Dear Shri Bahshy,
As usual a very thorough and informative sharing of your participation in 
NAAJMI meeting. 
I also was invited to NAAJMI meeting which is taking place in Bangalore  today 
and tomorrow..
I chose not to attend because of the following reasons.
1. Disability code. The following code is circulated and which very clearly 
gives special status to the National trust act and also Mental illness were not 
included.
Memorandum on Disability Code 
The Background 
In the explanatory note to the Working Draft we had communicated to the 
Committee that in our opinion in order to do full justice to the Disability 
Rights Authority in terms of putting down its power and responsibilities in 
full detail it would be appropriate if the Authority was established under a 
dedicated statute of its own, instead of being made to tag along with the 
Rights statute. We had pointed out that we felt cramped for space in working 
out the norms by which representation to the Authority should be worked out and 
accountability of members obtained. It was due to this substantive constraint 
along with the lack of time that prevented us from working out  the linkages 
between the DRA and other Authorities in the disability field such as the 
National Trust and the Rehabilitation Council of India.
 Dedicated Legislations 
Since  we reached the opinion that the newly established DRA should have its 
own legislation we also concluded that the National Trust and the RCI should 
have their own legislations which should spell out the specific tasks each of 
those authorities should carry out to implement the rights recognized in the 
New Rights for Persons with Disabilities Act. The National Trust should be the 
authority which addresses the issue of multiple discrimination and be mandated 
to proactively formulate policies and programs by which to ensure the equality 
and non discrimination of persons with disabilities who are so disadvantaged 
and the RCI could work on HRD. The composition and powers and functions of the 
three bodies should be so created that it ensures convergence of operation. 
Transitory Measures 
The proposed new law recognizes the paradigm of legal capacity with support. It 
also recognizes the right to life, liberty and integrity of all persons with 
disabilities. The recognition of these rights requires a reexamination of the 
Mental Health Act. Even if it is accepted that community living and no force 
are what is required for all; it is necessary to ask what should be done with 
the existing institutions and the inmates housed in them. The process of 
dismantling cannot be done without creating alternative services and there is a 
need to make a transit legislation which addresses this interim situation. The 
reason for making the transit legislation comes from the main law but to allow 
coherent operation and efficient implementation of these transitory measures it 
is better that they are contained in a separate legislation. 
Demands for Comprehensive Legislation and Protection of Interests of Most 
Marginalized 
The Committee and consequently the legal consultant has been faced with two  
demands:  one, seeking a comprehensive all inclusive legislation; and the other 
asking that the interests of the most marginalized persons with disabilities 
should not be compromised and sidelined. The reason for seeking a comprehensive 
legislation as we understand is to ensure convergence in the operation of 
various authorities in the field and to make for more effective implementation. 
Whilst the group asserting the interest of the marginalized accepts the need 
for convergence, it fears that if such convergence is obtained in one 
comprehensive legislation, which absorbs all authorities then the voices of the 
more organized groups could drown their concerns. 
Convergence in Disability Code 
It is in the wake of these equally valid concerns that it was suggested that a 
Disability Code may be formulated which could be a legally accepted and 
efficient way of bringing convergence along with accommodating difference. The 
difference between a Code and multiple legislations in a field is that the Code 
has a common philosophy; common grammar and a concerted effort to ensure that 
each part fits into a cohesive whole. Thus for example there are number of 
legislations on children which occupy the field today but they do not make a 
Children Code because the cohesiveness of philosophy, grammar and the 
convergence between authorities is absent. 

The difference between a Code with multiple legislations and a single 
comprehensive legislation is that a Code with multiple legislations allows each 
area to obtain the detailed and dedicated attention it requires. The Companies 
Act; the Income Tax Act are examples of legislations which are comprehensive 
but whose very comprehensiveness becomes a barrier to their efficient 
implementation. A Code with multiple legislations makes it  easier to undertake 
capacity building and awareness raising of the law and it ensures that the 
interests of the marginalized groups are not submerged in the bulk of a large 
legislation. 

