PERSPECTIVES
An Academic’s Response
Draft National Education Policy, 2019
Rowena Robinson
The acceptance of the draft
National Education Policy in
its current form may prove
disastrous for many of the gains
made in education so far, at
different levels. It will also mean
an increased political control
over educational institutions,
undermining its stated goal of
providing autonomy to them.
Rowena Robinson (rowena@iitb.ac.in) teaches
at the Indian Institute of Technology, Bombay.
28
T
he draft National Education Policy,
2019 (DNEP) has several innova-
tive ideas but it is also marked by
severe problems. Its acceptance in the
current form may prove quite disastrous
for many of the gains made in education
so far, at different levels. It is very im-
portant that there be thinking on it and
the policymakers consult members of
the teaching and student communities,
who are after all critical stakeholders in
this regard. The remarks that follow look
at school education, higher education,
and vocational education as set out in the
policy and the issue of financing, along
with some points of general concern.
With regard to pre-school education
and foundational stage learning, the pol-
icy is radical and forward-looking in in-
cluding children from the age of three
onwards within its scope and in commit-
ting to “free and compulsory quality
school education for all children in the
age group of 3–18 by 2030.” There are
other good ideas, including the use of
social workers to track children, the pro-
vision for breakfast and the use of volun-
teers to ensure that kids get to schools. It is
also good that the DNEP seeks to eliminate
junior colleges and to consider grades 11
and 12 as an integral part of the secondary
stage of education. This would reduce
the stress on students having to transfer,
at the young age of about 16, to other
educational institutions, which may also
be further away from their homes.
Loosening Control on Inputs
However, there are many very serious
concerns. Though the DNEP argues that
India’s concern with access and equity
meant that the baton has been dropped
with regard to the quality of education
(p 26), its own insistence on keeping
regulation and compliance to a bare
minimum and focusing on output, while
JULY 27, 2019
loosening requirements on inputs, con-
stitutes a very unhealthy precedent. The
focus merely on the physical and psy-
chological safety of children, the non-
profit nature of schools and minimum
standards for learning outcomes will
hardly achieve the desired goals of de-
cent, pleasant environments for students
and adequate physical infrastructure for
games, play, sport and the all-round de-
velopment of the children, which the poli-
cy everywhere seems to uphold.
Surely, for children, it is the inputs
that are absolutely crucial and which
will, in turn, ensure better outcomes for
all learners. A policy that puts inputs on
the periphery is going to the other ex-
treme of that which it seeks to avoid. In
doing so, it may inescapably be rendering
permissible the mushrooming of educa-
tional shops, quite possibly airless and
unpleasant, whereby, in the name of
philanthropy a school is opened that
merely promises literacy and numeracy
and may even be sanctioned state resources
for this purpose.
The thrust of the schooling part of the
policy is towards a certain pedagogical
and curricular organisation. It ends up
by sacrificing the physical infrastructure
of schools towards that goal. It is curious
and indeed quite disconcerting that a
policy that aims to keep children in
schools and to encourage good teachers
to enter the profession through “[a]de-
quate and safe infrastructure, including
working toilets, clean drinking water,
clean and attractive spaces conducive to
learning, electricity, computing devices,
and internet” (p 118) should then in
parenthesis state that “it must be noted
that the physical infrastructure of schools
need not necessarily be aligned with this
pedagogical and curricular organisation”
(p 74). What is one to make of this stark
contradiction?
One fears that this could become a
mechanism whereby private interests
could “volunteer” to set up schools with
the barest and lowest quality of infrastruc-
ture on the grounds that they can offer the
“pedagogical and curricular organisation”
envisaged by the policy and then ask for
and “receive various types of support
vol lIV no 30 EPW Economic & Political Weekly

from the public system” for providing
basic amenities (p 189). This does not
bode well for either access to education
or quality of education that will be
offered in such “schools.”
The Right of Children to Free and
Compulsory Education Act, 2009 (RTE)
mandated that schools make provision
for social and economic diversity. This
act has hardly been in place for 10 years
and it would not be at all in the interests
of the disadvantaged to give up its provi-
sions so hastily in favour of private
enterprise in schooling and to trust the
impetus provided by educationists or
non-governmental organisations, how-
ever well-meaning, to provide for diver-
sity without it being mandated (p 191).
