visually impaired employees, bank promotion policy, RPwD Act, discrimination, State Bank of India, Delhi High Court, reasonable accommodation, career progression, persons with disabilities
 29 May, 2026
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Visually Impaired Bank Employees Welfare Association Versus State Bank Of India And Ors.

  Delhi High Court W.P.(C) 6027/2025
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Case Background

As per case facts, the Visually Impaired Bank Employees Welfare Association challenged the promotion policy of the State Bank of India for Senior Management Grade Scale IV and V posts. ...

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Document Text Version

W.P.(C) 6027/2025 Page 1 of 28

* IN THE HIGH COURT OF DELHI AT NEW DELHI

Judgment Reserved on: 02.04.2026

% Judgment Delivered on: 29.05.2026

+ W.P.(C) 6027/2025

VISUALLY IMPAIRED BANK EMPLOYEES WELFARE

ASSOCIATION .....Petitioner

versus

STATE BANK OF INDIA AND ORS. .....Respondents

Advocates who appeared in this case

For the Petitioner: Mr. Rahul Bajaj and Ms. Sarah,

Advocates.

For the Respondents: Mr. Santosh Rout, S.C. with Mr.

Divyam Nandrajog, Mr. Dhruv

Kaushik, Advocates for R-1.

Mr. Nishant Gautam, CGSC with Ms.

Kavya Shukla, Mr. Vineet Negi, Mr.

Naman Sharma and Ms. Theresa

Shiji, Advocates for R-2 to R-4.

CORAM:

HON'BLE THE CHIEF JUSTICE

HON'BLE MR. JUSTICE TEJAS KARIA

JUDGMENT

TEJAS KARIA, J

1.The present Writ Petition has been filed by the Visually Impaired

Bank Employees Welfare Association under Article 226 of the Constitution

of India, 1950 (“Constitution”) challenging the promotion policy

W.P.(C) 6027/2025 Page 2 of 28

(“Impugned Policy”) of the State Bank of India, Respondent No. 1 for the

post of Senior Management Grade Scale (“SMGS”) - IV and V, which

mandates prior experience as a Branch Manager or in assignments related to

credit / trade finance and foreign exchange, the roles that are inherently

inaccessible to visually impaired officers due to the absence of assistive

technology and the visual nature of the tasks involved seeking the following

prayers:

“A. A writ, order or direction declaring the Impugned Requirement

in the Promotion Policy of the State Bank of India, for promotion

from Scale III MMGS III to SMGS IV and SMGS IV to V in the

respondent No. 1 bank as unconstitutional.

B. Issuance of directions to the respondent No. 1 to evolve a suitable

mechanism for promoting visually impaired bank employees from

MMGS III to SMGS IV and SMGS IV to V in the respondent No. 1

bank.

C. Directing the respondent No. 1 to comply with the

recommendation of the CCPD dated 01.12.2022.

D. In the alternative to prayer A-C, a direction to the Respondent

No. 1 bank to issue appropriate instructions exempting persons with

visual disabilities from the Impugned Requirement.

E. Direct Respondent No. 1 bank to consider the promotion of blind

officers who lost four opportunities for promotion to Scale IV

(2021–2025) with retrospective effect.”

2.The Petitioner comprises of over 600 members with visual disabilities

employed in various banks across India. The Petitioner contends that the

Impugned Policy amounts to direct and indirect discrimination under the

Rights of Persons with Disabilities Act, 2016 (“RPwD Act”) and the

Constitution. Despite a clear order by the Chief Commissioner for Persons

with Disabilities (“CCPD”) on 01.12.2022 recommending reasonable

W.P.(C) 6027/2025 Page 3 of 28

accommodations and policy modifications, Respondent No. 1 has refused to

comply, which has resulted in the systemic exclusion of visually impaired

officers from promotional avenues.

3.The Petitioner seeks to demonstrate in the present Petition that the

functions of a Branch Manager and a Credit Officer cannot be independently

discharged by visually impaired employees, as these roles entail tasks

involving visual verification, physical inspection, and the assumption of

legal responsibilities, which cannot be delegated to sighted colleagues, being

core and essential functions of the posts concerned.

4.It is further contended that the rigid insistence upon prior discharge of

these roles as asine qua nonfor promotion, despite structural impediments

such as the inaccessibility of hard-copy documentation, the absence of

screen reader-compatible systems, and the lack of an appropriate risk-

allocation mechanism to address personal liability, forms the gravamen of

challenge in the present Petition.

5.Accordingly, the present Writ Petition challenges Clause D of the

Impugned Policy insofar as it mandates service as a Branch Manager or in

Credit / Trade Finance / Forex / Measurable Position assignments as a

precondition for promotion, on the ground that the said requirement is

unconstitutional and contrary to the provisions of the RPwD Act.

