The Rights of Persons with Disabilities Act, 2016, (‘the Act’) in India grants essential rights and protections to individuals with disabilities, anchored in the principle of reasonable accommodation. At the same time, the Act clarifies that a failure to provide reasonable accommodation is justified when providing the accommodation would cause ‘disproportionate or undue burden’. This standard encompassing factors such as financial constraints and resources to implement such measures. However, varied interpretations and implementation of what makes a burden disproportionate or undue often result in a conceptually incoherent application of the principle of reasonable accommodation among different jurisdictions. This paper attempts to address this ambiguity surrounding the determination of ‘disproportionate or undue burden’ in the application of the principle of reasonable accommodation. By undertaking a cross-jurisdictional analysis of historical and legislative contexts, case laws, and considering international standards, the paper identifies key interpretational tools used in unpacking the ‘undue burden’ defence. Thereafter, the paper proposes a clear framework outlining factors for the Indian courts to consider when interpreting this standard. The scope of this paper is confined to a consideration of the undue burden defence in the realm of disability rights law. An examination of this standard in other areas of law, such as religious accommodations, is beyond the scope of this paper. ‎