The Department of Empowerment of Persons with Disabilities has
uploaded revised minutes of the meeting held for reviewing the writing
guidelines

I'm below sharing relevant sections where UPSC has submitted detailed
note objecting against the current guidelines..

block quote
 7.     The representatives from UPSC informed that they are allowing the
candidates to use their own scribes, in addition to Government scribes
for the objective type examination such as Civil Services
(Preliminary) examination. However, in case of Civil Services (main)
examination, which is of descriptive type they are allowing only
Government scribes who are arranged by Coordinator Supervisors
concerned. They stated that the discretion to the candidates to opt
for own scribe/reader would have an impact on the integrity of the
examination process as the candidate may bring a scribe who is more
proficient than him and who could write/correct/improve the content of
the answers. This may also become a commercial activity prone to
malpractices. UPSC has also received representations alleging
malpractices by the Candidates who had been permitted to have their
own scribes. UPSC was of the view that no amount of invigilation could
effectively obviate such malpractices in a descriptive
papers/examination.

 8.     The representatives from UPSC further stated that the possibility
of aspersions being cast in the public domain about the performance of
such candidates (who is allowed to use his own scribe) even if the
candidate qualified the examination on merit could not be ruled out.

 9.     They have further stated that UPSC has neither the presence nor
the resources to identify the scribes so as to make panels at the
Districts/Division/State level as per the requirements of the
examination Commission. Therefore, they have suggested that such a
panel should be prepared, maintained and updated by the State
Government concerned through district authorities from the local
resources/education Institutions and detailed guidelines for this
purpose may be formulated by the Government of India. This panel would
also facilitate the candidates with an option to select more than one
scribe/reader for writing different papers from such panel of scribes.

10. The representatives of UPSC have further mentioned that at
present, the scribes are being arranged through the Coordinating
Supervisors who are nominated by the concerned State Governments. UPSC
was of the view that the Government's scribes are governed by conduct
rules and thereby the chances of malpractice through them is minimised
whereas the Exam conducting body has no control over the private
scribes.

11. As regards the issue of doing away with fixation of any criteria
for the scribe, representative of UPSC stated that there should be
certain eligibility criteria like educational qualification for the
scribe so as to preclude the use of scribe who is more qualified and
has the ability to improve the performance of the candidate which
would tantamount to malpractice. Further, they have stated that at
present the Commission has been arranging for two scribes for each
eligible candidate keeping in view any aspect of emergency and also an
option for the candidate to select one out of the two scribes or
change the scribe opted by him. Allowing candidates to bring more than
one own scribe /reader on his own for writing different papers may
give the candidates an undue advantage and disturb the level playing
field. This may also have impact on integrity of the examination
process since the candidate would tend to bring subject specific
specialists as scribe for different papers in the examination.

 12.    The representative of UPSC also stated that the UPSC has been
providing scribes to the Visually Impaired candidates much before the
guidelines in the said OM came into existence and very few complaints
have been received from the candidates about the quality of the
scribes. Also, a large number of such candidates have been opting for
the Government scribes even when they had been exercised the option to
bring their own scribes in the Civil Services (Preliminary)
Examination. This is sufficient in itself to establish the efficacy of
the system which is a proven and a well established system being
operated by the UPSC.

 13.    In addition to the above, the representative of the UPSC
mentioned that except for one odd case, the Commission has not allowed
the candidates to bring their own scribe in the Civil Services (Main)
Examination. UPSC has been issuing detailed instructions to the
Coordinating Supervisors that the scribes being provided to the
candidates should not only be proficient in English but also in the
language medium opted by the candidate. He further mentioned that all
vacancies of PH candidate have been filled up in the Civil Services
Examinations in the recent past, where only Government scribes were
being allowed to PH candidate in the Civil Services (Main)
Examination.

 14.    With regard to the provisions in the guidelines allowing the
candidates to choose the mode of taking examination in Braille or on
computer or in large print, allowing assistive devices like talking
calculator etc. the representative from UPSC stated that these rules
not only involve logistical issues      but     may     also    have    the     
potential       for
representations/complaints/litigations on the grounds of the alleged
unsatisfactory hardware/printout/recording devices etc. Providing
question paper in Braille or in Computer in addition to the printed
version is likely to have involvement of multiple agencies and thereby
impinge on the confidentiality of question papers, which in turn could
have adverse impact on the sanctity and integrity of the examination
process.