SUBMISSIONS ON BEHALF OF THE PETITIONER

6.The learned Counsel for the Petitioner submitted that:

6.1.The visually disabled bank employees perform their functions in

the following ways:

a.Utilisation of Screen Reader Technology: A visually impaired

bank officer can effectively perform their duties using a

W.P.(C) 6027/2025 Page 4 of 28

screen-reader software that converts on-screen text into speech.

When documents and materials are provided in an accessible

format, the officer can independently access and process

information. The software further enables independent typing

and navigation on a computer system.

b.Accessibility of Documents and IT-Based Solutions: To be

compatible with screen-readers, documents must be in an

OCR-enabled, machine-readable format. Furthermore, any IT-

based banking solutions, including mobile phone applications

and websites, must comply with the Government of India

accessibility guidelines and BIS Standard IS 17802 (Parts 1 &

2) to ensure full usability for visually impaired employees.

c.Communication and Presentation Skills: Bank officers with

visual disabilities, like their non-disabled counterparts, can

develop strong communication and presentation skills,

enabling them to perform roles requiring client interaction,

report generation, and other essential workplace functions.

6.2.The Petitioner has 37 members employed with Respondent No. 1

in Scale-III. These officers, including persons with low vision and

visual impairment, discharge a range of functions in areas such as

marketing, loan recovery, digital banking, cross-selling, financial

inclusion, and training.

6.3.Under the Impugned Policy, the following preconditions are

required to be satisfied for the promotion of a bank officer from

Scale-III to Scale-IV and from Scale-IV to Scale-V (“Impugned

Requirements”):

W.P.(C) 6027/2025 Page 5 of 28

Promotion to MMGS

III to SMGS IV

Promotion to SMGS

IV to SMGS V

Mandatory

assignment

Two years’ service as

Branch Manager in Scale-

II / III incumbency

branch(es). OR 2 years’

service in an assignment

related to Credit or Trade

Finance or Forex

(Budgetary / Measurable

positions) across all

Verticals viz. CAG /

CCG / IBG / SARG /

R&DB in MMGSII / III

grades.

Minimum of 4 years

of Branch Experience

[excluding probation

period in any vertical

(CAG/ CCG/IBG@/

SARG/ R&DB)] out

of which minimum 2

years as Branch

Manager in Scale- III/

IV incumbency

branch(es) in R&DB

Vertical.

Weightage

for Branch

experience

4 years or more in any

vertical: 5 >=3 years <4

years in any vertical: 3

7 years or more in

any vertical: 5 >=6

years <7 years in any

vertical: 3

6.4.The Impugned Policy further provides for the award of 5 marks in

the final promotion merit list for two years of branch experience.

This is not a mere procedural stipulation, but a material component

of the promotional framework from which many visually impaired

officers stand systematically excluded. Notwithstanding that the

Impugned Policy has remained in force for over three years,

certain blind officers employed with Respondent No. 1 have yet to

be posted to branches, thereby rendering them ineligible to secure

the said 5 marks.

6.5.The failure to assign blind officers to branch postings, despite their

requests and eligibility, demonstrates an arbitrary and

unreasonable application of the Impugned Policy, thereby

W.P.(C) 6027/2025 Page 6 of 28

rendering it inaccessible to persons with visual disabilities and

resulting in a denial of equal opportunity, reflective of systemic

discrimination.

6.6.In contradistinction, other Public Sector Banks have extended

reasonable exemptions and accommodations to facilitate the career

progression of blind officers. By way of illustration, Mr. Ahul

Gambhir, Ms. Nikita Raut and Mr. Ashwini Agarwal, who are

members of the Petitioner, are presently serving as Bank Managers

in other Public Sector Banks, including Punjab National Bank,

which have adopted inclusive practices in conformity with the

rights of persons with disabilities (“PwDs”).

6.7.The responsibilities, nature of task and availability of assistive

technology for the roles of Bank Manager and Credit Officer are as

follows:

a.Branch Manager responsibilities:

S.

No.

Responsibility Nature of task Assistive

Technology

1 Takeover of

branch document

All documents in hard

copy including

verifying signatures

No assistive

technology

2 Inspection of

borrower units

Inspection of location

of unit, activity carried

on, type and quantity of

stocks available etc.

No assistive

technology

available

3 Perfection of

security (Creation

of mortgage,

hypothecation,

lien etc.)

Involves authenticating

originality of title

deeds of properties

offered as security,

creation of

hypothecation charges

etc.

No assistive

technology

available to

authenticate

originality of title

deeds.

W.P.(C) 6027/2025 Page 7 of 28

4 Monitoring of

staff entering and

exiting strong

room (containing

cash and jewelry)

Constant monitoring of

CCTV cameras and

visiting strong room

No assistive

technology

available

5 Tallying of gold

loan bags

Involves ensuring that

tally with number of

loans given against the

number of gold loan

bags

No assistive

technology

available

6 Sanction of loans

& advances

Involves perusing

information in KYC,

tax returns, appraisal

form, legal opinions

and valuations of

properties, pre-sanction

report etc.

