. a memorandum detailing some vital issues which have the
effect of nullifying the existing rights in the existing legislation
as well as legitimizing discrimination which the disability community
cannot accept.  Some of these issues include :







Postponement of inclusion of definition of low vision
Non-inclusion of definition of languages to include sign language
which was earlier included in the draft of 2011 and which is very
essential for hearing impaired persons.


Section 3(3) Non discrimination:  the only amendment which has been
made is to retain the power with the Executive for discriminating
against the disabled but the ground has been changed on which such
discrimination is justified viz. if it imposes disproportionate
burden.  However this disproportionate burden has not been defined in
the Bill which will make things arbitrary and unguided.


Access to Justice : (Section 11) There is no provision for recognition
or even mention of requirement of sign language, interpretation or
recognition of sign language while exercising right to access to
justice which is very crucial for persons with hearing impairment.


Legal capacity (Section 12 & 13): The Bill by the recent amendment
only recognizes the right to be treated alike and equality before law
but at the same time negates this right to intellectually disabled and
mentally ill persons by allowing the application of other laws to the
provisions of this law also in terms of section 110.  This would imply
that acts such as Indian Contract Act, Indian Evidence Act or other
Acts having exclusionary or negative clauses about competence of
persons with disabilities would apply simultaneously nullifying the
provision of the proposed Bill.  Further, the Bill provides for an
appeal against the appointment of guardian but no appellate forum has
been prescribed making this provision redundant.
Non discrimination in employment:  (section 19(1) :  This section
prohibits discrimination against any person with disability in any
matter relating to employment but circumvents this non-discrimination
clause by proviso giving authority to the Govt. to exempt any
1establishment from this section in view of the type of work carried
on in that establishment.  This is a clear attempt to circumvent
fundamental right of equality of opportunity in the matter of
employment guaranteed UA 16(1) of the Constitution of India and
therefore cannot be allowed to remain.


Insurance Scheme (Section 25)  :  There is no provision with regard to
non-discrimination in the matter of insurance coverage premium and
policy benefits.


Identification of Post for reservation (Section 32) :  Linking
identification with reservation is contrary to the recent supreme
court judgment and therefore the formulation submitted by us should be
accepted.


Reservation (section 33)  : In this the formulation given by us should
be accepted.  Further U/S 33(2) the carry forward and interchange rule
should be made applicable strictly in accordance with the O.M. Dt.
29.12.2005.   Further, the proviso to sub section 2 of section 33
giving right to the appropriate Govt. to interchange the percentage of
reservation among five categories by diverting the reservation in
favour of one category to other keeping in view the nature of
vacancies should be deleted.  Otherwise, it will apply against the
interests of severely disabled.


Accessibility (Section 39)   :  It provides after amendment the powers
to enforce Accessibility Regulations to National Commission but there
is no mechanism nor procedure to enforce them.


Section 53:  This section excludes the institutions of persons with
disability established or maintained by the Central or State Govt.
from the Registration and Regulations which is unacceptable.


National Commission for persons with disabilities:  The earlier
suggestions have not at all been attended and we reiterate the same.


Section 98: The Bill does not provide for any Tribunal or any other
judicial forum for remedy against violations of rights granted in the
Bill.


Offences and Penalties: We strongly oppose section 108 which requires
a previous sanction of the Govt. before any court could take
cognizance in the event of an offence alleged to have been committed
by an employee of the Govt.  Such a stipulation gives a kind of
immunity to the public servants to violate the provisions of this
Bill.


Further, the Bill does not contain the provision in the existing Act
which makes reservation in all poverty allevitaition programmes for
persons with disabilities.


While promoting discrimination across the Board, the Bill also fails
to acknowledge the specific forms of discrimination which are
perpetuated against women and children with disabilities, and the need
for the twin track approach in addressing these, as well as the
intersection of caste and disability. The provisions with regard to
protecting the rights of women and children with disabilities is
unaddressed under the Bill. The right to recognizing the evolving
capacity of children in taking their own decisions relating to their
lives, including their right to choosing their mode of education, is
denied under this Bill. This Bill also clamps down on reproductive
rights of women with disabilities. Only "medical procedures which lead
to infertility" are barred under the Bill (as opposed to procedures or
medications which may lead to infertility or impact sexual health),
and there are inclusion of provisions like Section 106 (f) which
permits women with "severe disabilities", which is undefined under the
Bill, certified by a Registered Medical Practitioner, to be subjected
to abortions even without their consent.


There is also conditional freedom of liberty granted under the Bill
under Section 3 (4), which provides for no deprivation of liberty only
on the grounds of disability - but which therefore allows for
deprivation on the grounds of associated conditions, like destitution
and tendency for self harm, a formulation which was specifically
objected to in UNCRPD drafting Sessions. This will continue to
encourage unnecessary and involuntary institutionalization, which is
not specifically barred under the Bill.


There is no respect for the integrity of the person with disability: a
decision on what "high support needs" Persons with "Benchmark"
Disabilities may require is left entirely to the discretion of an
Assessment Board under Section 37, which can be moved by any person on
behalf of the person with disability, even without the consent of the
person who it is meant for, and with no obligation to consult the
person or respect his or her wishes.


