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Thursday, July 14, 2011

Fwd: [Say No to UID] New Doc: Legal Notice to UIDAI



---------- Forwarded message ----------
From: Anivar Aravind <notification+kr4marbae4mn@facebookmail.com>
Date: Thu, Jul 14, 2011 at 11:01 AM
Subject: [Say No to UID] New Doc: Legal Notice to UIDAI
To: Say No to UID <nouid@groups.facebook.com>


Anivar Aravind posted in Say No to UID.
created the doc: "Legal Notice to UIDAI"
Anivar Aravind created the doc: "Legal Notice to UIDAI"

Following is the text of the notice issued to UIDAI, Planning Commission.

 

 

To,

 

1. THE CHAIRPERSON,

UNIQUE IDENTIFICATION AUTHORITY OF INDIA,

Planning Commission,

 

BANGALORE REGIONAL OFFICE:

THE CHAIRPERSON,

'KHANIJA BHAVAN',

floor, South Wing, No. 49, 3

Racecourse Road,

BANGALORE 560001

 

    2. THE CHAIRPERSON,

 

3. THE DEPUTY CHAIRPERSON,

                                                                   LEGAL NOTICE

 

 

We have been duly instructed by our client, Mr. Mathew Thomas, son of

Late T.P. John, aged 74 years, resident of Flat No. 102, Saroj Fantasy

Apartments, Bhuvaneshwari Road, Whitefield, Bangalore 560066, to issue

this notice as following:

 

    Our client is a citizen of India. He is issuing this notice to

you, being extremely concerned with the way all of you are abusing

your position and powers, spending huge amounts of tax payers' money

for acts that are not only against the interest of citizens of India,

and the Nation itself, but also against all accepted norms of Rule of

Law and fundamental rights, guaranteed under the Constitution of

India.

 

   First of you being the Chairperson, of UIDAI, second of you being

Chairperson of Planning Commission and third of you being Deputy

Chairperson are aware that Biometric and personal data is being

collected under, a scheme called, 'AADHAAR' and are issuing 'Aadhaar

Number' to every resident of India. However, there is no statutory

sanction for the same. The NIAI Bill is still at the stage of being

considered before the Parliamentary Standing Committee and is yet to

be tabled in Parliament. A reading of the Bill makes clear that

'Aadhaar Number' can be issued only under the provisions of the sub

section (2) of Section 3 of the said bill. Further, a reading of the

NIAI draft bill shows that date of coming into force of the Act is

subject to notification of the Central Government in official gazette

in this regard after the bill is passed by the Parliament and after

securing presidential assent. Our client states such being the status

of the 'Aadhaar', the collection of the biometric data and personal

data and issuing of 'Aadhaar Number' does not have any statutory

sanction and hence, the same is illegal. Our client states that you

could not have legally issued any orders for such collection of data.

. Our client states that hurried spending of thousands of crores of

tax payers' money on the project is done with a malafide intention of

compelling the parliament to pass the bill and endorse ex-post-facto

all contracts entered into, and activities done by, the First of you.

 

 

   Our client states that it is not known to parliamentary process,

where even before the statutory authority is constituted by the

legislative process, the authority commences functioning even before

the bill is tabled in the parliament. Under the NIAI Bill, the

national authority is to be appointed by the provisions of sub section

(1) of Section 11 of the Bill. Even before the Statute of NIAI Bill is

tabled or discussed by the parliament in the legislative process,

second and third of you have illegally constituted the UIDAI Authority

and appointed first of you as its chairperson for a purpose that is

yet to be the law. That first of you, knowing that the very purpose of

issuing 'Aadhaar number' does not have statutory sanction, has been

spending huge amount of taxpayers' money and entering into contracts

with companies that are registered in India and in other countries in

a manner that is a questionable and coloured exercise of illegally

usurped authority. Our client states that first of you do not have any

authority to enter into such contracts as you are yet to be legally

declared the authority under the proposed NIAI Bill.

 

    All of you are aware that the Bill is pending before Parliament.

Yet, you have chosen to go ahead with the issuing of UID numbers to

people, even before the Bill is passed by Parliament and notified in

the Gazette of India and Rules made under the law for its

implementation.