No assistive

technology to

peruse hard copies

involving

financials, title

deeds including

manuscripts,

signatures etc.

7 Physical safety of

branch office

Ensuring presence of

fire extinguishers,

renewal of gun licenses

etc.

No assistive

technology

8 Financial

transactions &

customer

information

amendments

Involves passing of

cheques and customer’s

personal information

amendments like

change of mobile

number. To be done

only after verifying

customer request

including tallying

signature.

No assistive

technology

b.Credit Officer responsibilities:

S.

No.

Responsibility Nature of task Assistive

Technology

1 Pre-sanction

survey

Inspecting business

unit, establishing its

location, unit being

No assistive

technology

W.P.(C) 6027/2025 Page 8 of 28

carried on, stock

present in the unit,

machinery available,

borrower’s residence

etc.

2 Inspection of

collateral

security

Perusing title deeds of

property (including

manuscripts), verifying

originality of such title

deeds, inspecting

location of property

offered as collateral

etc.

No assistive

technology

3 Appraisal Perusing tax returns

and other business

documents in hard

copies, establishing

their originality

including verifying

signatures

No assistive

technology

4 Documentation

and creation of

charge

Includes ensuring

filling up of documents

and obtaining borrower

signatures, creation of

charge which includes

establishing originality

of documents etc.

No assistive

technology

5 Post sanction

survey and loan

maintenance

Includes verifying

originality of asset

purchased out of bank

finance like machine,

vehicle, stock, factory

etc. periodical

inspection of business

units to verify

continuity of business

activity, stock

purchased, presence of

machinery etc.

No assistive

technology

W.P.(C) 6027/2025 Page 9 of 28

6 Financial

transactions

Includes customer

handwritten cheques,

transfer forms etc.

including tallying

customer signatures

No assistive

technology

6.8.The bank officers with visual disabilities are unable to perform the

role of Branch Manager or assignments related to credit / trade

finance due to the following reasons:

a.Visual nature of tasks: The roles contain too many things that

have to be carried out by perusing the physical environment,

such as identifying people, identifying locations of properties,

business activity, stocks, monitoring CCTV footage, etc.

Currently, the bank provides no assistive technology that

enables a blind person to do it.

b.Financial sanctions and transactions: All loan sanctions and

passing of financial transactions are done in SBI are

mandatorily in hard copies. Since the accuracy of information

and tallying customer signatures are indispensable, OCR

technology also does not suffice.

c.Human assistance: Since all the tasks involve financial risk and

are fraud-prone, human assistance cannot be simply relied

upon. The bank does not have a policy on staff accountability,

and neither the person who reads out information nor the

visually challenged manager who acts upon such information

is held accountable when things go wrong.

W.P.(C) 6027/2025 Page 10 of 28

6.9.A blind officer cannot reasonably be expected to sign the “Branch

Manager Monthly Certificate”, which every Branch Manager is

required to submit certifying compliance with diverse banking

regulations, for which the officer bears both direct and vicarious

liability, solely on the basis of oral inputs furnished by an assistant,

particularly when legal accountability for any false certification

cannot be clearly attributed either to the blind officer or to the

assisting personnel.

6.10.Officers in Scale-III and Scale-IV are capable of discharging a

broad spectrum of functions across multiple verticals, including

customer service, grievance redressal, digital banking, information

technology systems, marketing, and operations. Such roles

encompass responsibilities in backend operations, digital

transformation, product management, and service delivery, and

may involve,inter alia, the advancement of digital initiatives,

management of UPI and e-commerce platforms, support for card

operations, and the facilitation of cross-selling and marketing

strategies.

6.11.It is pertinent to note that Public Sector Banks across the country

have neither identified the posts of Branch Manager and Credit

Officer as suitable for visually impaired persons nor deployed

visually impaired officers in such roles. As per SBI e-circular

dated 10.02.2012, 33 posts have been identified as suitable for

officers with low vision and 17 posts for officers with visual

impairment; however, neither the post of Credit Officer nor that of

Branch Manager forms part of the identified cadre.

W.P.(C) 6027/2025 Page 11 of 28

6.12.By Office Memorandum, the Ministry of Finance, Department of

Financial Services, directed Ministries, Departments, and Central

Public Sector Enterprises to identify posts that can be readily

performed by PwDs, particularly in Groups B, C, and D, and to

ensure, as far as possible, that such officers are permitted to

continue in those roles. The said guidelines further emphasise that

where a person with disability can perform the same duties as

others efficiently, such person ought not to be restricted or

confined to specified roles. The Impugned Policy, however,

disregards this directive and erects systemic and artificial barriers

to the promotion of visually impaired officers who are otherwise

fully capable of discharging their duties.

