Towards inclusion: a comparative examination of the status of disability acts in South Asia

This article compares the recent disability legislation in India, Nepal, Bangladesh, and Maldives after signing the CRPD in 2006. Through a systematic comparative approach, this study identifies and examines the commonalities and differences in the provisions, participation of persons with disabilities (PWD), educational considerations, and rights of women with disabilities within their disability Acts. Qualitative content analysis has been used for thematic analysis of the content of these legal documents. The analysis revealed that a shared philosophical assumption existed across the Acts influenced by the social model of disability, while variations exist in the definition of disabilities across these Acts. It was found that due emphasis was placed on the involvement of PWD in regulatory committees in all Acts taken in the study. However, the level and extent of participation in these committees vary among countries. The nature of the educational provision is more inclined towards inclusive education across these Acts. However, not all of these four practices fully include PWD. Less emphasis has been put on including the rights of women with disabilities in the Acts. This article accentuates the importance of comparative studies for cross-country learning and the potential for adapting ideas to suit respective countries' national contexts.