 15.    The representative of UPSC drew the attention of Committee to the
order of Hon'ble High Court of judicature at Bombay dated 19.08.2014
in W.P. No. 5953 of 2014 in the matter of Shri Sujit Shinde and
another Versus UPSC and other. In this order, the Hon'ble High Court
has taken note of the fact that UPSC has justified its stand of
prescribing its maximum educational qualification which a scribe can
possess. In the Civil Services (Preliminary) examination which has an
objective type test, where the correct answer from 4 alternatives is
required to be marked by shading the appropriate circle therefore, a
scribe should be able to read Hindi/English versions of the questions
effectively. Therefore, a scribe of who is of graduate or
undergraduate level can effectively assist the visually challenged
candidate.

 16.    The representative of UPSC desired to know as to whether the
alternative objective question in lieu of descriptive questions for
hearing impaired person is recommending or mandatory in nature. JS,
DEPwD clarified that all the provisions of the guidelines including
para XV which deals with this aspect are mandatory.

 17.    The member SSC stated that the examinations conducted by SSC are
mostly based on multiple choice question papers. They allow only
Government scribes through their exam centre coordinators. SSC was of
the view that allowing private scribes even for multiple choice
answers would have impact on the integrity of the examination process.
SSC was in agreement with the submission of UPSC relating to other
issues such as fixation of criteria for the scribe, provision for
choice of taking examination in Braille, allowing assistive devices
etc.
block quote end