6.13.The Petitioner had preferred a complaint before the Chief

Commissioner for Persons with Disabilities (“CCPD”), impugning

the discriminatory effect of the Impugned Policy upon visually

impaired employees. In its observations, the CCPD noted that the

RPwD Act guarantees equality in employment and that no policy

may be framed in a manner that discriminates against PwDs. The

CCPD further found that the requirements of branch experience,

mandatory Branch Manager assignments, and credit assignments

in the promotion process effectively exclude visually impaired

employees, since such roles entail visual verification and cannot be

independently discharged by them. Consequently, such employees

are placed either in a position of dependence upon assistance from

others or are altogether excluded from consideration for promotion

to SMGS-IV and SMGS-V. The CCPD accordingly recommended

W.P.(C) 6027/2025 Page 12 of 28

that the Impugned Policy be modified to provide reasonable

accommodation and ensure equal opportunity for visually impaired

employees. It further suggested that equivalent weightage be

accorded for functions capable of being performed independently

and without undue risk, that alternative roles suited to visually

impaired employees be considered for promotion evaluation in lieu

of branch experience and credit assignments, and that the overall

promotion policy be reviewed so as to eliminate exclusionary

provisions and secure compliance with the principles of equal

opportunity.

6.14.Respondent No. 1, in reply to the order issued by the CCPD, stated

that the Impugned Policy is consistent with the RPwD Act and

does not contravene any legal provision. Respondent No. 1

contended that it had already implemented exemptions for PwDs

in terms of Government directives, including exemption from

mandatory rural and semi-urban assignments. It was, however,

maintained that other mandatory assignments, including branch

postings, are essential for operational and managerial exposure and

are not discriminatory in nature. Respondent No. 1 further asserted

that dispensing with such requirements would serve neither the

interests of the institution nor those of the employees.

Consequently, Respondent No. 1 expressed its inability to

implement the recommendations of the CCPD and requested that

its compliance report be taken on record.

6.15.Pursuant to the aforesaid reply of Respondent No. 1, the Petitioner

submitted a representation dated 15.05.2023 to the Ministry of

W.P.(C) 6027/2025 Page 13 of 28

Finance reiterating the grievance raised before the CCPD and

asserting that Respondent No. 1 was declining to comply with the

aforesaid recommendations on specious grounds.

6.16.The mandatory insistence upon the Impugned Requirements

amounts to direct discrimination against the visually impaired

employees of Respondent No. 1, inasmuch as the roles

contemplated thereunder involve functions such as cash handling,

physical verification of documents, and surveillance oversight,

which cannot be effectively performed by persons with visual

disabilities. By imposing such requirements upon visually

impaired employees, Respondent No. 1 has created an inherently

unequal standard by placing them on par with employees who do

not suffer from visual disabilities. As a consequence, visually

impaired employees are rendered unable to qualify for promotion,

thereby resulting in career stagnation and exclusion from higher

posts.

6.17.There exists no objective justification for such differential

treatment, which is violative of the right to equality guaranteed

under Article 14 of the Constitution. The principle of reasonable

accommodation mandates the creation of alternative pathways for

visually impaired employees so as to ensure that their career

progression is not unjustly impeded.

6.18.The refusal of Respondent No. 1 to comply with the order of the

CCPD, absent any cogent justification, demonstrates a disregard

for recommendations intended to secure equal opportunity.

Visually impaired employees are thereby confronted with a

W.P.(C) 6027/2025 Page 14 of 28

“Hobson’s Choice”, namely, either to accept roles for which they

are ill-equipped or insufficiently supported, or to face stagnation at

Scale-III and the attendant humiliation of being superseded. This

results in an untenable situation in which the career advancement

of visually impaired employees is made conditional upon assuming

responsibilities that aggravate the challenges arising from their

disability.

6.19.The Supreme Court has, inState of Kerala v. Leesamma Joseph

2021 SCC OnLine SC 435, held that functional requirements can

become ruse for denial of promotion to the PwDs, which results in

frustration and stagnation. It was further held that to ensure that the

disability does not become a reason for denial of promotion, it is

necessary to evolve a method to address the issue of stagnation of

the PwDs.

6.20.Under the first proviso to Section 34(1) of the RPwD Act, read

with the Office Memorandum dated 17.05.2022 issued by the

DoPT, Ministry of Social Justice and Empowerment, Government

of India, PwDs are entitled to reservation in promotion. It is

contended that the impediments created by the Impugned

Requirements render the said entitlement illusory insofar as the

members of the Petitioner are concerned.

6.21.The members of the Petitioner are presently discharging a wide

range of roles and responsibilities within Respondent No. 1 and

that there exists no justifiable reason to conclude that they are

incapable of performing analogous functions at the higher levels of

Scale-IV and Scale-V.

W.P.(C) 6027/2025 Page 15 of 28

6.22.Respondent No. 1 has neither demonstrated the manner in which a

visually impaired person may effectively discharge the full range

of functions of a Branch Manager or Credit Officer, nor furnished

any cogent justification for its refusal to implement the

recommendations of the CCPD.

