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The National Education Policy 2019: An Alarming Attempt To Redefine India

This twelve month period should be structured in order to ensure timelines are being adhered to and each relevant section receives adequate time, attention and care.

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In January 2015, the Ministry of Human Resource Development (MHRD) initiated the process of developing the National Education Policy for our country. This effort culminated into the 484 page draft National Education Policy 2019 (NEP) which was made public on 31st May 2019. While the initial 30 day period that was granted to the public was thereafter extended for an additional month, it is pertinent to note that the drafters took over four years before they submitted the current iteration of this report to the Government in December 2018, where after the Government took another five and a half months before releasing the same to the public.

Though it is not directly relevant to the more substantive comments contained hereinafter, it is pertinent to note and place on record that the official press release by the Government incorrectly indicated that the report was submitted by the drafting committee to the Government on the 31st of May 2019, a fact that is clearly contradicted by the committee’s own letter to the MHRD dated 15th December 2018.

The overarching comment that will emerge through the rest of this note is that while the policy is 484 pages long, it lacks the depth and context necessary for a policy of such national importance to be implemented. It is genuinely hoped that the policy drafters are clearer in their vision for India’s education sector than what is evident through the NEP.

Unfortunately, today, the 31st of July 2019 is the last date for submitting comments on the draft and therefore the time to address all the emergent issues is limited. This situation is further exacerbated given the current Government’s resounding majority in the Parliament as well as the declaration of the HRD Minister that they will be putting the final touches on the NEP within the next few weeks. The threat to India’s future is writ large and needs intervention at the earliest.

Setting aside personal opinions, let us take a look at some of the aspects that will eventually lead to India struggling to propagate equality, inclusiveness, empathy, and most importantly unity across demographics.

The NEP on page 401 states that, “this Policy is unambiguous and explicit that education must be a not-for-pro?t activity and enterprise in society.”

Unfortunately, the NEP is filled with statements and suggestions that seem to suggest that the consequence of this policy is going to be a shot in the arm for the private sector in more ways than one. It is also concerning that the drafters have gone on to implicitly define education as ‘formal’ education without acknowledging the rampant shadow economy which fearlessly runs education as a for-profit business. In fact, subject to the drafters’ clarifications, the policy does quite the reverse, by making suggestions which may possibly promote and legitimize this shadow economy.

In one of the most telling statements made by the drafters they establish that higher education institutions shall be governed by “market forces”. Notwithstanding, the interpretations of the term “market forces”, let us look at a few of the many ways in which the shadow economy will be propped up through the NEP.

One of the key objectives of the NEP is to make education compulsory even at the pre-primary level. This endeavour is well appreciated and would perhaps have been the best outcome of this policy, had it not been for the failure of the drafters to recognize the role that private pre-primary education centres play in this regard. This omission suggests that they favour the status quo of them being privately run as for-profit enterprises. That by itself may not be atrocious, as parents always had a choice whether to avail the services of these commercial establishments or not. However, the new policy enforces a diktat for all children to enter into pre-primary centres, without speaking of the current dichotomy. This is not only disturbing, but also bears a resemblance to the numerous times an industry has lobbied for its financial gain and policy-makers have succumbed to their demands without an analysis of the consequences.

The drafters may point out here that the government will step up and establish pre-primary schools to cover this gap. However, history teaches us that irrespective of government initiatives the private sector will inevitably be dominant, especially since in this case they can legally run these pre-primary centres for-profit.
Moving up to primary and secondary schooling, it has been well documented that students across the economic strata are prompted at all levels to undertake private tuitions. Often, these tuitions are imparted by their own schoolteachers. The inherent conflict of interest is not just optical, but a harsh reality that has been ignored by the drafters of the NEP. Adding impetus to an already regressive phenomenon is the granting of ‘alleged’ autonomy to schools and boards to determine the structure and content of their curriculum. Therefore, potentially giving further ammunition to the schools and teachers to deviate from the set norms and latently drive more and more students towards tuition. This will further fuel another existing problem of teachers in public and private schools pushing students into taking private tuitions after school hours, whereby the teachers charge an additional fee to discharge the same duties they are paid to discharge during school hours.
If the drafters are under the impression that Section 28 of the Right to Education Act 2009, which explicitly states that teachers are not allowed to engage in private tutoring, has taken care of this problem, they only need to look at public records as recent as earlier this year (2019) where the Madras High Court acknowledged this practice and had to reiterate its illegality. This, in spite of the 2012 Supreme Court judgment along the same lines as well as numerous other such instances over the years. This phenomenon continues to be prevalent in states like UP, Jharkhand and Delhi, amongst others.
A different, but related example is the education city of Kota, where students get enrolled in ‘dummy’ schools, only as a formality while attending tuitions and coaching centres during school hours.

