AI for All or Exclusion by Default? Open Letter to PM Narendra Modi on Disability Bias in Artificial Intelligence, Accessibility Challenges, and Lessons from India AI Impact Summit 2026 – Addressing TechnoAbleism in India's AI Policy and Governance

Date: 26/02/2026

To,

Shri Narendra Modi Ji
Hon’ble Prime Minister of India
South Block, New Delhi

Subject: On Artificial Intelligence, Disability Bias, and the Meaning of “AI for All”

Hon’ble Prime Minister,

Namaskar.

I write to you not as a technologist, nor as a lawyer by formal training. I write as a citizen who lives with disability, and as someone who has had to understand both law and technology simply in order to participate in ordinary life. Much of what I know about systems has not been learnt in classrooms. It has been learnt at doorways without ramps, on websites without structure, and in digital forms that could not be completed without assistance.

Exclusion rarely announces itself. It is usually designed quietly.

At the India AI Impact Summit 2026, when your address was translated in real time through an AI-powered sign language avatar, I watched carefully. It was an impressive demonstration, certainly. But it was also something more subtle. For a brief moment, Access was visible. It was not an afterthought. It stood alongside innovation, not behind it. That visibility matters. It signals direction.

I would also like to draw to the attention of Shri Narendra Modi that Moneylife published an article entitled “TechnoAbleism in India’s AI Moment: Why Accessibility Is Not Enough” [click here to read article] on 17 February 2026, coinciding with the India AI Impact Summit’s session on disability. The piece shows that this issue is already the subject of public discussion and media scrutiny, which underlines the urgency of treating accessibility and disability bias as central elements of India’s AI programme.

Yet direction must be followed by design.

We speak today of “AI for All.” It is a powerful phrase. But if it is to carry meaning, it must confront a difficult truth: artificial intelligence systems, as they are presently trained and deployed across the world, tend to absorb and reproduce the biases already present in society. Disability is not excluded intentionally. It is excluded structurally.

Artificial intelligence learns from data. That data is drawn from the world as it has been recorded. The recorded world, especially the digital one, reflects certain assumptions about how a person moves, speaks, types, sees, processes information, and builds a career. The so-called average user becomes the reference point. Systems are optimised around that reference point. Others are accommodated only when someone remembers to ask.

In such systems, disability becomes an exception.

This becomes visible in small but telling ways. When generative AI tools are asked to create websites or applications, they often produce code that assumes mouse navigation, adequate vision, and conventional interaction patterns. Keyboard accessibility may not be complete. Structural markup for screen readers may be missing. Alternative text may not be generated unless explicitly requested. Colour contrast frequently fails established accessibility norms.

Unless instructed, accessibility does not appear by default.

That word, default, is where the real issue lies.

Under the Rights of Persons with Disabilities Act, 2016, and under India’s obligations pursuant to the United Nations Convention on the Rights of Persons with Disabilities, accessibility is not optional. It is not decorative. It is a matter of Equality and Dignity. The Hon’ble Supreme Court has affirmed that accessibility is foundational to the exercise of fundamental rights. Without access, rights remain theoretical.

When artificial intelligence begins to generate systems at scale, inaccessible design also begins to scale. What was once a single inaccessible website becomes hundreds. What was once a human oversight becomes an automated pattern. Exclusion is no longer episodic. It is multiplied.

A citizen need not be denied formally. She may simply be unable to use what has been built.

India has articulated an ambitious artificial intelligence architecture, extending from infrastructure and compute to foundational models and applications. The vision is large. The confidence is visible. But I worry about timing. If disability is considered only at the application stage, after the underlying models have already been trained on datasets that insufficiently represent disability experience, then correction later will be partial and costly.

Bias does not remain soft once embedded. It settles into systems.

We have seen, in other technological domains, a familiar cycle. Innovation is celebrated. Adoption expands rapidly. Harm becomes visible only after scale has been achieved. Regulation then attempts to repair what might have been prevented. Artificial intelligence operates at a velocity and magnitude that make delayed correction far more difficult.

The Book of Proverbs says, “Where there is no vision, the people perish.” I do not read that verse as theological warning. I read it as policy advice. Vision must mean foresight; asking who is not being seen.

Around the world, governments have begun to grapple with these questions. The European Union has enacted an Artificial Intelligence Act that links AI governance explicitly to fundamental rights and non-discrimination. High-risk systems are subject to structured assessment and documentation. Bias audits and impact assessments are becoming part of regulatory vocabulary in several jurisdictions. The conversation is no longer limited to efficiency. It includes fairness.

India, as a State Party to the UN Convention on the Rights of Persons with Disabilities, is already bound by obligations to ensure equal access to information and communication technologies. These commitments do not diminish because technology evolves. If anything, their relevance increases.

This is not an argument for importing foreign law. It is an argument for aligning our technological progress with our own constitutional morality.

There is another dimension that requires attention, and it cannot be resolved by rhetoric alone. We need structured, publicly supported research on disability bias in artificial intelligence systems. Not assumption. Not symbolic inclusion. Research.

Datasets must be examined for representational gaps. Model outputs must be tested systematically across disability-related contexts. Evaluation metrics must measure performance across diverse sensory and cognitive realities. Without such empirical work, we shall continue to debate in abstraction.

Artificial intelligence is not only engineering. It touches law, sociology, governance, ethics, and lived experience. Universities such as NALSAR and other institutions working at the intersection of law and public policy ought to collaborate with technical institutes developing AI systems. Organisations grounded in disability rights must be involved as knowledge partners, not merely consulted at the end.

Public funding is being directed towards compute capacity, innovation ecosystems, and model development. A focused allocation for research on AI and disability bias would not be disproportionate. 

Yet its impact would be long-term and structural.

