A Guide to Litigating Identity Systems A unique function creep concern is implicated in these instances either because the application of the identity system extends beyond its statutory basis or the domain in which the system is extended meaningfully changes the applicable balancing under proportionality. b) The dissenting opinion in the Aadhaar judgment also identifies these instances of function creep. Additionally, the dissent notes a general concern of potential function creep by identifying the enacting legislation’s breadth and ambiguous language as giving rise to function creep.235 The dissent then points out that the Aadhaar system has been extended to 252 government schemes, ranging from children’s essay contest submissions to the receipt of food subsidies. The list of schemes the dissent provides illustrates the breadth of Aadhaar’s reach into everyday life: “[Schemes Aadhaar is required to include] schemes for children (such as benefits under the Sarva Shiksha Abhiyan or getting meals under the Mid-day meal scheme, painting and essay competitions for children, scholarships on merit), schemes relating to rehabilitation of bonded labour and human trafficking, scholarship schemes for SC/ST [Scheduled Caste (SCs) and Scheduled Tribes (STs)] students, universal access to tuberculosis care, pensions, schemes relating to labour and employment, skill development, personnel and training, agriculture and farmers’ welfare, primary and higher education, social justice, benefits for persons with disabilities, women and child development, rural development, food distribution, healthcare, Panchayati Raj, chemicals and fertilizers, water resources, petroleum and natural gas, science and technology, sanitation, textiles, urban development, minority affairs, road transport, culture, tourism, urban housing, tribal affairs and stipends for internship for students.”236 235 Aadhaar Judgment, ¶ 246 of dissent. 236 Aadhaar Judgment, ¶ 246 of dissent. 54