Making Marrakesh work: comparative lessons from the United Kingdom and India for advancing disability access in Sri Lanka: implications for the Global South

Abstract This paper critically examines Sri Lanka’s compliance with the Marrakesh Treaty, focusing on the practical realization of rights for persons with print disabilities. While Sri Lanka has formally adopted treaty obligations, its statutory framework falls short of guaranteeing enforceable access, particularly regarding technological protection measures, cross-border exchange and operational infrastructure. Through a comparative analysis of the UK and India, the study demonstrates that meaningful implementation requires more than legislative alignment, it demands institutional capacity, digital repositories, professional training and participatory mechanisms that connect beneficiaries with authorised entities. By situating Sri Lanka within the broader Global South context, the paper highlights systemic challenges. These include resource constraints, limited regional cooperation and doctrinal ambiguities that impede the translation of formal rights into tangible benefits. Drawing lessons from the UK and India, the study emphasises contextually adaptable strategies for operationalizing Marrakesh Treaty obligations, including technological protection measures exceptions, cross-border legal clarity, digital infrastructure development and regional collaboration. In doing so, it positions Sri Lanka as a case study for rights-oriented, operationally effective accessibility models and contributes original insights into Global South copyright law and practice.