The Government of India ought undertake such a structured research initiative on artificial intelligence and disability bias, I would respectfully seek to be involved in that effort. For several years, I have been examining this question in depth and have maintained a dedicated platform, thebiaspipeline.nileshingit.org [click here to visit site], where I have written extensively on disability bias in digital systems and AI. While many organisations in India are rightly focused on accessibility compliance, very few are examining algorithmic bias itself as a systemic concern. I believe my sustained work in this area positions me to contribute meaningfully to any national research initiative. Significant public resources are presently being invested in artificial intelligence. If disability bias is not studied with equal seriousness, an important dimension of inclusion risks being overlooked. The promise of “Sabka Saath, Sabka Vikas” cannot be realised if persons with disabilities are not structurally included in the design and evaluation of emerging technologies.

Over the past year, I wrote to the Ministry of Electronics and Information Technology and to NITI Aayog when national AI policy discussions were underway. My intention was simple: to place before them the structural concerns surrounding disability bias in AI systems. I have not received substantive responses. I mention this not as complaint, but as indication that this dimension has not yet been treated with the seriousness it deserves.

The phrase “human in the loop” is often used in AI governance. It is a reassuring phrase. Machines, we are told, shall not decide alone. But one must ask quietly: whose humanity is present in that loop?

As Shakespeare wrote, “What is the city but the people?” If oversight committees and review boards do not include disability expertise, certain harms will remain invisible. Representation in governance is not ceremonial. It is epistemic.

India stands at a formative moment. Our AI ecosystem is still being shaped. The choices being made now will determine whether exclusion is prevented or automated. If accessibility standards are embedded by default in publicly funded AI systems; if Disability Impact Assessments become routine for high-stakes deployments; if datasets are audited honestly; if disability expertise is included in national AI councils and technical bodies; then India may demonstrate that technological leadership and social Justice are not adversaries.

They may strengthen one another.

If accessibility remains secondary, we shall eventually attempt repair. Repair is always more expensive than foresight.

Hon’ble Prime Minister, artificial intelligence may indeed represent a civilisational opportunity. It is also a moral test. Let Access be built into foundations, not attached later. Let Inclusion be structural, not symbolic. Let Equality be measurable in code, not only declared in speech.

I place these reflections before you with respect and with hope.

Jai Hind. 

Yours sincerely,

Nilesh Singit

TechnoAbleism in India’s AI Moment: Why Accessibility Is Not Enough

When artificial intelligence is built on narrow assumptions of the “normal” user, accessibility features alone cannot prevent exclusion embedded within the algorithm itself.

India’s present moment in artificial intelligence is often described in terms of innovation, opportunity, and national technological leadership. The India AI Impact Summit brings global attention to how artificial intelligence is shaping governance, development, and social transformation. 

Within these discussions, disability is increasingly visible through conversations on accessibility, assistive technologies, and digital inclusion. This attention is important. For many years, disability was largely absent from technology policy debates. Yet, a deeper issue remains insufficiently examined: accessibility alone does not ensure inclusion when artificial intelligence systems themselves are shaped by structural bias.

Accessibility and bias are frequently treated as interchangeable ideas. They are not the same. Accessibility determines whether a person with disability can use a system. Bias determines whether the system was designed with that person in mind at all. When systems are built around assumptions about a so-called normal user, accessible interfaces merely allow disabled persons to enter environments that continue to exclude them through their internal logic. The interface may be open; the opportunity may still be closed.

This structural problem becomes visible in the rapidly expanding practice often called ‘vibe coding’, where developers use generative AI tools to create websites and software through simple prompts. When an AI coding assistant is asked to generate a webpage, the default output usually prioritises visual layouts, mouse-dependent navigation, and animation-heavy design. Accessibility features such as semantic structure, keyboard navigation, or screen-reader compatibility rarely appear unless they are explicitly demanded. The system has learned that the ‘default’ user is non-disabled because that assumption dominates the data from which it learned. As these outputs are reproduced across applications and services, exclusion becomes quietly automated.

Bias also appears in the decision-making systems that increasingly shape employment, education, financial access and public services. Hiring systems that analyse speech, expression, or behavioural patterns may interpret disability-related communication styles as indicators of low confidence or low performance. Speech recognition tools often struggle with atypical speech patterns. Vision systems may fail to recognise assistive devices correctly. These outcomes are not isolated technical errors. They arise because disability is often missing from training datasets, testing environments and design teams. When disability is absent from the design stage, the system internalises non-disabled behaviour as the baseline expectation.

Another less visible dimension of bias emerges from the way artificial intelligence systems classify behaviour. Many systems are trained to recognise patterns associated with what developers consider efficient, confident or normal interaction. When human diversity falls outside those patterns, the system may interpret difference as error. Research in AI ethics repeatedly shows that classification models tend to perform poorly when training datasets do not adequately represent disabled users, leading to systematic misinterpretation of speech, movement or communication styles. 

These classification failures are rarely dramatic; they appear as small inaccuracies that accumulate over time. A speech interface that repeatedly fails to understand a user, an automated assessment tool that consistently undervalues atypical communication, or a recognition system that misidentifies assistive devices can gradually shape unequal access to opportunities. As these outcomes arise from technical assumptions rather than explicit discrimination, they often remain invisible in public debates, even as their effects are widely experienced.

These patterns together reflect what disability scholars describe as techno-ableism - the tendency of technological systems to appear empowering while quietly reinforcing assumptions that favour non-disabled ways of functioning. Technologies may expand participation on the surface, yet the intelligence embedded within them continues to treat disability as deviation rather than diversity. A person with disability may be able to access the interface, log into the system or navigate the platform, yet still face exclusion through hiring algorithms, recognition systems, or automated decision tools that were never designed around diverse bodies and minds. The experience is not exclusion from technology, but exclusion within technology itself.

