A Guide to Litigating Identity Systems g) The dissent of the Indian Supreme Court also cites several other research studies conducted by the state governments, academicians, and members of civil society in India documenting evidence of authentication failures, leading to exclusion and serious human rights violations.304 h) The Kenyan High Court notes the risk of exclusion from access to goods and services that can result from both authentication failures and initial denial of enrolment because of a lack of documentation.305 The court finds that there is a need for a clear regulatory framework addressing potential exclusion.306 304 Aadhaar Judgment, ¶ 265–268 of dissent. 305 Huduma Namba Judgment, ¶¶ 876, 1012. 306 Huduma Namba Judgment, ¶ 1012. 70