 

   Our client states that first of you is spending several Thousands

of Crores of Rupees in this activity, Without Parliamentary approval

of the Bill. You may please note that although a budgetary provision

has been made for your office, set up as part of the Planning

Commission, you cannot use this money for the purposes of issuing UID

numbers by purchasing equipment, paying contractors etc., before the

law is enacted by the parliament.

 

   Our client states that you have appointed private organisations

and companies, registered in India and in other countries for

participating in various activities in 'Aadhaar' program. Following

are the questions raised and observations made by our client.

 

a)  What is the criterion for selecting the company, trust, society,

NGO or any other organization being selected as Registrar under the

'Aadhaar' Scheme? You have appointed 209 companies, organizations,

societies, trusts and organizations as Registrars for Aadhaar Project.

 

b) What is the criterion for selecting company Alankit Assignments

Limited, (@ 1007);Alankit Finsec Limited (@ 1008) and Alankit Lifecare

Limited(@1009) Managing Directors of the said organizations seem to be

related, they have their offices in the same vicinity of Jhandewalan,

having same first name for the company and having same web and e-mail

address? Similarly what is the criterion of selecting Alakananda

Philanthropic Trust (@ 1006) whose activity is only running an

Engineering College in Orissa? Similarly, what is the criterion of

selecting Annapu Reddy Education Society (@ 1010) of Secunderabad in

Andhra Pradesh as registrars for Kerala and Tamil Nadu? Similarly,

what is the criterion of selecting Baruanagar Tea Estate Pvt. Limited

as, Registrar for Assam? What is the criterion for selecting Bellary

IT Solutions Limited for Rajasthan and Karnataka? (By rule, the

applications and tenders are filed informing the registered office of

the company. In this case, it is doubtful where the registered office

of the company is, Bellary? Bangalore? Or Rajasthan?). What is the

criterion of selecting AkebonoSoft Technologies Pvt. Ltd and Asa Bhanu

Technical Services Limited ( when it comes to software services Asa

Bhanu says AkebonoSoft is its software wing!!!) Similar is the

situation of many of the companies that have been selected as

registrars for enrolling residents for issuance of 'Aadhaar Numbers'.

Our client reserves his right to seek further clarification against

other organizations and companies, as he is awaiting replies under

Right to Information Act on them.

 

 c) All of you are aware that Biometric Data is being collected by

number of private organizations and issuing Aadhaar numbers, as you

have entered into agreement with such organizations. All of you are

also aware that Biometric and demographic data of a person is very

personal and he has every right to deny the access to the same. If

recent incidents of such manipulations recorded by sting operations at

Mysore of a news channel are any indication, you should all be alarmed

of the real probability of fraud. While you have stated that the said

data will be protected, the way the same is being manipulated and

abused make it impossible to maintain confidentialityof the biometric

and demographic information of people, whose data is thus collected.

While there are 209 organizations that are appointed as registrars and

first of you have entered into contracts with 36 companies, there is

little data available about the nature and content of the contracts

that have been entered into with these companies and organizations. As

you are paying all these companies out of taxpayers' money, everyone

is entitled to know about the kind of contracts that you have entered

into with these companies. The same is not posted on the website

maintained by first of you. First of you are not transparent on the

contracts entered into with these companies.

 

d) As the Registrars and Contracted Companies will have access to the

Biometric and Demographic data, they are collecting and recording, the

question is whether all of you have enquired about the antecedents and

the persons who head and operate these companies and their

antecedents. You all are aware that Biometric and Demographic data is

sensitive data, more particularly when you are collecting such data of

all the residents of India. Have the Home Ministry and other related

departments of revenue intelligence conducted enquiry about the l egal

status of these organizations and companies and submitted no objection

for you to enter into agreement with these companies? (You are aware

the way transactions have taken place and how the entirecompany law

procedures have been compromised in creating false transactions in the

case of 2G scam dogging the country, where several ministers of union

cabinet and heads of 'reputed' companies are accused.) If all of you

have such reports, why is it that the data and due diligence carried

out before entering into contracts with vendors of the UID project,

not been made public, or made available on the website of the first of

you or second of you, being Deputy Chairperson of Planning Commission

of India?