Public discussions frequently present disability mainly through assistive innovation: tools that help blind users read text, applications that assist persons with mobility impairments or systems designed for specific accessibility functions. These innovations are valuable and necessary. However, when disability appears only in assistive contexts, it is positioned as a specialised technological niche rather than a structural dimension of all artificial intelligence systems. The mainstream design pipeline continues to assume the non-disabled user as the default, while disability inclusion becomes an add-on layer introduced later.

India currently stands at a formative stage in shaping its artificial intelligence ecosystem. As public digital infrastructure, governance platforms and automated service systems expand, the assumptions embedded in present design choices will influence social participation for decades. If accessibility becomes the only measure of inclusion, structural bias risks becoming embedded within the foundations of emerging technological systems. Inclusion then becomes symbolic rather than substantive: systems appear inclusive because they are accessible, yet continue to produce unequal outcomes.

From the standpoint of persons with disabilities, this distinction is deeply personal. Accessibility determines whether we can interact with the system. Bias determines whether the system recognises us as equal participants once we enter. Accessible platforms built upon biased intelligence do not remove barriers; they simply move the barrier from the interface to the algorithm.

As a disability rights practitioner working at the intersection of law, accessibility, and technology, I view the present expansion of AI discussions with cautious attention. Disability is finally visible in national technology conversations, yet the focus remains concentrated on accessibility demonstrations rather than the deeper question of structural bias. Artificial intelligence will increasingly shape employment, governance, education and everyday social participation. Whether these systems expand equality or quietly reproduce exclusion will depend not only on whether they are accessible, but also on whose experiences shape the data, assumptions, and decision rules within them.

Accessibility opens the door; fairness determines what happens after entry. Without confronting bias directly, technological progress risks creating a future that is digitally reachable yet socially unequal for many persons with disabilities. Many of the issues discussed here, including the structural relationship between accessibility and algorithmic bias, are explored in greater detail at The Bias Pipeline (https://thebiaspipeline.nileshsingit.org), where readers may engage with further analysis.

References

• India AI Impact Summit official information portal, Government of India.
• Coverage of summit accessibility and inclusion themes, Business Standard and related reporting.
• United Nations and global policy discussions on AI and disability inclusion.
• Nilesh Singit, The Bias Pipeline https://thebiaspipeline.nileshsingit.org/

(Nilesh Singit is a disability rights practitioner and accessibility strategist working at the intersection of law, governance, and AI inclusion. A Distinguished Research Fellow at the Centre for Disability Studies, NALSAR University of Law, he writes on accessibility, techno-ableism, and algorithmic bias at www.nileshsingit.org)

Moneylife.in
Published 17th Fevruary 202

MoneyLife.in

The Inclusivity Stack: Operationalising Disability Justice in India’s Sovereign AI Architecture

The Inclusivity Stack

Abstract

The Government of India’s strategic pivot towards "Sovereign Artificial Intelligence," crystallised in the ₹10,371 crore IndiaAI Mission, represents a watershed moment in the nation’s digital governance trajectory. As the state moves to integrate Artificial Intelligence (AI) into the foundational layer of Digital Public Infrastructure (DPI)—spanning healthcare, agriculture, and urban governance—it faces a critical architectural choice: to replicate the exclusionary patterns of the "medical model" of disability or to operationalise a "social model" that views accessibility as a non-negotiable constitutional guarantee. This report proposes the "Inclusivity Stack," a comprehensive governance and technical framework designed to embed disability justice into the IndiaAI ecosystem. Drawing extensively on the Supreme Court’s landmark judgment in Rajive Raturi v. Union of India (2024), the Rights of Persons with Disabilities (RPWD) Act, 2016, and global best practices such as the EU AI Act and Canada’s CAN-ASC-6.2 standard, this document outlines a roadmap for "fixing" the digital environment rather than the individual. It argues that the inclusion of India’s 26.8 million persons with disabilities is not merely a moral imperative but a prerequisite for the mathematical robustness, legal validity, and economic viability of India’s sovereign AI ambitions.

1. Introduction: The Sovereign AI Moment and the Risk of Digital Apartheid

1.1 The Genesis of the IndiaAI Mission

In March 2024, the Union Cabinet approved the IndiaAI Mission with a substantial budgetary outlay of ₹10,371.92 crore, signaling India’s intent to move from being a consumer of Western AI models to a creator of indigenous, sovereign AI capabilities.1 This mission is structurally organised around seven distinct pillars, designed to democratise access to computing power and data:

1. IndiaAI Compute Pillar: The deployment of over 38,000 Graphics Processing Units (GPUs) to provide affordable computational infrastructure to startups and researchers.2
2. IndiaAI Application Development Initiative: Targeting critical sectors such as healthcare, agriculture, and governance.2
3. AIKosh (Dataset Platform): A unified repository for high-quality, non-personal datasets to train indigenous models.3
4. IndiaAI Foundation Models (BharatGen): The development of "BharatGen," a sovereign Large Multimodal Model (LMM) trained on diverse Indic languages and datasets.4
5. IndiaAI FutureSkills: Aimed at expanding the AI talent pool through academic and vocational training.2
6. IndiaAI Startup Financing: Venture capital support for deep-tech AI startups.6
7. Safe & Trusted AI: A framework for responsible AI governance, including the establishment of the IndiaAI Safety Institute (AISI).7

While the mission’s scale is ambitious, aiming to catalyse a $1.7 trillion contribution to the Indian economy by 2035 2, its current architectural blueprint lacks explicit mechanisms to address the "digital apartheid" faced by Persons with Disabilities (PwDs). In a nation where internet access is already stratified by caste, class, and geography, the uncritical deployment of AI threatens to deepen these divides.

1.2 The "Data Void" and Algorithmic Exclusion

The exclusion of PwDs from the digital ecosystem is not accidental but systemic, often described as a "data void." Contemporary AI systems are predominantly trained on data that reflects the "normative" able-bodied user.

