In a significant step toward ensuring inclusive digital KYC, the Supreme Court of India, on 1st May 2025, directed the Reserve Bank of India (RBI) to issue guidelines making digital verification processes accessible for persons with disabilities. The judgment was delivered by a Division Bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan. The case was filed by individuals including acid attack survivors and a visually impaired person who were unable to complete standard e-KYC procedures due to facial disfigurements or blindness. The Court observed that the existing KYC methods such as requiring eye blinking or capturing a live photograph created serious accessibility barriers, violating the Rights of Persons with Disabilities Act, 2016, and Article 21 of the Constitution. Emphasizing the need for digital equality, the Bench highlighted that essential services must be inclusive, accessible, and barrier-free, especially for the most vulnerable sections of society. This blog covers the Supreme Court’s order to make digital KYC accessible for persons with disabilities.
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Background of the Case: The Need for Inclusive Digital KYC
The case was filed by individuals with disabilities, including acid attack survivors and a person with visual impairment, who faced serious challenges while completing online KYC (Know Your Customer) procedures. These digital KYC methods, commonly used by banks and telecom companies, often require users to blink or take a live photo for identity verification.
However, these requirements were not accessible to people with facial disfigurements or blindness, effectively excluding them from accessing essential services like opening bank accounts, activating SIM cards, or applying for government benefits.
The petitioners argued that such practices violated their rights under the Rights of Persons with Disabilities Act, 2016, which mandates equal access to all services, including digital platforms. They also claimed a violation of their fundamental right to life and dignity under Article 21 of the Constitution.
The Supreme Court took note of these concerns and agreed that the lack of inclusive digital KYC options leads to discrimination and digital exclusion, reinforcing the need for accessible and user-friendly verification methods.
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Court’s Reasoning on the Need for Inclusive Digital KYC
The Supreme Court emphasized that the right to life under Article 21 of the Constitution must be understood in today’s digital context. It stated that access to digital platforms like banking apps, government services, and online education is now essential for living a life of dignity and equality.
The Bench, comprising Justice J.B. Pardiwala and Justice R. Mahadevan, observed that digital KYC has become a mandatory process for accessing basic services such as opening bank accounts, buying SIM cards, and enrolling in welfare schemes. However, the current methods like requiring users to blink or submit a live photo are not accessible to everyone.
The Court pointed out that these procedures exclude people with visual impairments or facial disfigurements, violating their fundamental right to equality and dignity. It made it clear that ensuring inclusive digital KYC is not just a policy choice, but a constitutional duty.
The judges noted that many digital platforms are not compatible with screen readers, and important information is often shown only in visual formats, making it difficult for the blind or low-vision users to complete the process. These barriers limit the ability of persons with disabilities to fully participate in society whether it is through work, education, or communication.
Importantly, the Court stated that this exclusion amounts to a denial of equal access, violating the accessibility mandates under the Rights of Persons with Disabilities Act, 2016. It also goes against international obligations under the UN Convention on the Rights of Persons with Disabilities (UNCRPD). Therefore, the State must actively work to close the digital gap and make digital systems truly inclusive and equitable for all.
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Legal Framework Applied in the Case
- Rights of Persons with Disabilities Act, 2016 (RPwD Act): The Rights of Persons with Disabilities Act, 2016 is a landmark law in India that protects the rights of people with disabilities. It aims to ensure equality, non-discrimination, and accessibility for persons with disabilities in all areas of life, including education, employment, health, and public services.Under this Act, the government and private entities are required to provide reasonable accommodations and remove barriers that limit access for persons with disabilities. This includes making digital services accessible. The Act also emphasizes the need for inclusive infrastructure and technology, ensuring that persons with disabilities can participate fully and independently in society. In this case, the Supreme Court relied heavily on the RPwD Act to highlight that digital KYC processes must be adapted to meet the needs of persons with disabilities, preventing their exclusion from essential financial and government services.
- Article 21 of the Constitution of India: Article 21 guarantees the fundamental right to life and personal liberty to every citizen. The Supreme Court has interpreted this right broadly to include the right to live with dignity and the right to access essential services necessary for a decent life. In the digital age, the Court has extended Article 21 to cover digital access as an essential part of the right to life. This means the State must ensure that digital infrastructure, such as online platforms and digital KYC systems, are inclusive and accessible to all, including persons with disabilities.
- Articles 14, 15, and 38 of the Constitution of India
Article 14 provides the right to equality before the law and equal protection of the laws.
Article 15 prohibits discrimination based on religion, race, caste, sex, or place of birth.
Article 38 directs the State to promote social welfare and work towards minimizing inequalities.
Together, these Articles reinforce the constitutional duty of the State to design policies and systems including digital ones that are fair, non-discriminatory, and supportive of vulnerable groups.
These laws collectively form the legal basis for the Supreme Court’s order to make inclusive digital KYC mandatory, ensuring that persons with disabilities can access essential services without discrimination.
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Supreme Court Directives to Ensure Inclusive Digital KYC for Persons with Disabilities
To make the process of digital KYC accessible for persons with disabilities, especially those with facial or eye disfigurements due to acid attacks and people with visual impairments, the Supreme Court gave important directions:
- All government and private regulated entities (REs) must follow prescribed accessibility standards to make digital platforms easier to use for everyone.