While utilising school teachers for increasing the capacity for delivering education, albeit through tuitions, may not necessarily be a bad idea, it may be imperative to at least disallow teachers, whether public or private, from tutoring students from their own schools. Thus compelling them to discharge their duties effectively within school premises and during school hours. This is already practiced by some urban private schools and concretising it into a government law coupled with effective enforcement will ensure that it is taken more seriously.
This is where things start getting even more interesting. As we get into education at higher age groups, what emerges is the fact that the NEP has done a splendid job of being an enabler, alas for an industry that does not find mention in the policy at all.
The draft proposes entrance tests through the National Testing Agency (NTA) for admissions in universities, with the idea that it will reduce the burden of ‘high stakes’ 12th Board exams and varied entrance tests for different universities, which would in turn reduce dependency on coaching classes. However, this doesn’t change much for the children as they would now be dependent on coaching centres for these entrance tests. Hitherto, coaching centres are notoriously for-profit and thrive on the gigantic divergence between school and entrance exam curricula. Coaching centres will either have more services and products to add to their shelf or will continue to prosper unhindered. At this pace and with the widening of the NTA, watch out for more IPOs on the stock exchanges in this sector.
The draft excessively, obsessively, and ambiguously takes pride in the NTA-led entrance tests and how they will make it easier for students to get admissions in universities. After explicit instructions to public Higher Education Institutions (HEIs) to use the NTA, the drafters in the same breath give HEIs the autonomy to decide their own criteria for admission, making it another example of how the NEP makes autonomy a catch phrase left to differential interpretation.
Furthermore, and very dishearteningly, the policymakers through the NEP had the chance to explicitly penalise ‘profit-making education enterprises’, sending out a strong message that they shall not be tolerated. Yet, the NEP only hints at the existence of for-profit educational institutions and effectively stops there. This will lead to either of the two situations; first, the violators will continue to fill their coffers or the second, which is more hopeful, the educational czars will come in line with the ‘not-for-profit’ objective and will have to make do with whatever they have ‘stolen’ so far and find newer ways to steal from the system. The need of the hour is to have a past and present public audit of all private institutions where the onus to prove that they are not-for-profit is on them, rather than the other way around.
The need for regulatory intent is severely missing from the text of the NEP, which could have otherwise done well to, at the very least, bar violators from the education industry, if not return their loot. The names of these czars are well known and not worth risking a defamation suit, which seems to be another one of their specialties. There are bigger fish to fry, including one that is 484 units long.


Even if the concerns raised by other critiques of this policy as well as the points mentioned herein are matters that can be clarified and/or corrected, a major concern stems from the belief that appears from the tone of the drafters’ language throughout the chapter on URGs and everywhere else in the policy where URGs are mentioned. The Hindi word ‘ehsaan’ comes to mind, which means ‘a favour’.
A quick look at the paragraph that speaks of Madrasas and Gurukuls is a prime example of the supremist mindset that has become so common in today’s India. Paragraph 6.5.2 identifies Madrasas and Gurukuls as ‘religious schools’ and goes on to use a play of words which is better suited in a salesman’s playbook. The drafters begin with speaking of how Muslims are under-represented in schools across the country and how it is the duty of the country to correct that. They go on to propose the setting up of ‘excellent’ schools in Muslim dominated neighbourhoods. The use of the word ‘excellent’ has been highlighted because as with many other places in the NEP, adjectives are used without prescribing meaning, leading to ambiguity. In Paragraph 6.5.2, the drafters go on to say that Madrasas ‘may’ be encouraged to continue with their traditions and pedagogical styles, while they ‘must’ integrate the curriculum suggested by the National Curriculum Framework and that the teachers in the Madrasas ‘will’ be upskilled to teach science, math, social sciences and languages through the pedagogical practices set up under the NEP. The use of the words, ‘may’, ‘must’ and ‘will’ are telling and cause great concern that goes to the root of everything that our Constitution stands for. While many may say that it is a good step, the imposition and the manner of the imposition is highly disturbing and in light of everything else in this policy that has been written about over the past month or so, secularism and liberalism continues to evade today’s India.  