Our national experience has shown that
reservation alone, mandated by law, has
managed to bring some change in the
fortunes of Scheduled Castes and socially
backward communities. Certainly, such
progress would not have been possible if
it had been left to good intentions alone.
It is not at all advisable to remove the
existing regulation and reduce the current
provisions for compliance in this regard
(provided by Section 12, 1[c] of RTE).
The policy states that it would like to
engage instructional aides to encourage
community voluntarism and bring more
women and socially and economically
disadvantaged groups into the circuit of
teaching, so as to create a truly diverse
panel of educators. This would be good
if done in a thoughtful way. A panel of
women representing marginalised com-
munities as well would build a familiar
and more age-appropriate environment
necessary at this early stage of teaching
small children. However, it is puzzling how
this emphasis shifts to the inclusion of
retired army officers or the like, a few
paragraphs on (p 61).
Language and Curricula
Further, while the policy speaks of edu-
cation in the mother tongue and local
language(s), it places far too much thrust
on this. It is not true that English education
has lost its value; parents across the coun-
try want an English education for their
children, and the global economy, for
which children need to be prepared, relies
overwhelmingly on English. It will not
Economic & Political Weekly EPW JULY 27, 2019
better the fortunes of India’s poor children
to be denied access to strong English
foundations, even while they continue
to learn at the initial stages in local lan-
guages. The well-off “elite” will, in any
case, get such proficiency in their homes
and will not study in government schools.
Denying social and economic progress
to the vast numbers of India’s deprived
and aspiring children is not a healthy
goal for our education policy. Further,
it is going to consume an enormous
amount of resources to try to better lan-
guage education in every Indian lan-
guage and try to translate all educational
curricula—including scientific and tech-
nological, philosophical and sociological,
historical and numerical—into every
such language. The endeavour is of doubt-
ful worth and is in any case not achieva-
ble at this stage. It would be best to in-
corporate the home language(s) of chil-
dren at schools—which in itself is criti-
cal and necessary—from the initial
stages till grade five, after which English
must and should take primacy, with
Hindi/a third modern language besides.
The centrality given to classical lan-
guages in the policy is excessive and
these must certainly not be made com-
pulsory for all students at any level in
the educational system. Nowhere in the
modern world has the centrality of clas-
sical languages persisted in a compulsory
mode in school education. The needs of
the current global economy, polity or
society do not require proficiency in clas-
sical languages. The classical language
option must be retained as optional, as it
currently stands, and of course, remain
open for further and in-depth study for
those who wish to specialise in these at
later stages as a chosen career option.
Further, while the accent on arts,
crafts, music and the like are attractive
aspects of the policy, there is no reason
to restrict these only to the Indian arts at
all levels. Surely, just as we would like
Indian arts to be part of curricula world-
wide, at secondary stages in our school
system, Indian children have a right to
partake of a global legacy in literature,
art, music, painting and the like. While the
words global (37), globally (3), globe (2)
and globalisation (1) occur repeatedly
throughout the text, it is indeed detrimental
vol lIV no 30
PERSPECTIVES
for a modern education policy of a forward-
looking nation to frame itself so narrowly
and in such an inward-looking manner.
Rabindranath Tagore inspired Pablo
Neruda and the Upanishads T S Eliot,
Premchand was influenced by Anton
Chekhov and Leo Tolstoy, and lines in
Tagore’s poetry recollect John Keats and
Andrew Marvell.
Such fluid movements and the circula-
tion of ideas must be appreciated and
understood by our children. Moreover,
this may be the place to argue that the
policymakers needed to take more seri-
ously the “integration” of vocational
pursuits in the school system. While
there is much talk of such integration, in
this regard the policy fails in being as
radical and transformative as it makes
an overall bid to be and vocational edu-
cation is relegated to Chapter 20, towards
the end of the document. It is indeed siloed
and there is no reason for it to be.