 

e) Our client states that first of you have not demonstrated the way

the data is secured when it is recorded by the registrars and there

are number of instances, which already speak that the information may

be easily copied by use of storage systems when the same is recorded.

You are aware that the large majority of registrars are not parties

that are governed by the State or its instrumentality and yet they are

contracted by all of you to deliver the service of collecting the

Biometric and Demographic data.

 

f) Our client states that from the limited information that is

available on website of first of you, that first of you through your

contracted partners like Registrars and companies who provide allied

services collecting, storing, maintaining, revising, delivering the

data as and when called for identification all have access to the

biometric and demographic data. Whether they are software companies or

other like telecommunication companies, all have access data that is

collected by all of you in the name of Aadhaar.

 

g) Our client states that India consists more of rural population that

is hardly literate ( given the kind standards that we have assigned to

call a person 'literate') It would be impossible to expect him/her to

utilize the so called advantage of the Aadhaar Number. It can be tool

of corruption rather than a tool to prevent the same. The Aadhaar

application form takes a declaration from the applicants allowing the

sharing of the personal data collected. Most people, (especially the

Illiterate) sign this declaration, without understanding the

implications, and imagining that it is for the Government to use the

data in any manner deemed fit. This is tantamount to cheating the

people to part with personal data for commercial exploitation by

unknown parties. The first of you has made public statements, as

reported in the press, that the "Aadhaar Platform would be opened for

Application Development". Thus, the first of you, under the pretext of

being part of the government, as an "authority" is collecting personal

data of the people of India for providing the same for private

commercial purposes. Every person who is part of the state machinery

may demand identity and with the lack of infrastructure that is

existing and lack of transparency in governance (including UIDAI as

stated in keeping the contracts it has entered into with companies

away from public domain), it will be another tool of oppression. Want

of electricity, want of telecommunication infrastructure, defective

instruments, soiled hands, injured hands, or anaemic condition of the

resident, or hundreds of other situations may make the very purpose

impossible and deny access to any or all services. A verification of

the Registrars listed speak by their very business that many of them

do not have any qualification, past experience or knowhow in

collecting, storing or verifying the digital data.

 

 

h) Our client states that Election Commission has already issued EPIC

cards to 700 millions of citizen of India. Second and Third of you

along with all the instrumentalities of the State are aware of the

same. What was the need of collection of Biometric and Demographic

data when such Cards exist? You are aware most of the services of the

state are sought by persons who are older than 18 years and those who

are not, seek the same through their parents. While aspersions are

thrown by second and third of you of authorities of your own

government, as they being inconsistent and having false records, what

is the guarantee of records that are collected by number of private

organizations and companies are not duplicated or manipulated and

abused for their own purposes and intelligence, targeting and tracking

people.

 

 i) Our client states that first of you have without the existence of

the statute NIAI has already entered into contracts and agreements

with number of institutions and organizations, making Aadhaar data for

them for identity. The first of you and the body he heads, UIDAI, are

guilty of impersonating as an authority of the government to make the

contracting parties believe that it has the legal sanction to enter

into the contracts. You are aware that there may be number of changes

that may brought into the statute after due deliberations in the

Parliament, assuming, but not admitting, even if it were to become the

statute. Such being the case, our client asks that on what authority

first of you have entered into with such agreements?

 

 j) All of you are aware that the data that is being collected is

sensitive data. Hence one needs to know what are all the tests and

verifications that are done in respect of the machinery that is being

bought from companies like, L 1 Identity Solutions [L 1] of USA. All

of you are aware that Directors and other officials of the said L 1

Company are former directors of Central Intelligence Agency. Our

client wants to know whether the Home Ministry or Defence Ministry,

has after conducting its enquiry regarding the machinery that is being

purchased at such huge amounts from the said company, cleared these

companies from the national security point of view.

