Comments on the Draft National Health Research Policy 2026
On 6 July 2026, the Department of Health Research invited public comments on the Draft National Health Research Policy 2026, which sets out the plan of action and a top-level framework for the promotion, governance, and priority-setting for health research in India. The Vidhi Centre for Legal Policy has responded to this call and submitted detailed comments, offering both broad and clause-wise recommendations and points for further consideration. Drawing on Vidhi’s ongoing work across health law and policy, and disability inclusion and access, our submission is divided into two parts: recommendations on health research in general, and recommendations specific to persons with disabilities (PwDs).
Our key recommendations include:
On health research in general:
- Introducing clear definitions for key terms such as “research institution,” “industry,” and “research misconduct” to reduce ambiguity.
- Apportioning responsibilities clearly across clauses that currently leave guidance-setting, review, or oversight functions unassigned to a specific body.
- Bringing states to the foreground of the research ecosystem, instead of limiting state-level planning, review, and contributions largely to the Annexures.
To strengthen disability inclusion within the Draft Policy:
- Explicitly naming PwDs across equity and inclusion provisions, rather than leaving them to be read into broader terms like “vulnerable and underserved populations.”
- Embedding accessibility standards for research infrastructure, health technology assessment, and consultation mechanisms, in line with the Rights of Persons with Disabilities Act, 2016 (RPwD Act) and the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).
- Aligning the Draft Policy’s consent and legal capacity framework with the RPwD Act’s supported decision-making model.
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About the Authors
Rituparna is a Senior Resident Fellow at Vidhi and works in the area of health. Her interests include public health, data protection and privacy, and mental health. Prior to joining Vidhi, she was engaged as a Policy Research Associate under Mr. Kashish Aneja, a practicing advocate & consultant with the O’Neill Institute for National and Global Health Law, Washington D.C., where she worked extensively on topics including One Health, global regulation of e-cigarettes, and misleading advertisements related to high fat, sugar and sodium (HFSS) foods and beverages. Rituparna graduated from the National Law University Odisha (NLUO) in 2022 with a B.A., LL.B. (Hons.), and received a Merit Gold Medal in the subject of Personal Law.
Tanya is a Research Fellow with the Disability (Inclusion and Access) team at Vidhi Centre for Legal Policy. A 2026 graduate of Dr. Ram Manohar Lohiya National Law University, Lucknow, Tanya’s broader interest in social justice informs her engagement with questions of disability rights, inclusion, and equitable access. Her academic interests span constitutional jurisprudence, social justice, and commercial laws. At Vidhi, she is interested in exploring the interface of administrative and constitutional law through a rights-based lens, with a focus on strengthening accessibility, institutional accountability, and meaningful access to justice for all.
Shivani Mody is a Research Fellow with the Health team. Prior to joining Vidhi, she worked as a Law Researcher under Hon'ble Mr. Justice Prateek Jalan at the Delhi High Court where she focused on cases involving arbitration law as well as statutory writs. She graduated from Jindal Global Law School with a B.A. LL.B. in 2023. As a law student, she gained experience interning with various research and advocacy organizations, such as Vidhi, the Alternative Law Forum, and the Centre for Justice, Law and Society, where she examined how legal frameworks shape and influence societal issues.