While the policy is clear and lays out
at length the time to be spent, the cred-
its to be earned and the kinds of lan-
guages, arts, music and crafts to be
learned in schools, it is curiously laissez-
faire about vocational training. It is left
to the schools to choose according to the
facilities they have and what they can
manage and handle, and students to opt
from what will be on offer. This just, as
surely, instils all kinds of invidious divi-
sions into the curricula between cognitive
and intellectual, linguistic and “artistic”
competencies versus the manual, the
“practical” and the “labouring” skills.
Not only is this kind of divide unhealthy
for the development of a new generation
of children with all-round potential and
makes a dilution of equal opportunities
for all, but it is also unhelpful if we are
serious about increasing creativity and
innovativeness. Making, doing, designing
and working with material culture cannot
and must not be separated from thinking,
writing, reading, and communication: it
available at
Gyan Deep
Near Firayalal Chowk, Ranchi 834 001
Jharkhand
Ph: 2205640 (0651)
29
PERSPECTIVES
is the integration of these and the cross-
fertilisation that results in liberal educa-
tion—everywhere cited as the central
goal of the DNEP—achieving one of its
critical benefits.
The decentralisation of board exami-
nations for the 10th and 12th standards
is a worthy goal of the policy, but per-
plexingly it is replaced by the semester
system and multiple boards and a further
break up into the following stages (5 + 3
+ 3 + 4). This is only likely to increase
stress for all students at all levels and
promote greater anxiety throughout the
system. The policy suggests that this will
be avoided because of the overall reduc-
tion of load and core curricula and as
evaluation on these will be limited to
basic texts. However, while this seemingly
achieves the goal of de-stressing students,
it must be viewed with caution.
The world of learning has increased
immensely, as have the requirements for
citizens and for potential employment.
Surely the education policy aiming to
achieve the goal of decent work for all
the young people who will pass through
the system, should ensure the gain of
more complex skills and increased un-
derstanding and knowledge for them.
We will not be doing a service to any of
our children, particularly to those for
whom public education is the only way
out of poverty and disadvantage, by
teaching them less than they need to
know and not balancing the curricula in
a way that will prepare them well for the
rapidly changing world of work.
The integration of isolated schools
into school complexes again seems both
radical and innovative. However, it risks
losing precisely what one had gained
over the last so many years—access to
education close at hand. The system
would involve bringing together the fa-
cilities within a 10 mile (16 kilometre)
range. Facilities, and in some cases teach-
ers as well, would be shared across
schools within a circuit this large. This
reintroduces distance and the concerns
of access, the need for transportation,
problems of safety and security and
reach that we have been all along trying
to avoid.
It will hardly improve the quality of
teaching if instructors have long distances
30
to travel each day across different
schools within such a large complex.
How will timings be managed and how
will children be transported from one
school to another in rural areas if they
are to use laboratories and libraries far
from their home area? The burden of
managing all this is placed on the sec-
ondary school and its principal: this will
increase the load that they will have to
bear and reduce the time and attention
that need to be paid to the quality of sec-
ondary education.
Education and Democracy
Moreover, in every democratic society
around the world, the larger purpose of
education is active citizenship and aware-
ness of human and fundamental rights.
This critical goal is cited by the policy at
the beginning when it quotes the “historic
Universal Declaration of Human Rights,
adopted at the UN General Assembly in
1948,” wherein it was declared that “edu-
cation shall be directed to the full devel-
opment of the human personality and to
the strengthening of respect for human
rights and fundamental freedoms” (p 24).
However, this purpose of education in
fostering thinking citizens is not borne
out by a curriculum which under-stresses
civics, political science, geography, the
understanding of government and its
structures and the like. Moreover, the
policy seems to end on a note stressing a
far narrower economic logic for educa-
tion, seeing it as a “quasi-public good”
(p 399). It must be noted that in addition
to preparing children for occupations in
the modern world, one of the fundamen-
tal aims of liberal education is critical
thinking. To think of liberal education
in a traditional mode as a study of the
kalas (p 86) is not sufficient.
Throughout the world, liberal educa-
tion is understood as preparation for
“responsible citizenship,” in terms of
“empowerment” and as a course of edu-
cation suitable for a “free” human being.
It is within the framework of democracy,
of constitutional freedoms and funda-
mental rights that the aims and purpose
of liberal education must be defined and
must unfold. If we as a country set out to
do anything less we risk lowering our
educational standards—and ourselves
JULY 27, 2019
in the eyes of the democratic world—to
the training of subjects, not the creation
of rights-bearing citizens.
