Per your observations, the photo doesn't match the following specifications :
1. height of the face measures between 31 mm (1- 1/4 inches) and 36 mm (1- 7/16 inches) from chin to crown of head (natural top of head).
2. Taken straight on, with face and shoulders centred and squared to the camera (i.e. the photographs must show the full front view of the person’s head and shoulders, showing full face centred in the middle of the photograph).
I would suggest to show the photographer the specifications or redo it from other location who does PR card photos with acceptance guarantee.