Some may call this an unnecessarily reading between the lines and attributing intent, where none exists. If that is the case, it is unfortunate that the drafters have not been more articulate and clear while drafting this policy.
The chapter dealing with URGs speaks separately of tribals and correctly identifies that the prescribed curriculum needs to be contextualized in order to make it more relatable for them, however what is missing is how the rest of the students in the system should relate to the tribals. Missing out on this important piece of putting in the effort to harmonize the opportunities and acceptability of the underrepresented with the represented is unacceptable given the lack of trust that already exists in our country. A similar approach of making exceptions for the URGs while ignoring steps for promoting inclusiveness is rampant throughout the chapter and policy. Transgenders find mention, but the LGBQ don’t. These examples have the unfortunate and hopefully unintended impact of making the policy’s focus appear to be to segregate and not integrate. Surely, their steps are positive, but given that this policy is going to dictate the Government’s efforts over the next several decades, their efforts may be viewed as being akin to giving a homeless man a plastic sheet to cover his head, while effectively telling him that this is enough for him and he should feel grateful for it.
It’s difficult to concentrate on the positives of this policy, especially since intended and unintended ignorance, discrimination, and diversion tactics run deep into almost every section thereof.
Integrating URGs has been a challenge for countries world over and the drafters have passed the opportunity to make India a beacon for the rest of the world, promoting the lessons in inclusivity from our forefathers including Mahatma Gandhi. Innovative steps like diversity management in institutions, accessibility initiatives for special groups, and identity-swap techniques would have been welcome if only someone had gone down that path.

While the theme of the shadow economy and the ill-treatment of the URGs is troubling, what is even more worrisome is the fact that in almost every meaningful section of this policy the drafters make us question whether their idea of India is what we have been brought up in and more importantly what we want our country to be. Given below are 10 quick highlights amongst the numerous others that showcase this concern:

The draft policy makes the development of critical thinking and liberal thought as one of its core objectives. While the policy makers have made positive remarks around the type of holistic education that should be imparted in schools and colleges, their assumption that the same is enough to develop a culture of critical thinking and liberal thought is only the first step of what should’ve been a more robust and thoughtful strategy deployed keeping in mind the existing curriculum and student capacities to inculcate the same.

It is disconcerting to observe the choice of words used by the drafters while differentiating between the nature of HEIs envisaged by them through this policy. The drafters claim to have divided HEIs into three different “types” whereas what they have really done is create a hierarchy and tiers of HEIs. What is disturbing is instead of the aim being to ensure uniformity in standards across HEIs in a manner that gives confidence to each student that he or she is being given the best quality education that is possible, the policy drafters have instead made the gap more visible.

The drafters propose the establishment of 5 Liberal Arts Ivy-League level institutions within the next 5 years in those states that are willing to provide “a large tract of land, say 2000 acres, at an ‘attractive’ location and provide up to 50% of the funding requirements of the universities.” The NEP makes it easy for the Central Government to ignore relevant factors like the student density in an area, nearby industries for employment, which area needs development, equitable regional representation etc. If our country’s objective is to create an ‘educated India’ even the basic consideration of having an institution each in North-East-South-West-Central India would have been a more acceptable rationale than what is being proposed.

In what is one of the many stark omissions made by the drafters, they have given a complete miss to the sanitary and medical needs of the girl child which is often a major factor for their dropping out of school as well as reduced confidence levels. They also ignore that one of the biggest stains on the Indian education system has been the long standing ignorance of ragging across educational institutions. Issues such as these need special mention so that they are not brushed under the carpet, especially when it is well documented that their ignorance leads to a permanent impact on the mental health of students leading to dire consequences including suicide.