Higher Education
It is the context of higher education that
the policy, unfortunately, shows up a
considerably skewed or flawed under-
standing of Indian institutional and so-
cial realities. There are some ambitious
projects such as moving to the four-year
liberal arts model of undergraduate
education, the removal of the MPhil
degree, the closing of all affiliated col-
leges through conversion to universities or
by autonomy and so on. However, these
may overall be more radical than realistic.
Of course, Indian Institutes of Technology
(IITs) and some other educational
institutions at that level may not experi-
ence upheaval within the new system;
however, most of our higher education
takes place in state universities, and the
implications of the policy for these should,
therefore, be taken quite seriously.
In this regard, the new division proposed
by the draft policy between research uni-
versities, teaching universities and col-
leges, is both impractical and invidious.
While it is true that certain kinds of
research in India often took place out of
the university system in smaller institu-
tions, this did not foreclose the possibility
of research within the former and certain-
ly, no labels were applied in the past. The
new labelling will lead to stratification
and further lack of access to funding and
inequalities of resources for those in
“teaching” universities who are currently
engaged or wish to pursue research. It will
quite possibly kill research in many uni-
versities, instead of building their capaci-
ties for research. Moreover, what will
happen to colleges? How many independ-
ent colleges will public funds maintain?
The mandated amalgamation or
autonomy provisions recommended seem
to lead logically to the possibility of the
rapid privatisation of many colleges to fit
the needs of the policy, with the atten-
dant problems of high fees, reduction in
the number of seats available for socially
and economically deprived sections and
so on. Secondly, it must be recognised
that the system of affiliation is central to
the financial health and stability of most
vol lIV no 30 EPW Economic & Political Weekly

universities around the country at this
moment. To shut off this option within a
year’s time (2020) is hugely impractical.
Many state universities keep themselves
financially afloat through fees of affiliation,
examination and the like.1 They would
simply not be able to function or carry out
even basic activities without these funds.
Research Funding
When it comes to research funding, cur-
rently existing bodies such as Department
of Biotechnology (DBT), Department of
Atomic Energy (DAE), Indian Council of
Social Science Research (ICSSR), Univer-
sity Grants Commission (UGC), Indian
Council for Philosophical Research (ICPR),
and Indian Council of Historical Research
(ICHR) which are better aware of subjects
and disciplines and professional standards,
are to be largely replaced by a catch-all
body the National Research Foundation
(NRF). This is not a model followed in
most developed countries.
For India, it is advisable to separate
funding for science, technology, engi-
neering, and mathematics (STEM) and
the humanities and ensure adequate
funding for all research. Further, merging
all research under one body runs the
risk that in the general provisions of the
research council “scientistic” influences
and logics might prevail. These may
often be detrimental for the appreciation,
understanding, and promotion of research
in the humanities.
Moreover, while it is accepted in the
policy that bodies such as DBT, Indian
Council of Medical Research, Indian
Council of Agricultural Research and DAE
may continue to fund scientific and tech-
nological research (p 272), nothing is
said about bodies such as ICSSR, ICHR,
ICPR and the like. What is specified is
that the UGC will also not engage in re-
search funding (“It shall also not fund
any research … including for research
infrastructure” [p 332]) and with regard
to the NRF funds, it says:
In general, science and technology will require
much higher levels of funding for labora-
tory equipment, experiments, etc. How-
ever, funding for the humanities and social
sciences will be increased considerably from
present levels, in recognition of the fact that
such areas have been ignored in the country
for far too long. (p 272)
Economic & Political Weekly EPW JULY 27, 2019
This has to be laid against the fact that
unlike for the sciences, for the humanities
and social sciences, no other body will
be funding research. In effect, this
means an overall decrease in funding for
the humanities and social sciences and
not the other way around. The use of pri-
vate funding, including corporate social
responsibility (CSR) funding in the NRF, is
a model followed in some countries but
requires strict regulatory norms to en-
sure that conflict of interest is avoided,
and basic and not just applied research
continues to be a high priority. Moreover,
in the light of the aim to expand higher
education in all parts of the country, the
proposal to have just 500 doctoral and
500 postdoctoral fellowships seems paltry.