6.23.In view of the above, the Petitioner has prayed for granting the

prayers as sought in the present Petition.

SUBMISSIONS ON BEHALF OF THE RESPONDENTS

7.The learned Counsel for Respondent No. 1 submitted that:

7.1.The present Petition is not maintainable, as it does not conform to

the Delhi High Court (Public Interest Litigation) Rules, 2010

(“PIL Rules”), inasmuch as the Petitioner lacks the requisite locus

and has failed to place on record adequate authority for the

institution of the present proceedings. Rule 7(ii) of the PIL Rules

expressly excludes service matters from the purview of public

interest litigation. Since the present Petition directly concerns the

promotional criteria applicable to the employees of Respondent

No. 1, it squarely falls within the ambit of a service matter and is,

therefore, not maintainable as a PIL.

7.2.The Petitioner claims to represent the interests of visually impaired

employees of Respondent No. 1, who are stated to be its members.

In the event of success, the Petitioner and its members would

directly derive the benefit of the reliefs sought and, consequently,

the present proceedings cannot be maintained in the form of a

public interest litigation.

W.P.(C) 6027/2025 Page 16 of 28

7.3.It is further contended that the Petitioner has failed to disclose the

names and addresses of its office bearers in accordance with Rule

9(i)(f) of the PIL Rules and that the Petition is liable to be

dismissed on that ground alone. It is also submitted that the

Petitioner has not disclosed the names and places of posting of the

employees of Respondent No. 1 who are stated to be its members

and to be aggrieved by the Impugned Policy.

7.4.No grievance whatsoever has been received from any visually

impaired employee of Respondent No. 1 regarding any alleged

inability to discharge the assignments constituting the “mandatory

assignment” under the Impugned Policy for promotion to the

Senior Management Grades.

7.5.No representation was made by the Petitioner to Respondent No. 1

in accordance with Rule 9(i)(h) of the PIL Rules read with the

proviso thereto. Respondent No. 1, being responsible for

appointment and general superintendence over its officers, is stated

to be the proper statutory authority under Sections 17(1) and 43 of

the State Bank of India Act, 1955 (“SBI Act”). The representation

referred to in paragraph 6 of the Petition, according to Respondent

No. 1, was addressed to the Finance Minister, Government of

India, and not to Respondent No. 1. On that basis, it is contended

that the Petition is liable to be dismissed on this ground as well.

7.6.Although the Petitioner claims to have 37 officers in Scale-III

employed with Respondent No. 1, it has failed to demonstrate any

actual prejudice suffered by them as a consequence of the

Impugned Policy. It is submitted that, if such prejudice had in fact

W.P.(C) 6027/2025 Page 17 of 28

arisen, the Petitioner was in a position to furnish specific instances

thereof. The failure to provide any such particulars is stated to

indicate that none of the Petitioner’s members has specifically

authorised the institution of the present Petition. Accordingly, it is

contended that the Petitioner lacks locus in the absence of any

identified harm suffered by any of its members employed with

Respondent No. 1.

7.7.The present Petition discloses no cause of action against

Respondent No. 1. According to Respondent No. 1, it has in place

a fully functional and inclusive mechanism for the promotion of

visually impaired employees from MMGS-III to SMGS-IV and

beyond. On that basis, the Impugned Policy is stated to be

constitutionally valid and not violative of either the RPwD Act or

the Constitution.

7.8.Clause 5(d) of the Impugned Policy prescribes, for promotion to

SMGS-IV, two years’ service as a Branch Manager in Scale-II/III

incumbency branch(es) or two years’ service in an assignment

relating to credit, trade finance, or forex across all verticals in

MMGS-II/III grades. It is further submitted that, for promotion to

SMGS-V, the prescribed criteria are those set out in the Impugned

Policy governing service in the relevant branch and managerial

assignments.

7.9.Although the Petitioner contends that visually impaired officers are

capable of performing a wide range of roles and, therefore, ought

not to be required to undergo the mandatory assignments, neither

the RPwD Act nor the DoPT Guidelines confer a right upon such

W.P.(C) 6027/2025 Page 18 of 28

officers to seek promotion to senior positions without discharging

responsible assignments which are also required of non-visually

impaired officers. Respondent No. 1 contends that many visually

impaired officers seeking promotion to senior posts are already

discharging the mandatory assignments and are being considered

for promotion to the Senior Management Grades.

7.10.In the Delhi Circle alone, 15 officers with visual impairment are

serving in MMGS-III, of whom 8 are presently discharging the

mandatory assignments. According to Respondent No. 1, the

remaining visually impaired officers are to be assigned mandatory

roles in due course, prior to their respective promotion years, in

accordance with the extant Impugned Policy. It is further

submitted that visually impaired officers who have completed the

minimum assignment period have already been included within the

zone of consideration for promotion to SMGS-IV in the promotion

year 2025–26. On that basis, Respondent No. 1 contends that the

assertion that visually impaired officers are unable to perform the

functions of Branch Manager or credit-related assignments is

misconceived and that the present Petition is devoid of merit.