2.Legal capacity
On legal capacity 
Bhargavi’s paper as presented at the National Convention organised by DRG, New 
Delhi, 1-3rd December
If a blind person goes to a health service, and gets very angry at the way he 
or she was treated there, he would be seen as an “angry” person. That’s all. 
But not so, someone who is in treatment for a psychiatric problem: If he or she 
expressed their anger at not being treated well in a mental health facility, 
that would be seen as an escalation of ‘symptoms’ and SOS treatment started... 
sedation, shock treatment, solitary confinement, institutionalisation, upping 
of dosage, further curtailments of other civil political rights. 
Legal capacity is the focal point of exercising self determination and choice. 
Either you have it or you don’t. As human beings we all have legal capacity. 
That is a natural endowment. There should be no debate whether such a right 
should be ‘given’ to someone or not.
Legal capacity is not a continuum. “You can’t be a little pregnant or more 
pregnant” (citing Mr. Gabor Gombos, Hungarian Human Rights Defender and present 
UN committee member). So also, you cannot have a little legal capacity, or more 
legal capacity. Legal capacity is an inalienable natural right. 
If we acknowledge human diversity, people in different contexts need different 
kinds of support at different times. It is up to us as a human society to 
provide those supports. We cannot say, ‘how much support this person needs, 
that much legal capacity must be subtracted from that person’. There is no 
mathematical formula between support needed and legal capacity. There is no 
inverse ratio. 
Legal capacity is the universal assumption of the UNCRPD and the new Act. 
The PWDA is totally silent on legal capacity. There are neither affirming 
provisions, nor limiting provisions. The new Act proactively provides for full 
legal capacity for all persons with all disabilities. 
Today, there is advocacy from some sections of society to restrict legal 
capacity for people with “high support” needs. Concepts of “restricted LC”, 
“limited guardianship” or “limited substitution of decision making” are being 
argued for. 
When push comes to shove, who are these people with “high support” needs: 
Advocacy is coming from 2 groups- care givers of people with developmental and 
intellectual disabilities; and of people living with a mental illness. Groups 
of care givers of people seen as having “high support” or attributed to having 
high support needs have used the existing “incapacity” legal regime. Why this 
discrimination within the sector, that most persons with disabilities can make 
their own decisions and have control over their lives; while some, as a group, 
cannot?  Genuine inclusion within the disability sector requires our addressing 
this question. 
Universal legal capacity is the fundamental assumption of the new Act, along 
with equality and non-discrimination. If we place restrictions on the LC 
provision, that will compromise every single provision of rights in the Act. 
What the right hand gives, the left hand would have taken away. 
A limitation provision on rights cannot appear on the same provision / page / 
law as the granting of the right. Analogous situation prevailed with respect to 
“progressive realization”: Providing for “Progressive realization” in the 
UNCRPD would have taken away what any right provided for. [Within the scope of 
a single law, we cannot say, Provision A gives Full LC; and Provision B 
restricts A. LC is not like buying 1 kilo of potatoes, and then giving quarter 
kilo back.]  
If the sector demand is for limited LC, we must be open to another law with 
such restrictions. It is a contradiction to say we want comprehensive law on 
ALL rights of ALL persons with ALL disabilities, and place restrictions within 
it. 
To place restrictions of LC within new Law will COMPROMISE ... ALL rights of 
ALL persons with ALL disabilities.
E.g. future scenario where restricted LC is put within the comprehensive law:
Blind person approaches integrated disability and health services, gets angry 
at the way he or she was treated by the service provider. MH professional 
available at the service is brought in, and person is diagnosed as not safe for 
self or others (as happens widely in the MH sector). The disabled person is 
seen as “lacking insight / capacity”, and is forcibly treated with sedation, 
shock, SOS medicines, and “kidnapping” to the local mental asylum. 
Who is seen as “high support” becomes subjective and people in dominant 
positions in society will decide that. In a structured society, where persons 
with disabilities are marginalised, this provision will be used against them. 
Restriction of LC is a threat to everybody. When no criteria exists on “high 
support”, everybody will be pulled into the diagnosis of “high support”, 
“incapable”, “lacking insight”, “risky to self”, “risky to others”, “violent 
and dangerous”, etc. and stereotypes hitherto marked only for persons living 
with mental illness will now be extended to all persons with all disabilities. 
The degree and scope of marginalization will increase. 
Finally, how many persons living with a mental illness have we seen in 
disability or other meetings? Where are they? Their LC being severely 
restricted, they are house bound or inside institutions. LC is also the most 
restricted for people living on society’s margins... the poor and the homeless. 
 It is this restriction that brings them into institutions of different sorts 
(beggars’ home, police custody, prisons), without providing any other kind of 
relief. This status quo will remain if LC is restricted under the new Law. 
We, PLMI, are grateful for the inclusion efforts by various disability groups 
and coalitions, including DRG, HRLN, CBR forum, etc. With this inclusion, we 
also appeal strongly that LC be unconditional. Let this not be a subject of 
future debate. 
THANK YOU. 