On 5/1/15, Vaishnavi Jayakumar <[email protected]> wrote:
> Dear Avinash,
>
> Where did you source a text version of this document? The MSJE document is
> a pdf with images.
>
> I just spent the whole morning transcribing this and the ISLRTC document
> and am cursing because my morning was a waste!
>
> Vaishnavi
>
> avinash shahi
> <https://www.mail-archive.com/[email protected]&q=from:%22avinash+shahi%22>
>  Thu, 30 Apr 2015 06:50:34 -0700
> <https://www.mail-archive.com/[email protected]&q=date:20150430>
>
> Having repeatedly perusing the minutes of the meeting,I feel there is a
> consensus emerging among the babus for thwarting the substantive objectives
> of the existing comprehensive guidelines. Read below to know what mediocre
> arguments was put forward by the UPSC and other bodies to modify the
> guidelines. Let us all converge and take resolve on one salient point that
> Invigilation is the crux and the thrust of the guidelines which should be
> strengthened. No arbitrary tempering,please. They say it is impracticable
> to provide questionpaper in Braille. What a tardy response exposing their
> political illwill. Can somebody inform UPSC that the UGC provides
> questionpapers in Braille all over India in NET exams. And questionpaper is
> not leaked? Why cant they do so? questionpaper will not be leaked as they
> fear. Secondly, they say qualification of the scribe should be
> lowered,that's non-negotiable isn't it? Anyway, its very crucial time for
> all of us and hope we remain united and alert in whatever strategy we
> adopt. Rungta sir,and NFB lets keep the fire on until the issue is not
> resolved for one and all. Below is the minutes of the meeting,those want to
> read PDF could visit MSJE website. Minutes of the preliminary discussions
> of the Expert Committee to review the Guidelines for conducting Written
> Examination for PwDs held under the Chairmanship of Secretary, DEPwD on
> 13,04.2015 at 04:00 PM in the Conference Room, 5th Floor, Paryavaran
> Bhawan, New Delhi The List of Participants is at Annexure. 2. Secretary,
> DEPwD welcomed the participants and requested Joint Secretary, DEPwD to
> briefly explain the background of constitution of the expert Committee and
> the agenda to be discussed in the meeting. 3. Joint Secretary, DEPwD stated
> that on the basis of the recommendations of Chief Commissioner of Persons
> with Disabilities, the Ministry had issued detailed guidelines for
> conducting examination for Persons with Disabilities on 26th February,
> 2013. The guidelines inter-alia include provision for scribe/reader/lab
> assistant, grant of extra time to the extent of 20 minutes per hour of
> examination, option of choosing mode of taking examination in Braille or in
> computer or in large print etc. Recently, UPSC has raised certain issues
> relating to practical implementation of the guidelines. UPSC has said that
> their comments on the draft guidelines communicated in 2008 were not
> considered. UPSC now has raised the issue of allowing private scribes
> especially while taking main examinations (other than multiple type
> question based examination), practicality of allowing question paper in
> Braille etc. The issues raised by UPSC were also discussed in a meeting
> held with DoPT when Chairman UPSC was also present. Staff Selection
> Commission has also raised similar observations. In order to look into the
> practical implementation issues raised by UPSC, SSC etc. an expert
> Committee under the Chairmanship of Secretary, DEPwD has been constituted.
> UPSC has now brought a detailed note outlining their observations on
> implementation of these guidelines for consideration of the Expert
> Committee. He further stated that the Committee was also required to decide
> the associations/experts to represent different disability associations
> namely visual impairment, hearing impairment and locomotor disabilities in
> the Expert Committee. He also brought to the notice of the Committee to the
> fact that the Department has received representations requesting nomination
> of experts for the cause of other disabilities such as Autism Spectrum
> Disorder, Specific Learning Disabilities, and Speech Impairment etc. 4.
> Secretary DEPwD requested representative from UPSC to briefly explain the
> problem being faced by them in implementing the guidelines. 5. The
> representatives from UPSC submitted that they are allowing scribes as per
> the choice of the candidates for multiple choice question based examination
> such as ICS preliminary examination. However, in case of main examination
> which is especially of descriptive type they are allowing only Government
> scribes through their centre coordinators. They stated that the discretion
> to the candidates to opt for own scribe/reader would have an impact on the
> integrity of the examination process as the candidate may bring a scribe
> who is more proficient than him and who could improve the content of the
> answers. The Commission has also received representations alleging
> malpractices by the Candidates who had been permitted to have their own
> scribes. The Commission was of the view that no amount of invigilation
> could effectively obviate such malpractices in a descriptive type of
> examination. The representatives from UPSC further stated that the
> possibility of aspersions being cast in the public domain about the
> performance of such candidates (who is allowed to use his own scribe) even
> if the candidate qualified the examination on merit could not be ruled out.
> They have further stated that the commission has no resource to identify
> the scribes for making panels at the district/division/state level. At
> present, the scribes are being arranged through the coordinating
> supervisors who are nominated by the concerned State Governments. UPSC was
> of the view that the Government's scribes are governed by conduct rules and
> thereby the chances of malpractice through them is minimised. 6. As regards
> the issue of doing away with fixation of any criteria for the scribe,
> representative of UPSC stated that there should be certain eligibility
> criteria like educational qualification for the scribe so as to preclude
> the use of scribe who is more qualified and has the ability to improve the
> performance of the candidate which would tantamount to malpractice.
> Further, they have stated that at present the Commission has been arranging
> for two scribes for each eligible candidate keeping in view any aspect of
> emergency and also an option for the candidate to select one out of the two
> scribes. Allowing candidates more than one own scribe/ reader may also have
> impact on integrity of the examination process since the candidate would
