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Feb 29,2012

Dear Mr Raja

On 13 December, 2011, the Parliamentary Standing Committee on Finance presented its 42nd Report, on the National Identification Authority of India Bill 2010, to the Lok Sabha. It was laid before the Rajya Sabha on the same day.

The Report is a severe indictment of the proposed Bill, and of the UID project. The Committee recorded its “concerns and apprehensions about the UID scheme” and “categorically convey(ed) their unacceptability of the National Identification Authority of India Bill 2010 in its present form”. The Committee “urge(d) the government to reconsider and review the UID Scheme as also the proposals contained in the Bill in all its ramifications and bring forth a fresh legislation before Parliament”. (para 13 of ‘Observations/Recommendation’)

The Report of the Standing Committee specifically raises questions about the legality, and wisdom, of the collection of biometrics while creating a citizen/resident data base. The Report reads (in para 3© of the section on ‘Observations/Recommendations’: “The collection of biometric information and its linkage with personal information without amendment to the Citizenship Act 1955 as well as the Citizenship (Registration of Citizens and Issue of National Identity Cards) Rules 2003, appears to be beyond the scope of subordinate legislation, which needs to be examined in detail by Parliament.”

This is a matter for consideration by the Parliamentary Standing Committee on Home, and it is requested that this be brought before the Standing Committee urgently especially as the collection of biometrics is continuing despite the questionable legality of the exercise.

The Citizenship Act 1955 was mended (in 2004) and section 14-A introduced into it. Section 14-A authorised the Central Government to “compulsorily register every citizen of India and issue national identity card to him”. It recognised the Registrar General appointed under section 3(1) of the Registration of Births and Deaths Act 1969 to act as the National Registration Authority, and to function as the Registrar General of Citizen Registration. In sub-section (5), it said: “The procedure to be followed in compulsory registration of the citizens of India shall be such as may be prescribed.”

Rule 3(3) of the Citizenship Rules 2003 set out the particulars in respect of every citizen to be contained in the National Register of Indian Citizens. It specifies 12 fields of information:
Father’s name
Mother’s name
Date of birth
Place of birth
Residential address (present and permanent)
Marital status. If ever married, name of the spouse
Visible identification mark
Date of registration of citizen
Serial number of registration, and
National Identity Number.

Biometric information is not a notified field of information. In any event, and as the Standing Committee on Finance has observed, “the collection of biometric information and its linkage with personal information of individuals appears to be beyond the scope of subordinate legislation …”.

In the context of the use of biometrics, we draw to your attention the fact that the Registrar General has not done any testing of the use, and consequences, of biometrics technology on the whole Indian population. The few, meagre, reports that have been produced are from the UIDAI, which has been focussed on marketing the idea than seriously investigating it, as can be seen from a document on the UIDAI website titled “Aadhaar – Communicating to a billion” which may be found atAADHAAR_PDF.pdf. In the notification that sets up the committee to devise a strategy for marketing the idea (found atMedia_Awareness.pdf , the intention of the exercise is set out:

This explains why the only reports and documents on biometrics that has been produced under the aegis of the UIDAI have not been reliable indices of the use, accuracy, consequences of biometrics. These reports may be found atBiometrics_Standards_Committee_report.pdf  which is the report prepared by the UIDAI Committee on Biometrics, December 2009. UID_and_iris_paper_final.pdf    which is the UIDAI’s own report titled “Ensuring Uniqueness: Collecting iris biometrics for the Unique ID Mission” which reveals that this is untested technology, and which sells the idea of using iris scans, and does not investigate it.

uid_enrolment_poc_report.pdf  which is the “UID enrolment proof-of-concept report” based on field study conducted between March and May 2010 and which was made available in February 2011.The admission that “Prior to conducting the UIDAI PoC, there was insufficient reliable biometric data available for residents of India that could be used to analyze and reach conclusions relevant to the implementation of the UID program.” And that ” There was however, limited data available from anywhere in the world regarding the ease of iris capture, as well as the usability of iris images in the case of minors.” The small sample size, the unscientific representation of the results (just bare statements) and the statement that: ”The goal of the PoC was to collect data representative of India and not necessarily to find difficult-to-use biometrics. Therefore, extremely remote rural areas, often with populations specializing in certain types of work (tea plantation workers, areca nut growers, etc.) were not chosen. This ensured that degradation of biometrics characteristic of such narrow groups was not overrepresented in the sample data collected” is significant.

role_of_biometric_technology_in_aadhaar_jan21_2012.pdf which is a January 2012 document produced as a reaction to the Standing Committee report and which express the `confidence’ of the UIDAI, and this is not an independent audit, but an in-house exercise.

It is also of consequence that India has no manufacturer of iris scan equipment.

We request the Parliamentary Standing Committee on Home Affairs, of which you are a senior member, to consider this matter with urgency.


Vickram Crishna, Mumbai, [email protected]

Sukla Sen, Mumbai, [email protected]

Vinay Baindur, Bengaluru, [email protected]

Sudhir Vombatkere, Mysore, [email protected]

J T Dsouza, Mumbai, [email protected]

Usha Ramanathan, Delhi, [email protected]

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