• Speech Recognition: Models trained on standard datasets often fail to recognise dysarthric speech (common in conditions like cerebral palsy) or the vocal patterns of the deaf community.8
• Computer Vision: Facial recognition systems, such as those used in the DigiYatra biometric boarding initiative, are frequently trained on datasets that lack representation of individuals with facial differences, Down syndrome, or palsy, leading to higher failure rates for these groups.9
• Natural Language Processing (NLP): Large Language Models (LLMs) often hallucinate "cures" or offer patronizing advice when users disclose a disability, reflecting the biases inherent in their training corpora.11

If the IndiaAI Mission proceeds without rectifying these voids, the "Sovereign AI" infrastructure will effectively become a "Sovereign Exclusion Mechanism," automating the denial of services to the most vulnerable citizens.

1.3 The Economic and Constitutional Imperative

The argument for inclusion is not solely humanitarian; it is economic and constitutional.

• Economic Cost: Excluding PwDs from the digital economy limits the potential GDP growth that the IndiaAI Mission seeks to unlock. Accessible technology enables workforce participation for millions who are currently marginalized.13
• Constitutional Mandate: The Supreme Court of India, in Rajive Raturi v. Union of India (2024), explicitly held that accessibility is a facet of the Fundamental Right to Life (Article 21) and Equality (Article 14).14 The Court mandated that the "State has an obligation to ensure that all steps... are taken" to ensure accessibility in "information, technology and entertainment".16

This report articulates the "Inclusivity Stack"—a layered framework to operationalise these legal and ethical mandates within the technical architecture of the IndiaAI Mission.

2. Theoretical Framework: De-Medicalising Artificial Intelligence

To build an inclusive AI architecture, policy-makers must first interrogate and dismantle the theoretical models of disability that currently inform—often subconsciously—the development of AI systems.

2.1 The Medical Model vs. The Social Model in Code

The development of AI has historically been rooted in the Medical Model of Disability. This model views disability as a "deficit," "pathology," or "aberration" residing within the individual that requires diagnosis, treatment, or cure.17

• In AI Development: This manifests in data annotation practices where non-normative behaviors (e.g., lack of eye contact in autism, stuttering in speech) are labeled as "errors," "noise," or "negative samples" to be filtered out.11
• The Consequence: An AI system trained on this model views a disabled user as a "broken" user. A proctoring algorithm flags a neurodivergent student’s movements as "suspicious" 20; a hiring algorithm ranks a candidate with a disability lower because their resume signals a "deviation" from the norm.12

In contrast, the Social Model of Disability, which underpins the UN Convention on the Rights of Persons with Disabilities (UNCRPD), posits that disability is constructed by societal barriers—physical, attitudinal, and digital—that prevent full participation.21

• In AI Development: Operationalising the Social Model requires shifting the focus from "fixing the user" to "fixing the system." It demands that AI interfaces be designed to accommodate diverse modes of interaction (e.g., supporting screen readers, switch devices, or sign language) as native features, not afterthoughts.19

2.2 Confronting "Technoableism"

The philosopher of technology Ashley Shew defines "Technoableism" as the pervasive belief that technology is the "solution" to disability, often characterizing disabled people as "problems" awaiting a technological "fix".23

• The Trap of "Inspiration Porn": Technoableism often manifests in high-profile projects—such as AI-powered exoskeletons or brain-computer interfaces—that garner media attention ("Inspiration Porn") while basic digital infrastructure remains inaccessible.24
• Policy Implication: For the IndiaAI Mission, avoiding technoableism means prioritizing boring but essential infrastructure (e.g., ensuring the CAPTCHA on the PM-Kisan portal is accessible to the blind) over flashy, high-tech "cures" that benefit a few. It means recognizing that disabled people are experts in their own lives and must lead the design process ("Nothing Without Us").23

3. The Legal Layer: From Guidelines to Non-Negotiable Standards

The foundation of the Inclusivity Stack is a robust legal framework that elevates accessibility from a voluntary "best practice" to a mandatory compliance requirement. The legal landscape in India has shifted dramatically in this regard following recent judicial interventions.

3.1 The Rajive Raturi Paradigm Shift (2024)

On November 8, 2024, the Supreme Court of India delivered a landmark judgment in Rajive Raturi v. Union of India.14 The case, originating from a PIL filed in 2005 by visually impaired activist Rajive Raturi, addressed the systemic failure of the state to implement accessibility mandates.

Key Judicial Findings:

1. Mandatory Rules: The Court accepted the argument presented by the NALSAR Centre for Disability Studies (CDS) that Rule 15 of the RPWD Rules, 2017, which prescribed accessibility standards, had historically been treated as directory (voluntary). The Court ruled that Rule 15, read with Sections 40, 44, and 45 of the RPWD Act, creates a mandatory compliance framework.15
2. Ultra Vires: The NALSAR report Finding Sizes for All argued that any interpretation of the rules that allows for "self-regulation" or "guidelines" is ultra vires (beyond the powers of) the parent Act, which mandates full accessibility.26
3. Digital Inclusion: While the case focused on physical access, the judgment explicitly stated that "accessibility to information, technology and entertainment is equally important".16 This extends the mandate to all digital platforms, AI interfaces, and electronic services provided by the state.

Implication for IndiaAI: Any AI system deployed by the government (e.g., BharatGen, DigiYatra) that fails to meet accessibility standards is now illegal and actionable under the RPWD Act.27

3.2 IS 17802: The Constitutional Standard for Code

The technical benchmark for this legal mandate is IS 17802: Accessibility for ICT Products and Services, notified by the Bureau of Indian Standards (BIS) in 2021/2022.28

• Part 1 (Requirements): Aligned with the global standard EN 301 549 and WCAG 2.1, this section specifies functional performance statements (e.g., "usage without vision," "usage with limited manipulation").29
• Part 2 (Conformance): Defines the testing methodologies to verify compliance.29
• Enforceability: Following the RPWD Amendment Rules 2023, IS 17802 is the statutory standard.30 This means that procurement of AI systems via the Government e-Marketplace (GeM) must strictly adhere to these standards.

