Legal Review and Analysis of Mission Accessibility vs Union of India & Ors 2025 INSC 1376

Case Synopsis

Name & Citation: Mission Accessibility vs. Union of India & Ors. (2025 INSC 1376)

Essence: The Supreme Court mandated the Union Public Service Commission (UPSC) to transition from a policy of intent to one of actionable implementation for making the Civil Services Examination accessible. It directed the formulation of a concrete roadmap, flexible procedures, and inter-departmental coordination to provide screen readers and reasonable accommodations, thereby enforcing the constitutional guarantee of substantive equality and dignity for persons with disabilities.

1. Case Identification & Citation

Judgment Name: Mission Accessibility vs. Union of India & Ors
Citation: 2025 INSC 1376
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Writ Petition (C) No.: 206 of 2025

2. Relevant Laws & Legal Provisions

This judgment interprets and enforces the following constitutional and statutory mandates:

• Constitution of India:
  Article 14: Right to Equality.
  Article 16: Equality of opportunity in matters of public employment.
  Article 21: Right to Life and Personal Liberty, interpreted to include the right to live with dignity.

• The Rights of Persons with Disabilities Act, 2016: The primary legislation for safeguarding and promoting the rights and dignity of persons with disabilities (PwD) in all spheres of life, including access to education and employment.

• Civil Services Examination Rules, 2025: The rules governing the conduct of the UPSC Civil Services Examination.

3. Details of the Case

A. Factual Background

The writ petition was filed by "Mission Accessibility," an organization advocating for the rights of persons with disabilities. It challenged certain procedural norms of the Union Public Service Commission (UPSC) for the Civil Services Examination (CSE), arguing they created barriers for candidates with disabilities.

The key grievances were:

1. Inflexible Scribe Registration: The requirement for candidates to finalize and furnish details of their scribe at the time of submitting the initial application, with no provision for changes closer to the exam date in case of the scribe's unavailability.

2. Lack of Assistive Technology: The non-provision of screen reader software and accessible digital question papers for visually impaired candidates, forcing reliance on human scribes instead of enabling independent use of technology.

B. Issues Before the Supreme Court

The core legal issues were whether the UPSC's existing examination procedures:

1. Violated the constitutional rights to equality, dignity, and equal opportunity (Articles 14, 16, 21) and the statutory rights under the Rights of Persons with Disabilities Act, 2016, by imposing inflexible conditions for scribe arrangement.

2. Failed in their duty to provide reasonable accommodation by not allowing the use of laptops with screen reader software and accessible digital question papers for eligible candidates.

C. Ratio Decidendi (The Court's Reasoning & Decision)

The Supreme Court disposed of the petition by issuing specific mandamus directions to the respondents. Its reasoning forms the ratio decidendi:

1. Substantive Equality & Reasonable Accommodation: The Court articulated a philosophy of justice that moves beyond "formal equality" to "substantive inclusion." It held that true equality for persons with disabilities requires the removal of barriers and the provision of facilitative measures (like flexible scribe policies and assistive technology) to ensure they can compete on an equal footing.

2. Policy Approval with Implementation Gap: The Court acknowledged the UPSC's "in-principle" decision to introduce screen reader software as a "significant policy advancement." However, it found a critical gap between policy intent and practical execution, noting the lack of a concrete roadmap, timeline, or standardized operational framework.

3. Constitutional Imperative for Accessible Governance: The Court emphasized that the rights of persons with disabilities are not "acts of benevolence" but a constitutional promise. It held that the UPSC, as a premier constitutional body, must ensure its processes are accessible, transparent, and sensitive to the needs of all citizens to fulfil the vision of meaningful participation.

4. Core Legal Principle and In-Depth Analysis

Title: From Promise to Practice: Judicial Enforcement of Accessibility in Public Employment

Core Issue and the Supreme Court's Addressing: This judgment addresses the systemic failure to operationalize inclusive policies. The Supreme Court intervened not just to declare rights, but to bridge the implementation gap between progressive policy announcements and their tangible, on-ground realization for persons with disabilities.

A. Redefining Equality in Public Examinations: The Court’s opening remarks set a powerful normative framework. It distinguished between "uniformity" and the removal of barriers to achieve "parity." This reframed the petitioner's demands from seeking special privilege to claiming the "rightful fulfilment of the constitutional vision." The judgment elevates accessibility from an administrative concern to a constitutional imperative under Articles 14, 16, and 21.

B. The Judiciary as a Catalyst for Institutional Accountability: The Court’s role transcended adjudication; it assumed the function of a monitoring and coordinating authority. Recognizing UPSC’s dependence on external infrastructure (state governments, schools), the Court issued detailed, process-oriented directives to ensure inter-agency collaboration (between UPSC, DEPwD, NIEPVD). This reflects an understanding that complex systemic change requires judicial oversight to synchronize multiple stakeholders.

C. Mandating a Concrete Roadmap: From "In-Principle" to "In-Practice": The most significant aspect of the ruling is its refusal to accept a vague future promise as compliance. By directing the UPSC to file a "comprehensive compliance affidavit" with a clear plan, timeline, and modalities, the Court ensured accountability. It shifted the burden from the petitioner to prove ongoing violation, to the state to demonstrate proactive steps towards compliance. The listing of the matter for a future date (Feb 16, 2026) specifically to receive this affidavit underscores the Court's commitment to follow-through.

D. Balancing Accessibility with Examination Integrity: The Court consciously balanced the mandate for inclusion with the legitimate state interest in maintaining the "sanctity, confidentiality, and fairness" of examinations. Its directions require the formulation of "uniform guidelines and protocols" for assistive technology, ensuring that accessibility does not compromise security—a nuanced approach that strengthens the legitimacy of its intervention.

Final Outcome Synthesis:
The Supreme Court disposed of the writ petition with the following binding directions:

1. Flexible Scribe Policy: UPSC must allow candidates to request a scribe change up to seven days before the exam, with requests decided by a reasoned order within three working days.

2. Implementation Roadmap for Screen Readers: UPSC must file a detailed affidavit within two months outlining a concrete plan, timeline, and modalities for deploying screen reader software and accessible digital papers.

3. Inter-Agency Coordination: UPSC must coordinate with DEPwD and NIEPVD to formulate uniform guidelines for assistive technology.

4. Central Government Support: The Union of India (DoPT & Ministry of Social Justice) must extend all necessary support for implementation.

5. (MCQs) Based on the Judgment

Question 1: In Mission Accessibility vs. Union of India, the Supreme Court primarily based its directives on which core legal principle?
a) The principle of severability of unconstitutional provisions.
b) The principle of substantive equality and reasonable accommodation for persons with disabilities.
c) The principle of legitimate expectation.
d) The principle of proportionality in administrative action.

Question 2: One of the key directives issued by the Supreme Court in the aforementioned case was to ensure?
a) The immediate termination of the scribe system in all UPSC examinations.
b) The provision of a concrete implementation roadmap and timeline for introducing screen reader software.
c) The reduction of the number of attempts for candidates with disabilities.
d) The transfer of examination conduct authority from UPSC to the Ministry of Social Justice.