Accordingly, no barrier or discrimination within the meaning of

the RPwD Act is made out against Respondent No. 1.

7.11.Without prejudice to the aforesaid submissions, Respondent No. 1

operates in a heavily regulated sector and that officers at the Senior

Management level are expected to be well versed in critical

functions and to provide necessary oversight over the discharge of

duties by the middle management cadre. The performance of the

W.P.(C) 6027/2025 Page 19 of 28

roles contemplated by the Impugned Requirements strengthens the

quality of such oversight and safeguards the institution as a whole.

Visually impaired officers are already meeting the criteria under

the Impugned Policy and that the Petitioner has furnished no

credible basis to contend otherwise. The concerns of PwD

candidates have already been accommodated by exempting them

from service in rural and semi-urban centres as a qualifying

requirement for promotion to MMGS-III. Accordingly, the

Petitioner cannot seek selective exemption from other mandatory

roles when a common assessment baseline has already been

satisfied by visually impaired candidates.

7.12.Respondent No. 1 is in compliance with the applicable law, the

DoPT Guidelines, and other instructions governing PwD

candidates, including visually impaired candidates, in matters of

recruitment and promotion. Respondent No. 1 provides employees

with various assistive devices to enable them to discharge their

duties effectively.

7.13.Visually impaired candidates are already discharging the roles of

Branch Manager and Credit Officer as part of the mandatory

assignments and, therefore, the allegation of discrimination urged

by the Petitioner is untenable. Accordingly, the present Petition

deserves to be dismissed.

8.The learned Counsel for Respondent Nos. 2 and 4 submitted that:

8.1.Respondent No. 4 issued Guidelines dated 31.03.2014 prescribing

facilities to be extended to PwDs employed under the Government

for the efficient discharge of their duties. Respondent No. 2

W.P.(C) 6027/2025 Page 20 of 28

circulated the said Guidelines to all Public Sector Banks by

communication dated 18.11.2014. The Guidelines set out the

measures to be adopted for extending such facilities to ensure the

efficient performance of duties by PwDs.

8.2.The aforesaid Guidelines dated 31.03.2014 were subsequently

updated and consolidatedvideOffice Memorandum dated

02.02.2024 issued by Respondent No. 4. The updated Guidelines

were thereafter circulated by Respondent No. 2 to all Public Sector

Banksvideletter dated 30.09.2024.

8.3.The Public Sector Banks, including Respondent No. 1, are

commercial entities governed by their respective Boards of

Directors and have been accorded managerial autonomyvide

communication dated 22.02.2005 issued by Respondent No. 4,

which,inter alia, authorises such banks to take decisions on

human resource matters including staffing pattern, recruitment,

placement, transfer, training, and promotion.

8.4.Since Respondent No. 1 is governed by the State Bank of India

Act, 1955 (“SBI Act”), Section 43(1) thereof empowers

Respondent No. 1 to appoint such officers and employees as it

considers necessary or desirable for the efficient discharge of its

functions and to determine the terms and conditions of their

service. In exercise of the said power, Respondent No. 1 has

framed the Officers’ Service Rules, 1992, which govern the

service conditions of its employees.

W.P.(C) 6027/2025 Page 21 of 28

8.5.On the aforesaid basis, it was prayed that Respondent Nos. 2 and 4

be deleted from the array of parties as no substantive relief has

been sought against them in the present Petition.

ANALYSIS AND FINDINGS

9.We have heard the learned Counsel for the Parties.

10.The Petitioner asserts that the present Petition has been instituted to

bring into focus the alleged failure of Respondent No. 1 to comply with the

recommendation of the CCPD in relation to the criteria governing promotion

from Scale-III to Scale-IV and Scale-V, which, according to the Petitioner,

operate in a discriminatory manner against persons with blindness and low

vision.

11.The reliefs sought by the Petitioner include a declaration that the

Impugned Requirements contained in the Impugned Policy of Respondent

No. 1 are unconstitutional, together with a direction to evolve a suitable

mechanism for the promotion of visually impaired employees from MMGS-

III to SMGS-IV and SMGS-V in Respondent No. 1. The Petitioner further

seeks a direction requiring Respondent No. 1 to comply with the

recommendation of the CCPD dated 01.12.2022. In the alternative, the

Petitioner prays for issuance of appropriate instructions exempting persons

with visual disabilities from the Impugned Requirements.