- Every department must appoint a nodal officer responsible for ensuring digital accessibility compliance.
- Regular accessibility audits must be conducted by certified professionals. Persons with blindness should be involved during the user testing phase when designing new apps, websites, or features.
- The Reserve Bank of India (RBI) must issue guidelines to all regulated entities to adopt alternative ways to verify “liveness” or capture a live photograph beyond the traditional blinking of eyes for conducting inclusive digital KYC.
- The RBI should clarify that Customer Due Diligence (CDD) and onboarding can be done using video-based KYC or the “V-CIP” process, where blinking is not mandatory.
- The RBI must also amend its KYC Master Direction to strengthen the use of OTP-based face-to-face e-KYC authentication for customers.
- The government must continue allowing paper-based KYC as an accessible option for those unable to use digital methods.
- To help visually and hearing-impaired users, authorities should provide sign language interpretation, closed captions, and audio descriptions.
- Alternative formats such as Braille, easy-to-read versions, and voice-enabled services must be developed to share government notifications and public services accessibly.
These directives aim to ensure that the inclusive digital KYC process is user-friendly, accessible, and fair for all persons with disabilities.
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RBI’s KYC Master Direction 2016 and Its Role in Inclusive Digital KYC
The Reserve Bank of India’s (RBI) KYC Master Direction 2016 is a key regulatory guideline that sets the rules for Know Your Customer (KYC) processes across banks and financial institutions in India. It aims to prevent fraud, money laundering, and terrorism financing by verifying the identity of customers before providing banking or financial services.
Under this Master Direction, regulated entities must verify a customer’s identity through various methods, including digital or video-based KYC (e-KYC). Traditionally, this verification process requires capturing a live photograph or asking customers to blink during video authentication to confirm “liveness.”
However, these traditional verification methods create problems for persons with disabilities, especially those with facial disfigurements or visual impairments. The current standards can unintentionally exclude these groups, restricting their access to essential financial services.
Recognizing this challenge, the Supreme Court directed the RBI to amend the Master Direction to allow alternative and accessible methods for verifying “liveness” during digital KYC. This means that banks and financial institutions must adopt more inclusive digital KYC options that do not rely solely on blinking or live photo capture, ensuring persons with disabilities can complete KYC without barriers.
The RBI was also instructed to promote the use of OTP-based e-KYC authentication and maintain the option for paper-based KYC as an accessible alternative for those unable to use digital methods.
These changes aim to make the KYC process more inclusive, user-friendly, and accessible, in line with the constitutional mandate and the Rights of Persons with Disabilities Act, 2016.
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Supreme Court Quotes and Remarks on Inclusive Digital KYC
“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.”— Justice J.B. Pardiwala & Justice R. Mahadevan
The judges emphasize that in today’s world, digital access is part of our basic rights under Article 21 (right to life). Since so many important services are now online, the law must recognize that without digital inclusion, a person cannot fully enjoy their right to life and dignity. This highlights the need for inclusive digital KYC that accommodates everyone.
“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 Court says that closing the gap between those who have access to digital tools and those who don’t is not just a choice it is required by the Constitution. Everyone deserves equal chances to live with dignity and participate fully in society. Making digital KYC accessible is a key part of this effort.
“Persons with disabilities encounter unique barriers in accessing online services due to the lack of accessible websites, applications and assistive technologies.”
The judges recognize that many websites and apps are not designed to be used by persons with disabilities. This creates obstacles that make it hard for them to complete tasks like KYC verification. This ruling pushes for better design of digital services to ensure everyone can use them comfortably.
“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.”
The Court points out that digital barriers stop persons with disabilities from accessing jobs, education, and social life, which violates their rights under international and national laws like the Rights of Persons with Disabilities Act, 2016. Removing these barriers through inclusive digital KYC promotes equality and inclusion.
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Impact of the Case on Inclusive Digital KYC
This Supreme Court judgment marks a major step forward for inclusive digital KYC in India. By directing the RBI and other authorities to adopt accessible verification methods, the ruling ensures that persons with disabilities especially those with visual impairments or facial disfigurements
can now easily access essential financial and government services without facing discrimination.
The judgment reinforces the rights of persons with disabilities as guaranteed under the Rights of Persons with Disabilities Act, 2016, by removing digital barriers that excluded them from basic services. It pushes both government and private organizations to design their digital platforms to be accessible and user-friendly for everyone.
Beyond improving access to banking and telecom services, this case highlights the constitutional right to equality and dignity in the digital era. It sets an important precedent that digital inclusion is not optional but a constitutional mandate under Article 21.
Overall, this ruling will help reduce the digital divide, promote social and economic inclusion, and empower persons with disabilities to participate fully in society. It also encourages the development of new technologies and innovations that are accessible to all, fostering a more equitable digital future.
Final Thoughts
The Supreme Court’s ruling in this case is a landmark step toward making digital KYC processes truly inclusive and accessible for persons with disabilities. By directing the RBI and other authorities to adopt alternative verification methods beyond traditional eye-blinking checks, the Court has ensured that individuals with visual impairments and facial disfigurements can equally access essential financial and government services. Ultimately, the decision empowers marginalized communities, reduces social and economic exclusion, and paves the way for a more equitable digital future where technology serves everyone without discrimination.
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