LPG Consumers: Non-Aadhaar Physical KYC & Privacy Rights

Public Interest Document | LPG KYC, Aadhaar, Facial Recognition & DBT/Subsidy

Public Interest Document

This document has been prepared as a consumer representation concerning verification of domestic LPG connections, Aadhaar-based authentication/e-KYC, facial-recognition-based verification, physical/offline KYC, and voluntary opt-out from LPG subsidy/DBT.

It is intended to assist LPG consumers who wish to understand and formally communicate their preference for a conventional, privacy-preserving verification process where legally permissible.

The representation requests acceptance of alternative identity and address documents, recording of the consumer's voluntary decision not to receive subsidy/DBT, and continuation of LPG refill services without interruption merely because the consumer has declined Aadhaar-based, biometric or facial-recognition verification.

The representation principally requests:

1. Physical/offline KYC using permitted non-Aadhaar documents.

2. No Aadhaar number or Aadhaar authentication where the consumer does not consent.

3. No biometric or facial-recognition authentication for the requested physical-KYC route.

4. Recording of the consumer's voluntary opt-out from LPG subsidy/DBT.

5. Continuation of LPG refill booking, delivery and supply.

6. Written communication of the legal/circular basis if the agency considers Aadhaar e-KYC or facial recognition compulsory.

7. Acknowledgement of the consumer's representation.

The document raises a broader public-interest question:

Can a domestic LPG consumer who does not seek DBT/subsidy choose an alternative physical KYC process instead of Aadhaar-based, biometric or facial-recognition verification, where such alternative is legally permissible?

Privacy and data-protection concern:

The representation records concerns regarding the collection, storage, sharing, leakage and possible misuse of personal and biometric information. It therefore proposes a conventional physical/offline verification route using alternative documents.

The document also refers to constitutional privacy principles recognised by the Supreme Court and asks that any compulsory collection or use of personal data have an appropriate legal basis and satisfy requirements relating to legitimate purpose, necessity and proportionality.

Disclaimer: 

This document is published for public information, awareness and use as a representation template. It is not intended to constitute a universal determination that Aadhaar, e-KYC, biometric authentication or facial recognition is unlawful or that every LPG consumer is legally entitled to a particular verification method.

Requirements may vary depending upon the applicable law, Government directions, Oil Marketing Company instructions and the consumer's individual circumstances. Consumers should verify the applicable requirements before relying upon this document.

References to reports or allegations concerning data exposure are reproduced as matters of concern raised in the representation and should not be treated as independent findings or conclusions unless separately verified.

The information and documents published on this page are for general legal information and public-interest awareness only and do not constitute legal advice. Accessing, downloading or using any material does not create an advocate client relationship.

How can an LPG consumer use this document?

Consumers may download the representation, enter their own consumer and LPG connection details, attach the relevant supporting documents and submit it to their concerned LPG distributor.

The representation requests a written acknowledgement and asks the distributor to identify the specific legal or administrative basis if Aadhaar e-KYC or facial-recognition verification is asserted to be compulsory.

Consumers should retain a copy of the submitted representation and acknowledgement for their records.

Prepared / Published by

Adv. Sahil Goyal
Advocate | Supreme Court of India

Subject areas: Constitutional Law • Privacy & Data Protection • Public Interest • Consumer Rights • RTI • Cyber Law

This document is being placed in the public domain for legal awareness, transparency and public-interest discussion.