> tend to bring subject specific specialists as scribe for different exam
> papers. 7. With regard to the provisions in the guidelines allowing the
> candidates to choose the mode of taking examination in Braille or on
> computer or in large print, allowing assistive devices like talking
> calculator etc, the representative from UPSC submitted that these rules not
> only involve logistical . issues but may also have the potential for
> representations/ complaints/litigations on the grounds of the alleged
> unsatisfactory hardware/printout/recording devices etc. Providing question
> paper in Braille or in Computer in addition to the printed version is
> likely to have involvement of multiple agencies and thereby impinge on the
> confidentiality of question papers, which in turn could have adverse impact
> on the examination process. 8. The representative of UPSC drew the
> attention of Committee to the order of Hon'ble High Court of judicature at
> Bombay dated 19.08.2014 in W.P. No. 5953 of 2014 in the matter of Shri
> Sujit Shinde and another Versus UPSC and other. In this order, the Hon'ble
> High Court has taken note of the fact that UPSC has justified its stand of
> prescribing its maximum educational qualification which a scribe can
> possess. In the preliminary examination which has an objective type test,
> where the correct answer from 4 alternatives is required to be marked by
> shading the appropriate circle therefore, a scribe should be able to read
> Hindi/English versions of the questions effectively. Therefore, a scribe of
> who is of graduate or undergraduate level can effectively assist the
> visually challenged candidate. 9. The representative of UPSC desired to
> know as to whether the alternative objective question in lieu of
> descriptive questions for hearing impaired person is recommending or
> mandatory in nature. JS, DEPwD clarified that all the provisions of the
> guidelines including para XV which deals with this aspect are mandatory.
> 10. The member SSC stated that the examinations conducted by SSC are mostly
> based on multiple choice question papers. They allow only Government
> scribes through their exam centre coordinators. SSC was of the view that
> allowing private scribes even for multiple choice answers would have impact
> on the integrity of the examination process. SSC was in agreement with the
> submission of UPSC relating to other issues such as fixation of criteria
> for the scribe, provision for choice of taking examination in Braille,
> allowing assistive devices etc. 11. Shri T.D. Dhariyal, former Dy. CCPD and
> present Consultant in the Office of CCPD has intimated that the process of
> framing of policy guidelines for conducting examination of PwDs was
> initiated in 2001 -02 in consultation with Ministry of Human Resource 85
> Development and DoPT. As both the Agencies did not issue any guidelines,
> O/o CCPD took up the issues based on number of representations received by
> it. The stakeholders were of the view that there should not be any criteria
> such as the qualification of the scribe should be one class below the
> minimum required educational qualification for the examination. After
> prolonged consultations the Commission was of the view that no fixed
> criteria should be there for selection of scribe and the scribe is to be
> for all class of PwDs whose writing capacity or speed is affected.
> Subsequently the recommendations were sent to the Ministry for framing of
> guidelines. 12. Director, IPH submitted that it would be appropriate if
> UPSC on their own analyse the scenario taking into account number of cases
> where scribes were used, number of PwDs selected using such scribes,
> qualification of scribes, number of complaints received against such
> scribes etc. and submit a detailed justification for consideration of
> Committee. 13. Representative from Department of Higher Education submitted
> that the Ministry of HRD on its own does not have expertise to comment on
> the relevant aspects. He suggested that representatives from UGC, AICTE and
> CBSE may be co-opted as members so as to make the deliberations of
> Committee more meaningful. 14. Director, NIHH suggested that no criteria
> for the scribe should be prescribed rather the invigilation process should
> be strengthen to take care of any perceived malpractices during examination
> process. 15. After detailed deliberations, the following decisions were
> taken: i. The office of CCPD will submit a detailed documentation on
> framing of the guidelines containing the range of issues raised on each
> aspects, how the recommendations were finalised etc. ii. UPSC will submit
> detailed justification for seeking modifications in the guidelines taking
> into account number of cases where scribes were used, number of PwDs
> selected using such scribes, qualification of scribes, number of complaints
> received regarding use of such scribes (both government and private) etc.
> iii. Representatives from UGC, AICTE and CBSE may also be coopted as
> members of the Expert Committee. Department of Higher Education will
> expedite the process of nomination of these agencies. iv. The following may
> be nominated to represent various class of PwDs in the Committee:- Class of
> Disability Nominated Member a Visual Impairment (i) Ms. Kanchan Pamnani
> (ii) Shri S.K. Rungta, National Federation of Blind. Hearing Impairment (i)
> Mrs. Snigdha Sarkar, Secretary, ANWESHA (ii) Prof. S andhya Limay e, Centre
> of Disability Studies and Activities, Mumbai /. Locomotor Disabilities Shri
> Komal Kabra, Khalsa College, Delhi University Mental Impairment Ms Nirmala
> Srinivasan 16. The meeting ended with vote of thanks to the chair. *** **
> ** ********* ** Minutes of the Preliminary Discussion of Expert Committee
> to review the Guidelines for conducting examination for PwDs held under the
> Chairmanship of Secretary, DEPwD on 13.04.2015 at 04:00 PM LIST OF
> PARTICIPANTS 1. Shri Low Verma, Secretary, DEPwD in chair 2. Shri Awanish
> K. Awasthi, Joint Secretary, DEPwD 3. Ms Archana Verma, Joint Secretary,
> DoPT 4. Shri R.K. Arora, Additional Secretary, UPSC 5. Shri Sanjay
> Mehrishi, Joint Secretary, UPSC 6. Shri Chetan Prakash Jain, Member, SSC 7.
> Dr. Dharmendra Kumar, Director, IPH 8. Dr. A.K. Sinha, Director, AYJNIHH 9.
> Shri T.D. Dhariyal, Consultant, O/o CCPD 10. Shri Davinder Pal Singh,
> Deputy Secretary, Department of Higher Education, Ministry of Human
> Resource 85 Development 11. Shri D.K. Panda, Under Secretary, DEPwD --
> Avinash Shahi Doctoral student at Centre for Law and Governance JNU
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-- 
Avinash Shahi
Doctoral student at Centre for Law and Governance JNU



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