As per the drafters, a nutritious breakfast could be “even just some milk and a banana”. The ignorance of science and dietary studies is clear and the insensitivity of this statement needs no further explanation, especially keeping in mind that this policy is envisioned to remain relevant for the next 20 years.

This policy, in no uncertain terms, has declared that there should be no detention of children in grades up to grade 8. The drafters ignore the years of debate as well as the Government’s will to reverse the no detention policy as mentioned in the RTE Act and give their judgement on a highly critical policy change, through a short 50 word mention buried within the 484 pages of other text.

The drafters are clear in their stand that English is no longer the universal language that it was thought to have become and therefore the move towards local languages needs to be promoted. However flawed, even if their position is deemed to be correct, it is imperative that before propagating this change through the education system, the Government needs to first provide students with a conducive ecosystem that ensures equal opportunity irrespective of language biases at the administrative, corporate, judicial, legislative and other similar levels.

The drafters of this policy have deemed it appropriate to turn all professional institutions into multi-disciplinary institutions, thereby diluting the very essence of a professional course. Our country has worked extremely hard to empower professional colleges whether they be law schools, medical colleges, engineering institutions or others and make them compete with global counterparts. For the drafters to ignore these gigantic efforts as well as the globally established reasons for professional colleges to be standalone, seems to bring to question the objectives that we as a nation have earmarked as being critical for India’s future.

A pricking concern emerges from the treatment that post graduate (Masters and PhD) education receives at the hands of the drafters. There are constant references towards pushing “outstanding” students towards teaching. The more you read the references to mandatory teaching classes in all PhD courses as well as the focus on teaching being the natural progression from post graduate education gives a very wrong message to the student population of our country. The best case scenario for a nation is for its entire population to have received the highest level of education possible before they enter into the working world by ensuring affordability, parallel earning opportunities and societal acceptance for the same.

Amongst all the consultants mentioned in this policy, not even a single active school teacher has been formally acknowledged to have given her/his inputs. In an India that has historically struggled with school education as compared to our colleges and universities, this omission is telling of the mind space that continues in the minds of the policy framers of our country.

The core submission of this piece is the procedure which should be adopted for moving forward with the Government's initiative of developing the NEP, rather than all the troubling substantive comments that have been made earlier. Given the ambiguity surrounding the policy, it is strongly recommended that the following next steps be taken by the Government:

The drafters must be asked to make public all of their notes and materials that they have used in order to finalise this report. This is because there are many places in the report that indicate the existence of context which is otherwise clearly missing from its text. Therefore, in order to fully appreciate the intent of the drafters, it will be important to have access to everything they considered while drafting this report.

A public question and answer session needs to be organised where the drafters are made to answer the queries of the public in a sentence by sentence format based on all similar questions being clubbed together in advance.

Once the intent of the drafters has been clarified, it is imperative to establish a dedicated and full time working committee for the purpose of ensuring a well thought out National Education Policy, keeping in mind the following points:

The full-time committee should convene on a daily basis for a twelve month period.
Each week during their tenure, there should be mandatory open days for public interaction including context setting, queries and suggestions.

The progress of the committee and the open days should be recorded on a public forum on a real time basis.

This twelve month period should be structured in order to ensure timelines are being adhered to and each relevant section receives adequate time, attention and care.

Though a one year additional period for the finalisation of the NEP may sound unreasonable, however given the current state of the policy and the impact that is bound to have on India’s young workforce, it is crucial to get this right.

Disclaimer: The views expressed in the article above are those of the authors' and do not necessarily represent or reflect the views of this publishing house. Unless otherwise noted, the author is writing in his/her personal capacity. They are not intended and should not be thought to represent official ideas, attitudes, or policies of any agency or institution.

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Ramit Singh Chimni

The author is Founder of The Rasich Group and the 8one Foundation which has made its submissions to the MHRD on the NEP. He is a Harvard invited speaker with over 16 years of experience in the Social, Policy and Consulting sectors.

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