 

 k) Our client states that Identity of a person is very personal. A

Citizen need not produce evidence every time to prove his identity as

a citizen. More particularly, when he / she has to seek services of

the state, to which he / she has a fundamental right. Our client

states that in the numerous interviews of first of you and members and

supporters of your organizations are harking upon 'efficient

management of services' and 'efficient delivery of services' as the

necessity for introduction of Aadhaar. However, all of you often state

that there is failure of PDS system and other services of Govt of

India like, pension, NREGA, BPL cards, Ration Cards, and others. All

of you claim that there have been significant duplication of records

resulting in loss to the state, there is absolutely no guarantee of

security of identity of person or duplication of the identity In case

of discrepancy of the identity, the person has to 'update' his

identity, either biometric or demographic. There is no way by which, a

person whose biometric identity has been compromised, stolen or

misused, could have another identity. Our client states that every

resident of India who has problems with his identity will have to go

through whole lot of procedure for proving his identity. Our client

states that Aadhaar on the contrary becoming a boon to the ordinary

residents of India, it would become bane in no time.

 

 l) OUR CLIENT STATES THAT THIS FINGERPRINTING OF PEOPLE WAS THE

GROUND ON WHICH THE FATHER OF THIS NATION DID FIRST CIVIL DISOBEDIENCE

BY BURNING THE SAME IN SOUTH AFRICA. If that was the foundation of our

non-violent struggle for freedom, it is a tragedy that the self same

country that defied all the colonial laws to protect one's identity

from state abuse, is now demanding that every citizen be numbered,

finger printed and iris scanned. Their very existence is to be

established by a random number given to them by a inanimate machine.

(Unless all of you consider that machine is more intelligent and

reliable than Humans) Issuance of a number to every resident is an

insult to our dignity. Inhuman is the fact that these numbers are

issued by companies and organizations whose services are contracted by

all of you, even in the absence of a statute permitting the same. The

same is enshrined in our Constitution in chapter relating to

fundamental rights. It is violation of Right to Life and Personal

Liberty as guaranteed under Article 21 of the Constitution of India.

 

m) First of you have stated in all the advertisements that securing

Aadhaar Number is optional and not mandatory. However all the

indicators show that it would become impossible for anyone to get any

service of the state without its having the numbers. Following are the

reasons. In recent times Reserve Bank of India has come with a rule

that every person who seeks to open a Bank Account has to provide

information about the person and his/her family, his gender, religion,

caste, whether he is married, if so his marriage anniversary falls on

which date, whether he owns car, whether he owns a refrigerator,

television, domestic appliances, telephone numbers, mobile numbers of

the person and his/her members of family, their e-mail addresses, et

al under the garb of KNOW YOUR CUSTOMER. All this information is

collected along with the UID Number in the application form.

Similarly, first of you are collecting through respective State

Government in the garb of KNOW YOUR RESIDENT + (KYR+) form. Government

of Karnataka, for example, is collecting, along with the data required

under Aadhaar, data in detail from each of the resident in the name of

KYR+ ( Know Your Resident + ). Thus, all the data relating to a person

who is receives services of Govt, like pensions, PDS, BPL cardholder,

and other benefits are to give all their details in the KYR+ form,

which is being collected along with issuance of Aadhaar number. It

makes amply clear that henceforth any citizen (or resident) who is

seeking any service of the state has to prove his identity by

biometric and demographic data before he / she is delivered the said

service. Statements made by first of you that only information that is

being collected is that biometric and demographic data is absolutely

false. It would deny him / her if the biometric information does not

match even though he / she is the self same person because of the

technical errors and abuse or manipulation of his / her identity. It

amounts to being treated a thief in one's own country. Though you are

aware of this situation, you are continuing with collection of the

Biometric and Demographic information from residents. Our client

states that most deprived would be illiterates, the poor, Dalits,

Minorities, Women and other marginalized communities. Rather than

assisting them Aadhaar would deprive them of government welfare

services.

 

 n) Companies like Accenture and L 1 Identity solutions, are companies

that are providing similar services to US Department of Defense and

Intelligence departments. They have large contracts with US armed

forces. They are also said to be contracting with Central Intelligence

Agency (CIA), as some of the directors of L 1 are former officials of

Department of Defense or CIA. Our client wants to know whether before

entering into with contract with these companies, have all of you

verified and enquired about suitability of these companies in

providing technology and maintenance of the data by a thorough

investigation from Home Ministry. L 1 Identity solutions is mired with

number of litigations and recent reports state that it is a loss

making company despite sale of its subsidiary. Q10 reports are any

indications. Recently it was taken over by a french company.

