Upvote:1
The page cited by @GregHewgill indicates that persons over the age of 50 qualify for Emigration Check Not Required (Non-ECR). This PDF from the Indian Ministry of External Affairs confirms the over 50 category.
Presumably, evidence of her age should be sufficient, but you or she should contact the passport agency to confirm. Alternately, she can apply and wait and see if the passport agency requests further evidence of her age, and then proceed from there.