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As Rahul Gandhi’s clash with the Election Commission over non-searchable voter lists dominates headlines, disability rights advocates warn of a deeper violation — image-only PDFs of electoral rolls. This format, they say, not only hinders transparency but also breaks the law, shutting out millions of voters with sight disabilities from their right to vote.
The political dispute began when the Congress leader alleged that the Election Commission of India (ECI) provided his party with electoral rolls in formats designed to frustrate scrutiny, including reams of printed paper stacked “seven feet high” and digital files locked as non-machine-readable PDFs. Rahul said this hindered efforts to detect duplicate and fraudulent entries, pointing to alleged fraud in Mahadevapura, an assembly constituency in Bengaluru.
While the political fight about vote theft focuses on voting fraud detection, disability rights groups say Rahul’s complaints inadvertently highlight an older and largely ignored issue: that the ECI has been violating the Rights of Persons with Disabilities Act, 2016 (RPWD Act) for years by refusing to make electoral documents accessible.
Pointing out how accessibility is inseparable from transparency, activists explain how it helps people with low literacy, language barriers, learning disabilities, and neurodiverse individuals to participate in the nation-building process.
In India, Section 42 of the Act mandates the government to ensure accessibility to Information and Communication Technology (ICT) for persons with disabilities. This includes making all content in audio, print, and electronic media accessible, providing access to electronic media through audio description, sign language interpretation, and closed captioning, and ensuring that electronic goods and equipment are available in universal designs.
Non-compliance with this can be challenged before the Chief Commissioner for Persons with Disabilities, in the High Courts, or the Supreme Court.
Yet, even today, citizens with sight disabilities find themselves grappling with inaccessible documents, CAPTCHA systems, and increased dependency on others during the voting process, which violates their right to a secret ballot.
Clear obligations, missed deadlines
The RPwD Act, along with Rule 15 of the 2017 Rules, requires all public information to be available in machine-readable formats such as OCR-enabled PDFs or ePUB. These formats preserve text as text, allowing screen readers to convert it to speech or braille.
In 2023, Indian Standard IS 17802 established detailed norms for digital accessibility, aligning India with global benchmarks. Section 11 of the RPwD Act also specifically mandates that all polling materials, including candidate lists, must be fully accessible to persons with sight disabilities.
The compliance timeline was equally clear: services (including websites) were to become accessible within two years of the Rules’ notification in June 2017, and infrastructure changes were given a five-year window.
“By mid-2019, every electoral roll, candidate list, and related document should have been accessible,” said Vaishnavi Jayakumar, a member of the Disability Rights Alliance.
Dr Satendra Singh, a disability rights advocate honoured with the National Award on inclusive elections by the President of India, said that despite this, citizens with disabilities are being handed inaccessible documents.
“15 June 2019 was the deadline for all government websites to comply with accessibility standards. Yet in 2025, we see election bodies publishing inaccessible PDFs, excluding citizens with visual impairment,” Satendra added.
Why image-only PDFs shut people out
“For sighted voters, an image-only PDF is just inconvenient. For blind voters, it is impenetrable,” said Amar Jain, a corporate lawyer and co-founder of Mission Accessibility, a non-profit organisation advocating for equal accessibility for all citizens.
“What we are asking for is simple—keep text as text. A document you can select, copy, and search is a document that a blind person’s screen reader can read. The minute you turn it into an image, you shut us out,” Amar explained.
To explain this to a layman user, Amar elaborated that a simple document on which a Ctrl+F function and other basic word commands like cut, copy, paste, etc., can be performed would be ideal compared to an image-only PDF.
This problem also extends beyond voter rolls to other election documents. The candidate list showing the order of names on EVMs is also often published as an image PDF.
“Not everybody knows Braille. Even if they do, the polling booth may not have a braille copy. A sighted person can check the list and know exactly which number their preferred candidate is, but a blind person cannot unless the file is machine-readable,” Vaishnavi said.
She also added that inaccessible formats strip away the secrecy of the ballot, which is a core democratic right.
“I don’t want even a family member to know who I am voting for. But if I have to take someone’s help to read the list, my privacy is gone,” she said, adding that even a simple verification becomes impossible without help. This also prevents voters with sight disabilities from learning more about candidates, their qualifications, disqualifications, or their history of criminal proceedings.
“Additionally, if I want to check whether my name is still on the electoral roll or if I’ve been removed in a so-called purification drive, I can’t do it on my own. That dependency is discrimination,” she underlined.
No legitimate excuse for inaccessibility
Advocates say there are no technical or legal barriers to making these documents accessible to citizens with sight disabilities.
When Amar Jain approached the Supreme Court in 2025, citing how a majority of government websites, mobile applications, and digital services are inaccessible to people with disabilities, the Court upheld that the right to digital access forms part of the right to dignity, a fundamental right under Article 21 of the Constitution.
Vaishnavi pointed out that there is no disadvantage to any other party in the process. “You cannot claim there is a disadvantage in making documents machine-readable the way it was initially. There is no disadvantage. It’s just obstructive,” Vaishnavi said.
She also criticised the ECI’s use of inaccessible CAPTCHA systems on its website.
“We have been advocating for multi-modal CAPTCHA for over a decade. You can keep your security, but you must have a range of options — text, audio, SMS OTP. Accessibility is not a favour, it is a legal duty,” she further said.
With the ECI already under fire, activists want it to act immediately. Their demands include replacing all image-only PDFs with OCR-enabled, text-based files, implementing an IS 17802-compliant accessible CAPTCHA, and ensuring candidate lists and all other polling materials are in accessible formats.
“We’ve pointed this out to the ECI for years. We even converted a candidate list ourselves during one election to prove it can be done. The law is clear, the technology exists, and the deadline passed years ago. What’s missing is the will,” Vaishnavi said.
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