3.3 Comparative Jurisprudence: The EU and Canada

India’s legal framework can be further strengthened by examining global best practices:

• Canada (CAN-ASC-6.2:2025): Canada has released the world’s first standard specifically for "Accessible and Equitable Artificial Intelligence Systems".31 It mandates that persons with disabilities be involved in the entire AI lifecycle—from data collection to model training—and introduces the concept of "Equitable AI" to prevent algorithmic discrimination.25
• European Union (EU AI Act): The EU AI Act (Article 5 & Recital 80) categorises AI systems that exploit vulnerabilities of persons with disabilities as "Unacceptable Risk" (prohibited). High-risk systems (e.g., education, employment) must demonstrate compliance with accessibility requirements by design.33

Recommendation: The IndiaAI Mission should adopt a framework analogous to CAN-ASC-6.2, mandating "lifecycle inclusion" for all projects funded under the Safe & Trusted AI pillar.

4. The Data Layer: Constructing the Disability Data Commons

Artificial Intelligence is, at its core, an engine of pattern recognition. If the "pattern" of disability is absent from the training data, the AI will inevitably treat disability as an anomaly. The AIKosh pillar of the IndiaAI Mission 2 must address this "data void" to ensure sovereign AI is truly inclusive.

4.1 The Representation Gap in Indic Datasets

Current datasets for Indian languages (e.g., those used to train BharatGen) suffer from a dual exclusion:

1. General Data Poverty: While initiatives like Bhashini are addressing the lack of Indic language data, there is a severe scarcity of data representing disabled speakers of these languages.8
2. Specific Modality Gaps:

• Dysarthric Speech: There are few, if any, large-scale datasets of dysarthric or atypical speech in languages like Hindi, Tamil, or Bengali. This renders voice-activated UPI payments or government helplines inaccessible to millions with motor or speech impairments.35
• Indian Sign Language (ISL): Despite being a scheduled language capability under the New Education Policy, ISL lacks a comprehensive, annotated video-to-text corpus required to build robust translation models.36

4.2 The "Outlier Advantage": Robustness via Inclusion

A compelling technical argument for inclusion is the concept of the "Outlier Advantage." Machine Learning (ML) research indicates that training models on "edge cases" or diverse outliers improves the mathematical robustness and generalisation capabilities of the model for all users.37

• Curriculum Learning: By including "difficult" samples—such as stuttered speech or heavily accented voice commands—during training, the model learns to identify the phonetic core of language rather than over-fitting to superficial acoustic features.39
• Universal Benefit: A speech model trained on dysarthric speech performs significantly better in noisy environments (e.g., a railway station) for non-disabled users. Thus, investing in disability data is an investment in the overall quality of India’s sovereign AI.40

4.3 Governance: Data Empowerment and Protection Architecture (DEPA)

To collect this sensitive data without exploitation, India must leverage its Data Empowerment and Protection Architecture (DEPA).41

• Disability Data Trusts: We propose the creation of "Disability Data Commons"—fiduciary structures where the disability community pools their data (e.g., voice samples, gait patterns).
• Consent Managers: Using DEPA’s electronic consent artifact, PwDs can grant temporary, purpose-limited access to their data for training "public good" models (like BharatGen) while retaining ownership.43 This shifts the dynamic from "data extraction" to "data empowerment."

5. The Model Layer: Indigenous Intelligence and Red Teaming

The IndiaAI Compute Pillar and BharatGen initiative provide the computational muscle to build indigenous foundational models.4 This sovereign control offers a unique opportunity to "bake in" inclusion at the model layer, rather than retrofitting it later.

5.1 BharatGen and the Constitutional AI Paradigm

BharatGen, India’s proposed sovereign Large Multimodal Model, is currently being trained on datasets spanning 22 Indian languages.5 To avoid the pitfalls of Western models, BharatGen must adopt a Constitutional AI approach.

• Constitution as the Objective Function: The model’s reward function (in Reinforcement Learning from Human Feedback - RLHF) should be aligned with the constitutional values of Article 14 (Equality) and Article 21 (Dignity).
• Anti-Ableist Fine-Tuning: The model must be penalised for generating "inspiration porn," "medical model" diagnoses for social queries, or ableist stereotypes. It should be rewarded for providing accessible, empowering, and rights-based responses.12

5.2 Accessibility Red Teaming

The Safe & Trusted AI pillar 7 must institutionalize Accessibility Red Teaming—a structured adversarial testing process focused on disability bias.45

• Methodology: Unlike security red teaming (which tests for hacks), accessibility red teaming tests for Allocative Harms (denial of resources) and Quality of Service Harms (degraded performance).46
• The Red Team: This requires recruiting "white-hat" testers with disabilities—blind screen-reader users, autistic testers, deaf signers—to identify failure modes that able-bodied developers cannot perceive.47
• NIST Alignment: The IndiaAI Safety Institute (AISI) should align its red teaming protocols with the NIST AI Risk Management Framework (RMF), which explicitly identifies "bias and discrimination" as top-tier risks.48

5.3 Case Study: The Bhashini Gap

Bhashini, the National Language Translation Mission, is a flagship success, offering text-to-text translation in 22 languages.36 However, it currently treats Indian Sign Language (ISL) as an outlier.