12.The Impugned Requirements stipulate that, for consideration for

promotion to SMGS-IV, an officer must have completed two years’ service

as a Branch Manager in Scale-II/III incumbency branch(es) or two years’

service in an assignment relating to credit, trade finance, or forex in MMGS-

II/III grades. Likewise, for promotion from SMGS-IV to SMGS-V, the

officer must possess a minimum of four years’ branch experience in any

W.P.(C) 6027/2025 Page 22 of 28

vertical, of which at least two years must have been served as a Branch

Manager in Scale-III/IV incumbency branch(es) in the R&DB vertical. The

Petitioner contends that its members serving with Respondent No. 1 are

unable to satisfy these mandatory requirements owing to three practical

difficulties said to be faced by blind and low-vision officers.Firstly, the

roles in question involve the identification of persons, locations, business

activities, stocks, and the monitoring of CCTV footage, for which no

assistive technology is stated to have been provided.Secondly, loan

sanctions and the processing of financial transactions are undertaken in

hard-copy form and, given the necessity of accuracy and the verification of

customers’ signatures, OCR technology is stated to be inadequate.And

thirdly, since these tasks entail financial risk and are susceptible to fraud,

reliance upon human assistance alone is stated to be untenable.

13.On that basis, the Petitioner contended that the Impugned

Requirements are incapable of being effectively fulfilled by officers with

visual disabilities. The Petitioner submitted that a Branch Manager is

required to peruse hard-copy documents such as title deeds, customer KYC

records and tax returns, and to undertake physical inspection of borrower

units, authenticate the originality of title deeds, monitor the strong room, and

tally gold loan bags against the loans disbursed. Similarly, a Credit Officer

is required to conduct pre-sanction surveys involving physical inspection of

securities and units, as well as appraisal of collateral securities and title

deeds, all of which are stated to be in hard-copy form. It is further submitted

by the Petitioner that every Branch Manager is required to furnish a Monthly

Certificate certifying compliance with diverse banking regulations, for

which the officer bears both direct and vicarious liability. According to the

W.P.(C) 6027/2025 Page 23 of 28

Petitioner, a blind officer cannot reasonably be expected to sign such a

certificate solely based on oral inputs from an assistant, particularly when

legal accountability for any false certification cannot be clearly fixed either

upon the officer concerned or upon the assisting personnel.

14.The Petitioner further contends that other Public Sector Banks do not

impose requirements of the nature mandated by Respondent No. 1 as a

precondition for promotion and that such banks have adopted inclusive

practices in conformity with the RPwD Act.

15.The Petitioner also submits that the Impugned Requirements place

employees of Respondent No. 1 with visual impairments on the same

footing as employees without such disabilities, thereby operating to their

disadvantage and rendering them unable to qualify for promotion, with the

consequence of career stagnation and exclusion from higher posts. It is on

this basis that the Petitioner seeks reasonable accommodation or alternative

pathways to ensure that the career progression of visually impaired

employees of Respondent No. 1 is not unjustly impeded.

16.Per contra, Respondent No. 1 contends that there is no discrimination

and that the Impugned Requirements contained in the Impugned Policy are

in conformity with the RPwD Act and the Constitution. Respondent No. 1

has also questioned the locus of the Petitioner to maintain the present

proceedings in the form of a PIL, particularly in the absence of any

identified instance of discrimination suffered by any specific member

employed with Respondent No. 1. It is further contended by Respondent No.

1 that several visually impaired employees are successfully discharging the

mandatory assignments prescribed by the Impugned Policy and have, in fact,

been promoted to the Senior Management Grades. On that basis,

W.P.(C) 6027/2025 Page 24 of 28

Respondent No. 1 submitted that the averments in the present Petition are

speculative and do not disclose any concrete instance of discrimination

arising from the Impugned Policy.

17.Having considered the submissions advanced on behalf of the parties,

there can be no cavil that persons with disabilities are entitled to live and

work with equal dignity, and that discrimination against them, including in

matters of promotion, is impermissible.

18.Section 20(3) of the RPwD Act states as under:

“20. (3) No promotion shall be denied to a person merely on

the ground of disability.”

19.It is, therefore, necessary to ensure that officers of Respondent No. 1

with visual disabilities are treated equally and are provided with such

support and facilities as may be necessary to offset the impact of their

disability. InLeesamma Joseph(supra), the Hon’ble Supreme Court held

that where disability operates as an impediment to satisfying the criteria for

promotion, it becomes necessary to evolve appropriate measures to address

the consequent stagnation of persons with disabilities.

20.InRe: Recruitment of Visually Impaired in Judicial Services, 2025

INSC 300, the Hon’ble Supreme Court recognised that criteria which are

facially neutral may nevertheless operate in an indirectly discriminatory

manner against persons with disabilities.

21.In the present case, the Petitioner contends that although the

Impugned Requirements do not expressly prohibit blind and low-vision

officers from seeking promotion, they have the effect of disproportionately

disadvantaging such officers. Accordingly, any provision that creates an

impediment to the promotion of visually impaired officers would run

W.P.(C) 6027/2025 Page 25 of 28

contrary to the provisions of the RPwD Act and the law laid down by the

Hon’ble Supreme Court in relation to the rights and treatment of persons

with visual disabilities.