Finally, the policy’s statement that “only
the government can have the perspec-
tive to drive the research that will result in
innovations that will facilitate economic
growth” (p 267), is neither true nor healthy
for the flourishing of research. Through-
out India’s development in the post-inde-
pendence period, researchers, scientists
and experts of all kinds have played a
very vital role in helping and advising
governments, in building institutions and
driving research in areas that have led to
innovation and economic growth.
Doctoral Programmes
The requirement of courses (8 credits) in
teaching and pedagogy for all doctoral
students is not advisable (p 292). First,
not all doctorates become teachers; many
go into industry or other fields. Second,
in a five-year funded programme of
research, wherein one wishes to ensure
the quality of the research itself, such a
mandated requirement would consume
time needed to hone the student’s re-
search and methodological skills and his
or her advanced learning in the subject.
As a country, we need to develop first-
class research at the doctorate level. The
problems of low-quality research, of pla-
giarism and the like have been a worry for
some time now. Teaching credits should be
acquired additionally and outside of the
research duration of five years by those who
wish to opt for teaching and should not be
mandated within the programme for all.
Second, and partly for the same rea-
sons as above, the requirement for all
vol lIV no 30
PERSPECTIVES
doctoral students to take a unit in an
Indian language other than English should
be removed. This is justified in the policy
in the context of developing their ability
to write newspaper articles or conduct
interviews in Indian languages in their
subject areas (p 233). However, not only
are the requirements of written and oral
communication quite different, the art of
translation is a difficult and laboured
one and not one that can be learned by
all students. Certainly, it would come at
the cost of time needed for research ex-
cellence, and not all research needs to
be so translated.
Translation of certain quality research
into mainstream Indian languages is not
in itself an unworthy effort. However,
the burden of this should not be placed
on the researcher. If students so choose,
they should have the option of taking
extra language courses as additional
credit. This is even more important given
that the policy envisages bringing more
international students to India, who
would not face such a requirement.
Certainly, we should have parity among
students and not place more demands
on Indian students in relation to others.
Diverse Issues
The proposed closure of the MPhil pro-
gramme and restriction of the powers of
the UGC need to be thought out much
more carefully in relation to their
implications for social justice and the
maintenance of standards. While there
have been problems for a large organisa-
tion such as the UGC, the proposed plan
to replace its regulatory function with
a stress on outputs and quality of out-
comes, without an emphasis on inputs
and processes (p 326), is not healthy.
It opens the way for private initiatives in
accreditation (p 329), and overdue reliance
on these to evaluate institutions will
undo efforts to actually ensure minimum
standards (and their gradual improve-
ment) of infrastructure in colleges and
universities, as well as increased access
and availability for historically deprived
castes and classes. Neither outcome is con-
ducive to improving higher education.
The proposed National Repository of
Educational Data (NRED) to maintain
individual records in a single database of
31
PERSPECTIVES
all teachers and students—accessible by
Aadhaar numbers—has complex and
serious implications for the possible
targeting of individuals, privacy and
security, and is highly inadvisable. Indi-
vidual data must be stored at an institu-
tional level, while collated and anonymised
data useful for the making of policy may
be stored in a single database.
Finally, the proposed tenure system
with a five-year probation period would
be quite detrimental to encouraging
good teachers to come into the profession,
particularly in the planned “teaching
universities.” Given that such a top-down,
government-heavy architecture opens
the way further to political influences in
recruitment, universities will be recruit-
ing teachers who do not think for them-
selves but due to the fear of trying to
keep their jobs will be rubber stamps of
the authority structures above them.
Moreover, if research is de-emphasised,
what will the teacher be evaluated on?2
There are several other issues that
need serious reconsideration, such as al-
lowing nurses to compensate for the lack
of doctors (p 306). Mainstreaming tradi-
tional medicine and allowing people the
choice of medical regimes is not unac-
ceptable; however, patients must be aware
of the doctor’s qualifications and what
treatment (allopathic, homoeopathic or
other) they are being offered in multi-
specialty clinics and hospitals. These
must be clearly indicated.