Similarly, Accenture and L 1 also outsource their work to various

companies. Our client wants to know whether all of you have verified

about companies that provide such services to Accenture and L1

Identity Solutions. Our client states that such outsourcing and

purchase is also a practice of number of companies that are registered

in India. You have entered into contracts with such companies like,

Wipro, HCL and others. Have all of you have verified about the

suitability of these companies for awarding such contracts? Following

is an allegation against L 1, as reported in Internet media:

http://www.nationalcorruptionindex.org/pages/profile.php?profile_id=486.

 

 o) Our client states that you could not have entered into contracts

with these companies before a law being in place, enabling the same.

By entering into such transactions without any legislative support for

the activity, you are risking national intelligence and huge amounts

of taxpayers' money at your whim and fancy.

 

 p) Our client wants to know why the NIAI Bill is sent to Standing

Committee on Finance instead of Standing Committee on law first for

its discussion.

 

 q) Our client states that while issuing of EPIC Card no payments were

made to any of the citizen of India. No payments have been made to any

citizen while being issued with BPL Card whereas, for registering for

Aadhaar, certain classes of people are being incentives in money.

Tamil Nadu is one of the state where delivery of services of the state

is efficient. This state does not obtain personal data of its people

in the manner the first of you is doing. It has not paid monies to

residents to register their names and identities. Why biomertrics are

required now by you and why not allow state to have their own systems,

since the matter is a state subject, under the Constitution? Our

client is not against computerisation, but your violation of law and

the Constitution of India, by finger printing all people, taking their

iris scans, storing these with other personal data in a central

database for access by service providers.

 

 r) Our client states that there are number of criticisms on safety of

people's Biometric data stored in a central database. Our client

states that studies by the London School of Economics (LSE), in 2005,

(on the UK ID card scheme, which similar to the UID scheme) have shown

that such projects would not achieve their objectives and are a waste

of public money. The UK Government scrapped the scheme in Jun 2009,

saying that it is "Intrusive bullying" and assault on personal

liberties. A study by the Indian Institute of Management (Ahmedabad),

in 2011, has questioned the feasibility of your UID project and

suggested examination of its viability. Yet you continue to spend

public money recklessly on the project.

 

 s) Our client states that you have proposed to store all the

biometric and personal data of people collected by you in a "Cloud".

"Cloud" is a computer technology term used for the computer servers of

a service provider who stores data and provides access to it, to a

client. Thus, you have said that the data would be stored in a central

database for access by many. The LSE study has found that such a

central database would itself become an attractive target for

terrorists. You are aware that there has been over 4000 attacks in the

past year, by hackers of Indian Government websites and databases,

including the office of the PMO and the Defense Ministry. In the case

of your UID scheme, hacking is not necessary, since the data would be

available to the foreign and private agencies who are your

contractors. Thus, your activities jeopardise national security.

 

 t) Our client states that fingerprints of people collected by you

through the project, and available to your officials, other government

officials, private companies and organisations could easily be misused

to falsify documents and commit crimes. This would destroy the value

of fingerprints, as corroborative evidence in Indian courts, since it

would have to be first established as how the fingerprints came to be

on the objects in question. This could seriously harm the entire

judicial system.

 

u) It is well known that petty officials of private and government

agencies involved in the UID scheme are luring the unwary and / or

illiterate people by either promising benefits to those who give their

biometric and other data under to scheme or suggesting that the UID

number is essential for certain transactions. For example, recently,

some officials of the Regional Transport Authority (RTA) at Mysore

asked people wanting to transfer vehicles to produce UID numbers. The

Minister for Transport, Mr. R Ashok, had to issue a clarification

through the press that the RTA has been directed not to ask for UID

numbers.

 

 v) Our client states that before initiating such an exercise it is

necessary that a detailed national debate be initiated rather than few

consultations held with 'civil society' at places and in language far

removed from the people of this nation. Our client strongly refutes

the kind of 'consultations' held by first of you as not being serious

discussions as many of those 'beneficiaries' are never consulted or

informed about the dangers of such identity disclosure.