22.The present Petition has been instituted in the nature of a PIL, even

though the Petitioner asserts that its members are directly affected by the

Impugned Policy. While the maintainability of the Petition as a PIL may

therefore be open to doubt, having regard to the larger issues raised herein

regarding PwDs, we are inclined to entertain the present Petition as PIL.

23.The Petitioner asserts that several of its members are adversely

affected by the Impugned Policy, inasmuch as they are allegedly unable to

discharge the roles contemplated by the Impugned Requirements. However,

the Petitioner has not identified the specific employees stated to have been

impacted by the said Policy and provided details of exact hardship being

faced by them.

24.The Impugned Policy prescribes uniform criteria for promotion within

Respondent No. 1. Respondent No. 1 is governed by the SBI Act and the

Officers’ Service Rules, 1992, in matters pertaining to recruitment, transfer,

training, and promotion. The limited grievance urged by the Petitioner is that

the Impugned Requirements render it difficult for visually impaired officers

of Respondent No. 1 to discharge the functions of a Branch Manager or

Credit Officer, having regard to the nature of the duties associated with

those posts. While the Petitioner has identified the difficulties allegedly

faced by its members, it has not placed on record any practical solutions to

address the same.

25.The Petitioner has contended that the inherent nature of the roles of

Branch Manager and Credit Officer makes it difficult for visually impaired

W.P.(C) 6027/2025 Page 26 of 28

officers to discharge such functions. Although the Petitioner has furnished

illustrations of tasks that, according to it, visually impaired officers are

unable to perform, Respondent No. 1 has, on the other hand, cited instances

where such duties are being discharged by visually impaired officers. In

rejoinder, the Petitioner submitted that the examples relied upon by

Respondent No. 1 pertain to persons with low vision and not total blindness,

and that such officers may possess sufficient residual vision to perform the

tasks in question. The Petitioner has further contended that no assistive

devices or support mechanisms have been provided to enable visually

impaired officers to overcome the substantial obstacles highlighted in the

present Petition.

26.The Petitioner, being an organisation representing blind and low-

vision bank officers serving in public and private sector banks across the

country, is well placed to suggest solutions to the issues identified in the

present Petition. The Petitioner has also submitted that Public Sector Banks

other than Respondent No. 1 have adopted inclusive policies to

accommodate blind and low-vision officers.

27.Respondent No. 1 has contended that the policies adopted by it are

inclusive and do not discriminate against visually impaired officers in

matters of promotion. Respondent No. 1 has also raised an objection that no

representation was submitted to it prior to the institution of the present

Petition.

28.In view of the foregoing, we deem it appropriate to direct the

Petitioner to submit a detailed Representation to Respondent No. 1,

identifying the officers of Respondent No. 1 who are stated to be adversely

affected by the Impugned Policy and setting out concrete suggestions and

W.P.(C) 6027/2025 Page 27 of 28

measures that may enable such officers to comply with the Impugned

Requirements. Such Representation shall also set out the practices adopted

by other Public Sector Banks in relation to similarly situated officers and the

methodology followed by those banks for considering such officers for

promotion. The Representation shall further indicate any alternative pathway

or mechanism by which the mandatory requirements under the Impugned

Policy may be met, so as to obviate stagnation and secure for visually

impaired officers an equal opportunity to compete with other officers of

Respondent No. 1 on a level playing field.

29.Such Representation shall also be accompanied by all documents

upon which the Petitioner seeks to place reliance in support thereof,

including the recommendation of the CCPD that the Impugned Policy be

suitably modified so as to provide reasonable accommodation and ensure

equal opportunity for visually impaired employees by according equivalent

weightage to functions capable of being independently discharged without

undue risk, considering alternative roles suited to visually impaired

employees in lieu of branch experience and credit assignments for the

purposes of promotion evaluation, and undertaking a comprehensive review

of the promotion policy so as to eliminate exclusionary provisions and

secure conformity with the principles of equal opportunity. The said

Representation shall be submitted by the Petitioner to Respondent No. 1

within a period of four weeks from today. Upon receipt thereof, the Board of

Directors of Respondent No. 1 shall examine the Representation and, after

affording an opportunity of hearing to the authorised representative or

Counsel for the Petitioner, consider the suggestions contained therein and

implement the same, to the extent feasible, in furtherance of the objectives

W.P.(C) 6027/2025 Page 28 of 28

of the RPwD Act within a period of twelve weeks thereafter, and shall

communicate the steps taken in that behalf to the Petitioner.

30.The present Petition is disposed of with the aforesaid directions.

TEJAS KARIA, J

DEVENDRA KUMAR UPADHYAYA, CJ

MAY 29, 2026/sms

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