3. The latest draft of 6th Dec the Mental health care act 2010 was given and 
they want this draft to be scrapped. No discussion,  It should be scrapped as 
it is against spirit of UNCRPD

   Now what I found was the mind of most of the participants who organise this 
event have already made up and the other  participants are called to rubber 
stamp the concept notes already prepared.
I did not find any scope for divergent views or even expressing divergent views 
and discussion.
   So i preferred not to attend.
   This is for your kind information.

 
"Greatness lies not in never falling but in rising everytime we fall"
Captain Johann samuhanand,  BANGALORE  INDIA
91 80  42023252   
www.captainjohann.blogspot.com
 


From: Amrit Kumar Bakhshy <[email protected]>
To: [email protected]
Cc: 
Sent: Wednesday, 15 December, 2010 11:37:02 PM
Subject: [MhaReformIndia:264] Winds of change


If winter comes, can spring be far behind?
NAAJMI in partnership with Action Aid organized a regional level consultation 
in Pune on 13th-14th of this month. The consultation was to focus on the New 
Disability Draft Legislation and the Mental Health Act and proposed amendments 
in the context of UNCRPD. When the consultations were planned, the draft 
document of the proposed Mental Health Care Act was not out and therefore the 
second amendments were circulated to the participants. The organizers, however, 
took cognizance of this late development and the presentation was based on the 
draft document of the proposed MHCA.
The participants were from various NGOs in Maharashtra working in disability 
sector including mental health sector. I was happy to see quite a few disabled 
amongst them.  Most of them were working at the grass root level and were not 
familiar with the disability laws and the reform process taking place. The 
organizer therefore spent most of the time explaining in simple language the 
UNCRPD, the disability laws and the drafts of the new laws proposed. The 
presentations were made by Amita Dhanda and she was supported by Bhargavi 
Davar. Next week high level regional consultations are planned which   are 
likely to be attended by bigwigs of the disability sector.
Based on the presentation made by Amita Dhanda and the discussions I had with 
her, I would like to share my impressions with the Group of what NAAJMI’s views 
are in regard to Mental Health Law.
1.       I sensed a softening of approach and keenness to move forward.
2.       There were serious reservations in regard to the first and the second 
draft to the extent that NAAJMI was not willing to participate in regional 
consultations. 
3.       The Draft Document on MHCA is considered a marked improvement on the 
earlier drafts.
4.       NAAJMI is now willing to have a dialogue and accepts that through 
dialogue issues can be resolved.
5.       It is accepted that the 6th December document makes a good 
presentation. But while the icing put is thick and nice, the cake remains the 
same.
6.       Reservations to involuntary admissions.
7.       A transitional arrangement to phase out the present system of 
institutionalization.
8.       Institutionalization for custody purpose is opposed.
9.       The draft MHCL requires PwMI to establish competence to make decision. 
In law a person is treated as competent unless proved otherwise. PwMI should be 
treated on an equal basis with others.
10.   For making an Advance Directive or for appointing a Nominated 
Representative, the document is proposed to be signed by a medical practitioner 
which is discriminatory. While a person may choose to have a witness who is a 
doctor as is recommended while executing a will, it should not be a 
requirement.  If someone believes that when the AD was made or NR was 
appointed, the person doing so was not competent, it is for him to prove so.
11.   The draft provides for duties and rights of NRS. There is one duty and 7 
rights. There should be an elaborate list of duties and responsibilities.
12.   An order of precedence is given for appointment of NR if no such 
appointment is made by a person. But there is no provision for the person to 
change such NR appointed from the order of precedence, if he or she so wants to 
do so at a later date.
13.   While there is a chapter on rights of PwMI, the effect is diluted with 
many exceptions added.
The above is what I recollect. I must have missed a few and/or I might not have 
understood correctly some of the points made. However I can say that there was 
definitely positivity and a dialogue should help in clarifying the doubts and 
bridging the gaps. I am encouraged by the impressions I gained. It will be a 
great service to the MH Sector if we carry forward the mission with one voice 
accommodating each others’ view point. 
What P.B.Shelly said in the concluding lines of 'An Ode to West Wind' should 
happen.It may not be wrong to say that stars are aligning and favourable winds 
have started blowing. I am sanguine.

-- 

 Every passion in isolation is insane, therefore sanity is the synthesis of 
insanities.

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[email protected]
Discussions on mental health law / policy / plan monitoring / human rights etc 
[email protected]
India-specific news and views related to mental health
[email protected]
Information and support to carers of people with mental health issues
[email protected]
Mutual support and sharing of experiential knowledge, skills and social 
learning amongst peers

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