"One also has to show a 'neutral' expression the rules say, which sounds like a remarkably subjective word to apply to someone's facial expression. If it came to an argument based on a passport picture rejection by UKPS, it'd be interesting to see what legal body would be ready to adjudicate on whether a facial expression were neutral or not.
There is real possibility that disabled people could be at a disadvantage if UKPS strictly enforces these guidelines. And if you ever try to take a photo for a baby or child's pasport, it's odds on the picture will not exactly comply. "