http://www.publictechnology.net/modules.php?op=modload&name=News&file=article&sid=3586
"On of the key rules is that the photo must show a full face, looking straight at the camera, with a neutral expression, with their mouth closed. This is an impossibility for many disabled people, or children of a young age - and the UKPS is probably going to (rightly) get a lot of flack (and possibly legal challenges under the Disability Discrimination Act) from disability action groups on this, if the rule is strictly enforced. UKPS... you try telling a severely autistic 7 year old who cannot shut his mouth to keep his mouth closed when having a passport photo taken."