 

 w) As a responsible government, and custodians of public trust and

public monies, the first, second and third of you are to exercise

utmost prudence before spending public money. Our client states that

all of you are going about spending these huge sums of public money in

a cavalier fashion, without a feasibility study and / or cost-benefit

analysis.The claim of all of you that Aadhaar numbers and their use

would reduce or eliminate leakages of welfare funds / benefits, is

untested and unproved. It is publicly known that subsidised items,

like kerosene, are siphoned by mafia gangs operating in collusion or

otherwise with politicians and / or government officials. Such mafia

activity is the major source of leakages of these funds. Further,

thousands of Crores of Rupees worth of food grains are lost / damaged

due to poor storage facilities. Issuing Aadhaar numbers would not

prevent these losses. Your priorities are misplaced. Your above claim

regarding Aadhaar is false, frivolous and made with the malafide

intent to justify the scheme you have launched without the sanction of

law.

 

 x) The Citizenship Act was amended to provide for a National

Population Register and National ID cards for citizens. Aadhaar, on

the other hand issues numbers and identity to all residents as opposed

to citizens. Amazingly, while the first of you claims to provide a

unique identity to all people residing in India, in the process

employed for issuing the Aadhaar numbers, you are accepting as many as

14 other identities, such as PAN cards, driving licenses, ration cards

etc, as proof of identity and proof of address, with no verification

of either address or identity. This is a flawed and dangerous process

and jeopardises national security.

 

 OUR client therefore calls upon:

 

 1   First of you to immediately stop all the activities of

collection of biometric and demographic data from residents of India

until such time this mechanism is approved by a notified legislation.

 

 2. First of you to immediately initiate a larger discussion involving

not just urban 'civil society' or 'informed consent' of 'target

groups' on the issue of Aadhaar and all aspects of the same including

the errors and difficulties that may arise in respect of the

information that is disclosed to authority.

 

 3. All of you to transparently and publicly carry out a feasibility

study and cost-benefit analysis, before any further sums from the

public exchequer is spent on the project.

 

 4) All of you to ensure, that if at all the project is found

feasible, and in public interest, ID cards are issued only to

citizens. Non-citizen residents may be treated with a separate system

of registration, like the foreigners' registration procedure, now

available.

 

5) All of you take immediate steps to terminate the contracts entered

into with private companies and organisations, whether registered in

other countries or in India and take back all data gathered by them,

delete such data and further, provide proof of such destruction of the

data.

 

6)  First of you to make a public statement that he and UIDAI are NOT

an authority of the Government of India in order so that no one is

misled anyone into believing otherwise.

 

 7) Second and third of you to immediately issue directions to first

of you not spend tax payers' money in collection of the biometric and

demographic data from residents.

 

8) All of you stop entering into agreements with any company or

organization until the law is set in motion and stop making payments

to companies in the name of Aadhaar project for either purchase of

instruments or for provision of technical or other support. Further,

all of you to take steps to recover the sums paid to these vendors and

registrars, since the contracts are illegal, the first contracting

party, namely, UIDAI, having no legal basis for purporting to act as

an authority on behalf of the Government of India.

 

9) Initiate enquiry into all the companies, trusts, societies and

organizations, which have contracts for Aadhaar project work, through

the Home Ministry and make public all such enquiry reports.

 

 10) First of you immediately place in public domain and make freely

available all the agreements entered into by you with all the

companies and organisations in respect of Aadhaar Project.

 

11) Second and third of you immediately inform all by a public

disclosure the reasons as to why the NIAI Bill is not referred to Law

Ministry but to Standing Committee on finance.

 

 12) First of you to immediately make public and to provide to our

client the copy of the selection criterion and method of selecting the

209 companies, organizations and societies in respect of Aadhaar

Project and similarly provide the selection criterion and the

rationale behind procuring equipment, technology and services from 36

companies.

 

13)  As on what authority and basis in the absence of law first of you

have entered into contracts with number of institutions like LIC and

others at the cost of Taxpayers money.

 

Our client hereby calls upon all of you to take action on all the

above issues within 10 days of receipt of this notice. In the event of

your failure to do so, our client would be constrained to initiate

such legal action as may be necessary against you in your official

capacity and in your personal capacity, as you have used taxpayers

money in an arbitrary manner and further, since you have, by your

actions, placed the security of the nation and of its people in

jeopardy.


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Palash Biswas
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