Persons with Disabilities are kept away from the private sector:  be
it through denial of reservation in non-government employment, or by
the limitation of accessibility provisions only to Government
buildings- as the definition of "Establishments" exempts the
responsibility of the Private sector towards persons with
disabilities.


>From the above it is clear that the move to promulgate ordinance to
give effect to the pending flawed (rights of persons With Disabilities
Bill 2014) before Rajya Sabha and referred to the Standing Committee
to replace the existing The Persons With Disabilities Act 1995 is not
only detrimental to the existing rights of persons with disabilities
but would legitimize discrimination on  the ground of disability.  In
case the Govt. decides to go ahead with this move, this would be a
clear example of abuse of power U/A 123 of the Constitution of India.
This declaration has shakened our fate in the party and its
leadership.  We therefore request your honour to intervene and ensure
that no such is promulgated which otherwise also is unconstitutional.
In case, the Govt. wants to extend benefits in the existing Act to
those disabilities which are not included in the existing Act but are
included in the proposed Bill pending in Rajya Sabha, Govt. may bring
in an ordinance to include other disabilities within the definition of
the "persons with disabilities" as contained in Section 2(i) of the
Persons With Disabilities Act, 1995.



Thanking you,



Yours sincerely,





S.K. RUNGTA

Coordinator













Dated: 25.2.14

Dear friends!


Here is the latest update on developments regarding the RPD Bill.  The
All-India Disability alliance has intensified its campaign to stall
the promulgation of the RPD Bill through the ordinance route. As a
part of the said campaign, the alliance held demonstrations at 10
Janpath in front of Congress President Mrs. Sonia Gandhi's residence
as well as at Akbar Road in front of the Congress office yesterday.
Opposing any prospective move to promulgate the RPD Bill in its
present form, the demonstrators expressed the view that in case the
Govt. is keen to promulgate the Bill through ordinance apparently in
order to include the categories of persons with disabilities left out
of the purview of the Current PWD Act, it could do so by amending the
extant PWD Act; rather than by promulgating the RPD Bill in its
present form which, inter alia, seeks to legitimize discrimination
against persons with disabilities. Congress Treasurer Mr. Motilal Bora
and Dr. Jay kumar, Secretary AICC met me yesterday in the wake of the
said demonstrations.  Mr. Motilal Bora assured me that if at all any
ordinance is brought in, it will, as demanded by the All-India
Disability Alliance, only be for the purpose of amending the
definition related Section of the current PWD Act so as to include
persons belonging to those other categories of disabilities who are
not covered under the existing provisions of the PWD Act. AICC
Secretary Dr. Jay Kumar stated that no ordinance will be promulgated
without the active concurrence of the All-India Disability Alliance.


Sunday update


On behalf of the said alliance, a delegation met Mr. V. Narayan Swamy,
Minister of State in the PMO in Pondicherry who categorically stated
that no ordinance is in contemplation of the Govt. in violation of
established procedures.   Another delegation of the National
Federation of the Blind also met Mr. Rahul Gandhi in Dehra Dun,
Uttarakhand on behalf of the Alliance and submitted a memorandum
requesting him to ensure that the RPD Bill is not promulgated through
the ordinance route in its present form albeit the Govt. may, in order
to include persons belonging to some other categories of disabilities
as stated above, may appropriately amend the existing PWD Act.  Mr.
Gandhi, after hearing out the delegation assured that whatever is in
the best interest of persons with disabilities will be done and that
he will look into the demand of the Alliance.


Tuesday Update



A delegation comprising of members of National Federation of the Blind
met Smt. Sonia Gandhi in Rai Bareilly U.P. on behalf of the Alliance
and submitted her a memorandum making similar demand of not
promulgating the ordinance to give effect to the RPD Bill in its
present form and instead, consider amending the existing Act so as to
include other categories of disabilities not included in the present
Act by amending the definition of "persons with disabilities".  She
assured the delegation that the Ordinance to give effect to RPD Bill
in its present form which is pending consideration before the Standing
committee of Rajya Sabha, will not be promulgated.



Please find attached the memorandum submitted to Mrs. Sonia Gandhi on
behalf of Alliance.



Thanking you,





Yours sincerely,



S.K. RUNGTA

Coordinator







The AIDA is an Alliance of Organizations working on disability rights
including: All India Confederation of the Blind, Deafenabled, Delhi
University Physically Challenged Teachers Association, Human Rights
Law Network, Indian Association of Special Education and
Rehabilitation, National Association for the Blind India, National
Federation of the Blind, PARIVAAR (National Confederation of Parent's
Organizations for persons with intellectual and developmental
disabilities), Rashtrikya Viklang Manch, Saksham, Handicapped Welfare
Federation, Tamilnadu Disability Rights Alliance, Association of
Challenged People and Bethany Society Meghalaya, Sambhavna

-- 
Ajay Arora phd research scholar
Centre for the Study of Law and Governance
JNU
Nelson Mandela Marg
New Delhi India



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