A Guide to Litigating Identity Systems in villages with poor connectivity where technological glitches immobilse the system.293 b) The dissent of the Indian Supreme Court also cites excerpts from a book that states the systems intended to provide assistance and help people out of poverty can become systems of perpetuating poverty and injustice due to problems in authentication and algorithmic technology.294 c) The Kenyan High Court notes that enrolment may be more difficult for members of pastoral communities that lack identification documents required by the Kenyan national identity system.295 69. Authentication failures can lead to exclusion from access to goods and services that are made conditional on successful authentication. Individuals who are excluded may consequently suffer disproportionate restrictions on their social and economic rights, including, but not limited to, the right to social security; the right to an adequate standard of living; the right to enjoyment of the highest attainable standard of physical and mental health; and the right to education.296 a) The dissent of the Indian Supreme Court holds that proven authentication failures of biometric identity systems lead to exclusion of genuine and eligible beneficiaries.297 For example, the figures from the Economic Survey of India, an official document of the Government, indicated that there are millions of eligible beneficiaries across India who have suffered financial exclusion.298 293 Jean Drèze, “Dark clouds over the PDS,” The Hindu (10 September 2016), https://www.thehindu.com/opinion/lead/Dark-clouds-over-the-PDS/article14631030.ece 294 Virginia Eubanks, Automating Inequality: How High-Tech Tools Profile, Police, and Punish the Poor (St Martin’s Press, 2018). 295 See Huduma Namba Judgment, ¶¶ 1006, 1012. 296 International Covenant on Economic, Social and Cultural Rights, Arts. 9, 11, 12 and 13. 297 Government of India, Economic Survey 2016–17 at 194. 298 Aadhaar Judgment, ¶ 264 of dissent. 68