• The "23rd Language": ISL is a distinct natural language with its own grammar (Subject-Object-Verb), distinct from spoken Hindi or English.
• The Inclusivity Stack Requirement: The Bhashini mandate must be expanded to treat ISL as the "23rd language." This requires funding for specific transformer architectures capable of processing 3D spatial grammar (video-to-text and text-to-avatar), moving beyond simple gesture recognition.36

6. The Governance Layer: Operationalising Justice

Technology is deployed within a bureaucratic structure. The "Governance Layer" ensures that the technical capabilities of the Inclusivity Stack are enforced through administrative and financial levers.

6.1 Public Procurement as a Policy Lever (GeM)

The Government of India is the largest purchaser of technology in the country. The Government e-Marketplace (GeM) is the primary funnel for this procurement.51

• Mandatory Accessibility Check: GeM must integrate a mandatory "IS 17802 Compliance" field for all AI and software tenders. Vendors should be required to upload a Voluntary Product Accessibility Template (VPAT) or a certificate from the Standardisation Testing and Quality Certification (STQC) directorate.52
• Market Shaping: By disqualifying inaccessible products from government tenders, the state creates a powerful market incentive for private vendors to adopt "Universal Design" principles.

6.2 Disability Impact Assessments (DIA)

For high-stakes AI deployments (e.g., policing, welfare distribution, healthcare), the nodal agency must conduct a Disability Impact Assessment (DIA) prior to deployment.8

• Framework: A DIA evaluates:

1. Exclusion Risk: Does the system (e.g., DigiYatra) exclude specific disability phenotypes (e.g., facial paralysis)?
2. Disparate Impact: Is the error rate higher for PwDs than for the general population?
3. Accommodation Pathways: Is there a non-digital, human-in-the-loop alternative available?

• Accountability: The results of the DIA should be public, and high-risk findings should trigger a mandatory pause in deployment until mitigations are in place.54

6.3 Institutional Accountability: CCPD and CAG

• Chief Commissioner for Persons with Disabilities (CCPD): The CCPD should establish a specialized "Digital Rights Wing" equipped with technical experts to adjudicate complaints regarding digital accessibility and AI discrimination.30
• Comptroller and Auditor General (CAG): As the CAG moves towards auditing AI systems 9, it must include specific "inclusivity audit" parameters. An AI system that is inaccessible is an inefficient use of public funds and should be flagged in CAG reports.

7. Case Studies in Exclusion and Remediation

7.1 DigiYatra and Biometric Exclusion

The Problem: DigiYatra uses Facial Recognition Technology (FRT) for airport entry. While efficient for the majority, it poses severe exclusion risks for PwDs.

• Biometric Failure: Individuals with cerebral palsy (head tremors), facial disfigurements, or Down syndrome often experience higher "False Rejection Rates" in FRT systems.9
• Physical Barriers: The automated gates often close too quickly for wheelchair users or those with slow gaits, causing physical anxiety or harm.55

The Inclusivity Stack Solution:

1. Data: Retrain the FRT models using a "Disability Data Trust" dataset to improve recognition of diverse faces (The Outlier Advantage).
2. Process: Mandate a permanent, staffed "Accessibility Lane" that does not require biometric authentication. This lane should not be a "penalty box" (slower) but a "premium service" (faster) to ensure dignity.56

7.2 PM-Kisan and Algorithmic Gatekeeping

The Problem: Welfare schemes like PM-Kisan rely on Aadhaar-seeded databases and AI-driven fraud detection to disperse funds.57

• Exclusion: AI systems may flag "suspicious" patterns—such as a mismatch in biometrics due to manual labor or disability—leading to the automated suspension of benefits ("Digital Death").
• Lack of Recourse: The grievance redressal mechanisms are often digital-first (chatbots), which may themselves be inaccessible to the blind or illiterate.

The Inclusivity Stack Solution:

1. Human-in-the-Loop: Any AI decision to suspend benefits must be automatically escalated to a human review officer.
2. Accessible Redressal: A "Click-to-Call" feature or a dedicated, accessible web portal compliant with IS 17802 must be available for beneficiaries to challenge algorithmic decisions.25

8. Conclusion: The Road to a Viksit Bharat

India’s aspiration to become a Viksit Bharat (Developed Nation) by 2047 rests on its ability to harness the full potential of its human capital. Leaving 2.21% of the population (officially) or closer to 15% (globally estimated) behind in a "digital apartheid" is not just a violation of human rights; it is a strategic error that undermines the nation’s economic and social cohesion.

The Inclusivity Stack proposed in this report is not an optional add-on; it is the structural steel required to support the weight of a billion aspirations. By operationalising the legal mandates of Rajive Raturi, leveraging the "Outlier Advantage" in data, and enforcing accountability through governance, India can demonstrate that its "Sovereign AI" is truly sovereign—because it serves everyone.

As India builds the digital highways of the 21st century, it must ensure they have ramps. The cost of exclusion is high, but the return on inclusion—a resilient, robust, and just digital republic—is immeasurable.

Table 1: The Inclusivity Stack – Summary of Recommendations

Layer	Current State (The Problem)	The Inclusivity Stack (The Solution)	Key Lever / Standard
Legal	Voluntary guidelines; "Soft Law" approach.	Mandatory Compliance; Non-negotiable standards.	Rajive Raturi Judgment; IS 17802; RPWD Act S.40.
Data	Data Voids; Medical Model annotation; Exclusion of outliers.	Disability Data Commons; Social Model annotation; Outlier Advantage.	AIKosh; DEPA; Data Trusts.
Model	Bias; Hallucinations; "Inspiration Porn"; Ignored edge cases.	Constitutional AI; Accessibility Red Teaming; Anti-ableist RLHF.	BharatGen; NIST RMF; AISI.
Interface	Inaccessible CAPTCHAs; Lack of ISL; Voice-only or Text-only silos.	Universal Design; Multi-modal access (ISL, text, voice, switch).	Bhashini (ISL Mission); CAN-ASC-6.2.
Governance	Self-regulation; Lack of audits; Technoableism.	Disability Impact Assessments (DIA); Third-party Audits; Procurement mandates.	GeM; CCPD; CAG Audits.

