Respected Sir / Madam,
We respectfully submit the enclosed advisory prepared by EMA regarding the Draft Gazette Notification concerning Non-Negotiable Accessibility Standards in the Built Environment.
EMA welcomes this Gazette as a landmark step toward fulfilling the mandate of the Supreme Court and statutory obligations under the Rights of Persons with Disabilities Act, 2016. Recognizing accessibility as "non-negotiable" marks a significant shift in national policy.
Based on extensive fieldwork, audits, and post-occupancy evaluations, our advisory highlights that accessibility failures in India stem primarily from a lack of enforceable systems rather than an absence of standards. Consequently, the enclosed document focuses on clarity, accountability, and practical mechanisms to ensure the Gazette's intent results in measurable outcomes.
The advisory:
- Identifies systemic gaps leading to routine non-compliance.
- Recommends clear, verifiable requirements to replace descriptive clauses.
- Emphasizes the continuity of accessible routes as a mandatory pass-fail condition.
- Proposes standardized audit competence, evidence requirements, and liability frameworks.
- Recommends adopting AI-based building plan scrutiny for consistency and transparency.
Annexure II provides a clause-by-clause technical reference on the Gazette Schedule (Part A and Part B), including suggested text for direct incorporation.
EMA submits this advisory as constructive support and stands ready to assist the Ministry with further consultations, technical reviews, or pilot initiatives. We hope these inputs assist MoSJE in finalizing a Gazette that is both progressive and effective in practice.
Best regards,
| Anubha Singhal |
| Principal Architect, Director |
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