Accessibility of Currency is a Legal Right, Not a Concession: Delhi High Court Tells RBI to Ensure Disability-Inclusive Banking and Currency

Delhi High Court declines to order withdrawal of ₹50 note, but mandates RBI to implement inclusive reforms and submit compliance reports every six months. Delhi High Court delivered a landmark judgment in Rohit Dandriyal & Others v. Reserve Bank of India & Others & Connected Matters, disposing of a batch of Public Interest Litigations filed under Article 226 of the Constitution. The Court, while declining to issue a writ of mandamus for immediate redesign or withdrawal of the ₹50 currency note, categorically held that “accessibility for persons with disabilities is not an act of charity but a constitutional and statutory mandate under the Rights of Persons with Disabilities Act, 2016.”

The Court directed the Reserve Bank of India (RBI) and the Union of India to "scrupulously implement" the recommendations of a High Powered Committee constituted by the Court and ensure that accessibility concerns of the visually impaired are “factored in before printing or launching any new series of currency notes or digital payment platforms including the e-Rupee.”

The bench comprising Chief Justice Devender Kumar Upadhyay and Justice Tushar Rao Gedela underscored the urgency and legal imperative of financial inclusion for persons with disabilities, but balanced it with judicial restraint, observing that "currency design lies within the exclusive domain of policy-making and involves technical, economic, and security considerations."

“Judicial Review Cannot Rewrite Policy, But Accessibility Must Shape It” – Court Refuses Mandamus on Currency Redesign

In its detailed judgment, the Delhi High Court ruled that the courts cannot compel the RBI or the Government of India to redesign existing currency notes by issuing a writ of mandamus. However, it laid down a binding framework for implementation of inclusive design going forward, particularly in the context of new currency series and the digital rupee initiative. The Court emphasised that the Rights of Persons with Disabilities Act, 2016 is not merely aspirational but binding in its obligations, holding:

“After all, the provisions of the Act have been promulgated by the Government of India to alleviate and assuage the concerns of one of the most vulnerable citizens of this country.” [Para 9]

The case revolved around the accessibility of Indian currency, coins, ATMs, digital banking platforms, and payment systems for the visually impaired, with specific focus on the newly introduced ₹50 denomination note that lacked tactile features sufficient for identification by blind or low-vision persons.

High Court Sets Judicial Limits, But Expands Executive Responsibility: “Court Cannot Dictate Currency Design, But Inclusion Must Guide Future Series”

The petitions, dating from 2017 to 2020, were filed by individuals and advocacy organisations representing the blind and visually impaired, including the All India Confederation of the Blind, Blind Graduates Forum of India, and petitioner George Abraham. The grievance centered on the absence of adequate identification features in new currency notes—especially ₹50—following demonetisation, as well as the inaccessibility of banking apps, ATMs, and now digital currencies.

Petitioners argued that RBI had failed to meet its obligations under Sections 40 and 42 of the Rights of Persons with Disabilities Act, 2016, which mandate accessibility in public services and infrastructure. They sought court directions for the redesign of currency, implementation of accessibility audits, and establishment of enforceable standards across all regulated entities, including banks and payment systems.

Recognising the systemic nature of the issue, the Court constituted a High Powered Committee (HPC) by its order dated 29 July 2022, comprising RBI officials, IIT Delhi professors, and disability rights activists to formulate concrete recommendations.

“Implementation, Not Intent, Is What Matters” – Court Orders Six-Monthly Progress Reports From Banks on Accessibility

The key constitutional and legal issues before the Court were:

1. Whether inaccessible currency and digital financial systems violate the rights of persons with disabilities under the 2016 Act.

2. Whether a constitutional court can compel the RBI and GoI to redesign currency through judicial directions.

3. Whether financial accessibility is an enforceable right under Article 226.

4. The balance between the independence of RBI as a policy-making body and its statutory obligations to ensure inclusion.

The Court struck a cautious but firm tone. On the question of enforceability, it observed:

“It is unfortunate that judicial intervention is required in such matters when measures to ensure ease of accessibility for the specially-abled should be implemented in a proactive manner.” [Order dated 29.07.2022]

It further added that while the Court is restrained from ordering immediate changes in currency design, it expects the RBI and the Government of India to:

“...keep in mind and take into consideration the suggestions of the High Powered Committee as and when the Government of India and RBI decide to print fresh currency.” [Para 9]

The Court held that the judiciary cannot replace executive wisdom in policy matters, but it can ensure statutory compliance:

“Such matters involve technical and financial considerations, which is the domain of the Government of India and RBI. Thus, any direction in the nature of a mandamus, having regard to the above observations in respect of printing of fresh currency notes in the manner sought by the petitioners, may not be possible to issue.” [Para 10]

RBI Assures Future Accessibility; Court Takes Assurance on Record, But Retains Oversight

After reviewing the High Powered Committee’s Report dated 7 July 2023 and RBI’s Action Taken Reports from 2023 to 2025, the Court noted significant progress on digital banking reforms and partial compliance by banks. It recorded with approval that RBI had already:

• Issued circulars for making Point-of-Sale machines and digital banking systems accessible.

• Directed banks to factor accessibility into e-Rupee applications during pilot testing.

• Engaged disability rights organisations in the design of the next currency series.

However, the Court insisted on continuing accountability:

“The RBI must obtain six (6) monthly reports from various banks as to the progress made by each of such Banks till it is finally implemented or the goal reached.” [Para 8]

On ₹50 Currency Note:
Petitioners specifically challenged the absence of tactile markers on the ₹50 note. The Court, while not granting relief, stated:

“Given the fact that printing of new currency notes after alignment with the suggestions of the Committee may entail huge costs... we can only observe that the RBI and the Government of India shall keep in mind and take into consideration the suggestions of the High Powered Committee... when they decide to print fresh currency.” [Para 9]

On e-Rupee and Digital Currency:
The Court accepted the RBI’s assurance that accessibility features would be built into the final launch of the e-Rupee:

“Accessibility concerns of the differently abled, if any, would be comprehensively addressed and suitably factored in, as per the available technology, before the final launch.” [Para 6, ATR]

On Cheques, Cards, and Digital Documents:
The Court acknowledged that RBI was in the process of incorporating tactile standards and accessibility norms into Master Directions for all regulated entities. It noted the proactive steps taken, including pilot solutions developed during RBI’s “HaRBInger” innovation challenge under the theme "Being Divyang Friendly."

The Delhi High Court has stopped short of mandating a redesign of the ₹50 note but has substantially advanced the cause of accessibility by creating a framework of ongoing executive responsibility, statutory compliance, and judicial oversight. By requiring half-yearly reports and holding the RBI accountable to the suggestions of its own expert committee, the Court has embedded accessibility into the future of Indian currency and digital finance.

“We thus, with fond hope and in positive anticipation of implementation of the suggestions of the High Powered Committee, dispose of the present Public Interest Petition.” [Para 12]

While the judgment does not deliver immediate relief, it institutionalises long-term structural reform and reaffirms that accessibility is not an optional policy, but a legal obligation flowing from both statute and constitutional values.

Date of Decision: 24 September 2025