References & Citation Key

• Legal: Rajive Raturi v. Union of India (2024) 14; RPWD Act 2016 27; IS 17802.28
• Policy: IndiaAI Mission 1; NITI Aayog AI Strategy 7; EU AI Act 33; CAN-ASC-6.2.25
• Theory: Technoableism (Ashley Shew) 23; Social vs. Medical Model 18; Algorithmic Harms.46
• Technical: Red Teaming 45; Bias in datasets 8; Bhashini 36; Outlier Advantage.37
• Governance: GeM Procurement 51; DEPA & Data Trusts.41

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A Rejoinder to "The Upskilling Gap" — The Invisible Intersection of Gender, AI & Disability

 To:

Ms. Shravani Prakash, Ms. Tanu M. Goyal, and Ms. Chellsea Lauhka
c/o The Hindu, Chennai / Delhi, India

Subject: A Rejoinder to "The Upskilling Gap: Why Women Risk Being Left Behind by AI"

Dear Authors,

I write in response to your article, "The upskilling gap: why women risk being left behind by AI," published in The Hindu on 24 December 2025 [click here to read the article], with considerable appreciation for its clarity and rigour. Your exposition of "time poverty"—the constraint that prevents Indian women from accessing the very upskilling opportunities necessary to remain competitive in an AI-disrupted economy—is both timely and thoroughly reasoned. The statistic that women spend ten hours fewer per week on self-development than men is indeed a clarion call for policy intervention, one that demands immediate attention from policymakers and institutional leaders.

Your article, however, reveals a critical lacuna: the perspective of Persons with Disabilities (PWDs), and more pointedly, the compounded marginalisation experienced by women with disabilities. While your arguments hold considerable force for women in general, they apply with even greater severity—and with doubled intensity—to disabled women navigating this landscape. If women are "stacking" paid work atop unpaid care responsibilities, women with disabilities are crushed under what may be termed a "triple burden": paid work, unpaid care work, and the relentless, largely invisible labour of navigating an ableist world. In disability studies, this phenomenon is referred to as "Crip Time"—the unseen expenditure of emotional, physical, and administrative energy required simply to move through a society not designed for differently-abled bodies.

1. The "Time Tax" and Crip Time: A Compounded Deficit

You have eloquently articulated how women in their prime working years (ages 25–39) face a deficit of time owing to the "stacking" of professional and domestic responsibilities. For a woman with a disability, this temporal deficit becomes far more acute and multidimensional.

Consider the following invisible labour burdens:

Administrative and Bureaucratic Labour. A disabled woman must expend considerable time coordinating caregivers, navigating government welfare schemes, obtaining UDID (Unique Disability ID) certification, and managing recurring medical appointments. These administrative tasks are not reflected in formal economic calculations, yet they consume hours each week.

Navigation Labour. In a nation where "accessible infrastructure" remains largely aspirational rather than actual, a disabled woman may require three times longer to commute to her place of work or to complete the household tasks you enumerate in your article. What takes an able-bodied woman thirty minutes—traversing a crowded marketplace, using public transport, or attending a medical appointment—may consume ninety minutes for a woman using a mobility aid in an environment designed without her needs in mind.

Emotional Labour. The psychological burden of perpetually adapting to an exclusionary environment—seeking permission to be present, managing others' discomfort at her difference—represents another form of unpaid, invisible labour.

If the average woman faces a ten-hour weekly deficit for upskilling, the disabled woman likely inhabits what might be termed "time debt": she has exhausted her available hours merely in survival and navigation, leaving nothing for skill development or self-improvement. She is not merely "time poor"; she exists in a state of temporal deficit.

2. The Trap of Technoableism: When Technology Becomes the Problem

Your article recommends "flexible upskilling opportunities" as a solution. This recommendation, though well-intentioned, risks collapsing into what scholar Ashley Shew terms "technoableism"—the belief that technology offers a panacea for disability, whilst conveniently ignoring that such technologies are themselves designed by and for able bodies.

The Inaccessibility of "Flexible" Learning. Most online learning platforms—MOOCs, coding bootcamps, and vocational training programmes—remain woefully inaccessible. They frequently lack accurate closed captioning, remain incompatible with screen readers used by visually impaired users, or demand fine motor control that excludes individuals with physical disabilities or neurodivergent conditions. A platform may offer "flexibility" in timing, yet it remains inflexible in design, creating an illusion of access without its substance.

The Burden of Adaptation Falls on the Disabled Person. Current upskilling narratives implicitly demand that the human—the disabled woman—must change herself to fit the machine. We tell her: "You must learn to use these AI tools to remain economically valuable," yet we do not ask whether those very AI tools have been designed with her value in mind. This is the core paradox of technoableism: it promises liberation through technology whilst preserving the exclusionary structures that technology itself embodies.

3. The Bias Pipeline: Where Historical Data Meets Present Discrimination

Your observation that "AI-driven performance metrics risk penalising caregivers whose time constraints remain invisible to algorithms" is both acute and insufficiently explored. Let us examine this with greater precision.

The Hiring Algorithm and the "Employment Gap." Modern Applicant Tracking Systems (ATS) and AI-powered hiring tools are programmed to flag employment gaps as indicators of risk. Consider how these gaps are interpreted differently:

• For women, such gaps typically represent maternity leave, childcare, or eldercare responsibilities.

• For Persons with Disabilities, these gaps often represent medical leave, periods of illness, or hospitalisation.

• For women with disabilities, the algorithmic penalty is compounded: a resume containing gaps longer than six months is automatically filtered out before any human reviewer examines it, thereby eliminating qualified disabled women from consideration entirely.

