Aha. Chance to rant on my favorite beef with Indian babus.

This is one of the most stupid rules I have encountered. (and there are lots when it comes to India)

Face does change with time and need to update photograph after certain period of time make sense. But....

why does a person getting OCI at 49, need again at 51?
face does not change in 28 years between age 21 to 49 but does between 49 and 51?

A reasonable policy would have been to require photo update every 10 years.

Also, why a photo update require such elaborate process that can be handled only in Delhi? (YOU CANT TRAVEL WHILE THIS IS UNDERWAY). Any consulate should be able to handle it.

By the way, a photo is taken at every entry and exit and stored in computers associated with OCI number. Does a photo on a card provide more info?

Luckily the old adage that GOI's left hand and right hand are unfamiliar with each other and usually end up contradicting each other actually works in our favor.

In last 20+ visits, I have yet to encounter a single immigration officer who know about this rule (even when questioned and pocked)

Of course it is better to be safe than sorry but what is safe and what is sorry is up to individual circumstances. Not being able to travel to attend parent's funeral because OCI card is sitting in Delhi for weeks working on "updating photo" falls into "sorry" part.

Have yet to hear a single DP on FT or immihelp or any other india related website where 50+ year old was denied entry because he did not comply with this rule (of course there can always be DP #1 )