Moreover, while traditional law may
be studied as part of legal history or
legal anthropology, for law graduates to
compete and have “occupational readi-
ness,” as well as to contribute significantly
to policymaking in the country (p 244),
what is more crucial is rigorous training
in modern legal systems and in interna-
tional law and in the special and newly
evolving domains such as maritime law,
environmental law, healthcare law, intel-
lectual property, patent law and the like.
Financial Issues
While the DNEP makes laudable asser-
tions that financial autonomy for higher
educational institutions will not mean
lower government spending, that funds
must be released early in the year and
that institutions should have flexibility
32
in the way allocated funds are utilised,
subject to financial integrity, there is a
drift towards privatisation and potential
withdrawal of public funding in higher
education that underlies the policy. This
appears in its insistence that all higher
educational institutes set up effective
structures for raising resources through
a “development office.”
As mentioned earlier, it also underlies
the proposal that all colleges must be
autonomous, affiliation must cease, and
that private and philanthropic educa-
tional efforts must be encouraged by
de-emphasising inputs and processes.
Thus, logically the proposal would also
tend towards the increase of fees for
higher education. When combined with
the fact that the policy envisages reduc-
ing the number of institutions through
closing down those which cannot attain
autonomy and amalgamating those that
can achieve multidisciplinary status as
“research” or “teaching” universities, the
goal of access to education recedes rather
than comes closer.
The proposed setting up of new inter-
university centres is not likely to achieve
the desired goals; experiments in this
regard in the past have shown mixed
success. Moreover, starting more univer-
sities for the liberal arts may be a mis-
placed idea; it would be better to rejuve-
nate existing universities. The policy
further does not mention that through
the Higher Education Financing Agency
(HEFA), public investment in infrastruc-
ture development of higher educational
institutions is already effectively a matter
of the past.
Financing of higher education through
public funds occurs in Addendum 1 in
the DNEP. The figure of 10% of total gov-
ernment spending is quoted, alongside
the fact that investment in education in
India has been hovering around 3% of
gross domestic product (GDP) (p 402). It
is not entirely clear how the first figure
of 10% has been reached, but the policy
does shift suddenly after espousing
throughout the text that there should be
increased public funding for education
to asserting that India can only reach
the desired 6% if the “tax-to-GDP” ratio
improves (p 406). Surely if countries
such as Bhutan, Zimbabwe, Costa Rica,
JULY 27, 2019
Palestine, Mongolia, Kenya, and Kyrgy-
zstan are able to spend more on educa-
tion (p 402), India needs to rethink not
the amount collected in taxes but the
proportion of those needed to be set
aside for the urgent task of education,
regardless of other investments.
Autonomy and Political Control
Most importantly, contrary to the goal of
autonomy stated throughout the policy
(110 occurrences), the policy envisages a
centralised and tightly structured system
that will be under the direct control of
political leaders of the government of the
day. The educational architecture propo-
sed by the policy, in particular the Rash-
triya Shiksha Aayog (RSA) at the national
level (and the Rajya Shiksha Aayog [RjSA]
in each state), which will be in charge of
all aspects of the educational system—
regulation, teaching, curriculum, research
funding and every other matter—is un-
precedented and entirely unhealthy for
the flourishing of the educational system.
This body, the RSA, will stand above
even the Ministry of Education (as the
Ministry of Human Resource Develop-
ment is to be renamed). The RSA will be
directly headed by the Prime Minister
and the RjSA by the chief minister of every
state. Appointments to the RSA will be
made by a committee consisting of the
Prime Minister, the Chief Justice of India,
the speaker of the Lok Sabha, the leader of
the opposition in Parliament and the
union minister of education.
The proposed architecture undermines
effectively and completely the stated goal
of autonomy. It will bring even greater
and more authoritative external inter-
ference in all aspects of the functioning
of educational institutions—curriculum,
recruitment, research funding, infra-
structure development and the like—
and it manifests a remarkable lack of
trust in the abilities of educationists to
run or manage the educational system.
Such breathtaking political control of
the educational system is highly detri-
mental and absolutely inadvisable for
the country.
notes
1 Thanks to D J Saikia for pointing this out.
2 D J Saikia pointed this out.
vol lIV no 30 EPW Economic & Political Weekly