Research audits have documented this discrimination. In one verified case, hiring algorithms flagged minority candidates disproportionately as needing human review because such candidates—inhibited by systemic bias in how they were evaluated—tended to give shorter responses during video interviews, which the algorithm interpreted as "low engagement".​

Video Interviewing Software and Facial Analysis. Until its removal in January 2021, the video interviewing platform HireVue employed facial analysis to assess candidates' suitability—evaluating eye contact, facial expressions, and speech patterns as proxies for "employability" and honesty. This system exemplified technoableism in its purest form:

• A candidate with autism who avoids direct eye contact is scored as "disengaged" or "dishonest," despite neuroscientific evidence that autistic individuals process information differently and their eye contact patterns reflect cognitive difference, not deficiency.

• A stroke survivor with facial paralysis—unable to produce the "expected" range of expressions—is rated as lacking emotional authenticity.

• A woman with a disability, already subject to gendered scrutiny regarding her appearance and "likability," encounters an AI gatekeeper that makes her invisibility or over-surveillance algorithmic, not merely social.

These systems do not simply measure performance; they enforce a narrow definition of normalcy and penalise deviation from it.

4. Verified Examples: The "Double Glitch" in Action

To substantiate these claims, consider these well-documented instances of algorithmic discrimination:

Speech Recognition and Dysarthria. Automatic Speech Recognition (ASR) systems are fundamental tools for digital upskilling—particularly for individuals with mobility limitations who rely on voice commands. Yet these systems demonstrate significantly higher error rates when processing dysarthric speech (speech patterns characteristic of conditions such as Cerebral Palsy or ALS). Recent research quantifies this disparity:

• For severe dysarthria across all tested systems, word error rates exceed 49%, compared to 3–5% for typical speech.​

• Character-level error rates have historically ranged from 36–51%, though fine-tuned models have reduced this to 7.3%.​

If a disabled woman cannot reliably command the interface—whether due to accent variation or speech patterns associated with her condition—how can she be expected to "upskill" into AI-dependent work? The platform itself becomes a barrier.

Facial Recognition and the Intersection of Race and Gender. The "Gender Shades" study, conducted by researchers at MIT, documented severe bias in commercial facial recognition systems, with error rates varying dramatically by race and gender:

• Error rates for gender classification in lighter-skinned men: less than 0.8%

• Error rates for gender classification in darker-skinned women: 20.8% to 34.7%​

Amazon Rekognition similarly misclassified 31 percent of darker-skinned women. For a disabled woman of colour seeking employment or accessing digital services, facial recognition systems compound her marginalisation: she is simultaneously rendered invisible (failed detection) or hyper-surveilled (flagged as suspicious).​

The Absence of Disability-Disaggregated Data. Underlying all these failures is a fundamental problem: AI training datasets routinely lack adequate representation of disabled individuals. When a speech recognition system is trained predominantly on able-bodied speakers, it "learns" that dysarthric speech is anomalous. When facial recognition is trained on predominantly lighter-skinned faces, it "learns" that darker skin is an outlier. Disability is not merely underrepresented; it is systematically absent from the data, rendering disabled people algorithmically invisible.

5. Toward Inclusive Policy: Dismantling the Bias Pipeline

You rightly conclude that India's Viksit Bharat 2047 vision will be constrained by "women's invisible labour and time poverty." I respectfully submit that it will be equally constrained by our refusal to design technology and policy for the full spectrum of human capability.

True empowerment cannot mean simply "adding jobs," as your article notes. Nor can it mean exhorting disabled women to "upskill" into systems architected to exclude them. Rather, it requires three concrete interventions:

First, Inclusive Data Collection. Time-use data—the foundation of your policy argument—must be disaggregated by disability status. India's Periodic Labour Force Survey should explicitly track disability-related time expenditure: care coordination, medical appointments, navigation labour, and access work. Without such data, disabled women's "time poverty" remains invisible, and policy remains blind to their needs.

Second, Accessibility by Design, Not Retrofit. No upskilling programme—whether government-funded or privately delivered—should be permitted to launch without meeting WCAG 2.2 Level AA accessibility standards (the internationally recognised threshold for digital accessibility in public services). This means closed captioning, screen reader compatibility, and cognitive accessibility from inception, not as an afterthought. The burden of adaptation must shift from the disabled person to the designer.​

Third, Mandatory Algorithmic Audits for Intersectional Bias. Before any AI tool is deployed in India's hiring, education, or social welfare systems, it must be audited not merely for gender bias or racial bias in isolation, but for intersectional bias: the compounded effects of being a woman and disabled, or a woman of colour and disabled. Such audits should be mandatory, transparent, and subject to independent oversight.

Conclusion: A Truly Viksit Bharat

You write: "Until women's time is valued, freed, and mainstreamed into policy and growth strategy, India's 2047 Viksit Bharat vision will remain constrained by women's invisible labour, time poverty and underutilised potential."

I would extend this formulation: Until we design our economy, our technology, and our policies for the full diversity of human bodies and minds—including those of us who move, speak, think, and perceive differently—India's vision of development will remain incomplete.

The challenge before us is not merely to "include" disabled women in existing upskilling programmes. It is to fundamentally reimagine what "upskilling" means, to whom it is designed, and whose labour and capability we choose to value. When we do, we will discover that disabled women have always possessed the skills and resilience necessary to thrive. Our task is simply to remove the barriers we have constructed.

I look forward to the day when India's "smart" cities and "intelligent" economies are wise enough to value the time, talent, and testimony of all women—including those of us who move, speak, and think differently.

Yours faithfully,

Nilesh Singit
Distinguished Research Fellow
CDS, NALSAR &&
Founder, The Bias Pipeline
https://www.nileshsingit.org/