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Draft National Education Policy 2019 deserves to be rejected outright

Draft National Education Policy 2019 deserves to be rejected outright

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Shikshan Sangharsh Samanwaya Samiti
(A Co-ordination Committee on Draft NEP 2019)
Contact Info.: Address- c/o Harishchandra Sukhdeve, C-4, Mulik Complex,
Somalwada, Wardha Road, Nagpur – 440 025

(Letter to HRD Minister and all MPs)

5 September, 2019

Hon’ble Member of Parliament,
New Delhi

Respected Madam / Sir,

Subject: Draft National Education Policy 2019  deserves to be rejected outright

The National Education Policy 2019 (NEP 2019) is likely to be introduced soon in the parliament. Government of India had sought suggestions from the public on the draft policy which was placed in public domain in the first week of June 2019. The full draft of NEP 2019 was made available only in English and Hindi to the public. On serious study of the same, we have come to a conclusion that any corrections in the draft policy is not going to make it worth adopting for the nation. The draft policy cannot help achieve the objective as stated in the Vision of the draft i.e. “an India centred education system that contributes directly to transforming our nation sustainably into an equitable and vibrant knowledge society, by providing high quality education to all.” (page 45) The draft NEP 2019 envisages to achieve this goal through “the revision and revamping of all aspects of the education structure, its regulation and governance.” (page 24)

The Revision and Revamping of the present education structure as suggested in the draft NEP 2019 is without any empirical evidence on any aspect and without any application of mind though its honourable Chairman Padma Vibhushan Dr Kasturirangan claims it is ‘out-of-the-box’ thinking by the Committee. In fact, there is enough ground to believe that all that revamp and revision has some hidden meanings. The draft policy is not honest in its objectives and therefore in its recommendations. Here are few examples:

1. Revamp means more autonomy for complete privatization & profiteering?

The draft NEP 2019 strongly recommends complete autonomy to the managements at all levels. It proclaims “It is only when institutions, school complexes, colleges and universities are autonomous and empowered to deliver on the goals of the Policy that we will have a responsive education that is key to achieving a knowledge society.” (page 31) “Institutional governance will be based on full autonomy – academic, administrative and financial – for all higher education institutions (HEIs) with financial certainty and backing”. (page 312) The complete autonomy – academic, administrative and financial – is not only for HEIs only but also in early childcare education and above.

In a section sub-titled as ‘Facilitating setting of up of high quality philanthropic institutions committed to inclusion’ in Addendum_1 policy says “These institutions must have complete financial and curricular autonomy as described in Section 17.1 on ‘Empowered governance and effective leadership’ (See P17.1.20 and P17.1.21). This encouragement to set up new high quality institutions would focus on priority areas; e.g. early childhood education in underserved geographies and for excluded populations, in higher education leading to liberal undergraduate degrees, in teacher education and in preparation of medical professionals. Involvement of industry bodies in the improvement of quality of technical education is also to be promoted”. (page 410). Will these philanthropic institutions ensure financial certainty and backing as envisaged on page 312 for all times and for all the people?

We demand that Government should take responsibility for all expenditure on education and provide 6% of GDP as has been recommended in all the previous policies. Government may take funds from the philanthropists but without any control and autonomy of education institutions.

2. Revamp means complete autonomy for discrimination in teaching and in offering curriculum courses?     

While recommending autonomy to teachers in choosing finer aspects of curriculum and pedagogy, the committee gloats about the role of ‘gurus’ in ancient India. It claims “Only the very best and most learned became teachers. Society gave teachers, or gurus, what they needed in order to pass on their knowledge, skills, and ethics optimally to students; in particular, gurus were given full autonomy to decide how best to carry out this creative process, and as a consequence, they did their very best to develop personalised learning plans for every student in order to help each student achieve her/ his life’s potential.” (page 113)

Not many will agree that these ‘gurus’ have created equitable, vibrant knowledge society in our nation. This country was home for all sorts of invaders for centuries because more than half of its population was rendered irrelevant by those very Gurus! If that kind of autonomy is to be bestowed on the teachers and also on the parallel structure of Social Workers and Counsellors as proposed in the draft policy, our society is doomed to be pushed into that dreaded graded inequality.

The so-called personalised learning plans of these gurus were nothing but caste and varna based vocations and skills to strengthen the supremacy of few. The policy recommendations for offering various vocational and extra-curricular subjects as main curricular as early as in 8th standard with autonomy to Teachers and Social Workers/ Counsellors is a sinister design to push URGs and poor out of any meaningful education which leads to one’s emancipation and freedom. [URGs – the “Under Represented Groups” which includes all women, the SC/ST/OBCs, Muslims, minorities, transgender, differently abled people and all those who have difficulty is learning].

The draft NEP 2019 recommends amendments in the Right to Education Act (RTE) only because its clause 12(1)(c) “is not quite in tune with the principle of autonomy of institutions (including for student admission) in this Policy, which empowers schools and trusts them to do the right thing” (page 193-194).

Trust the schools to do the right thing, without force of law? What a benevolence for autonomy!

It recommends “The Higher Education Institutions (HEIs) will be governed by Independent Boards, with complete academic and administrative autonomy.” (page 210) They will have autonomy on curriculum, pedagogy and assessment, autonomy in recruitment and also in deciding fees for higher education courses. “In line with the spirit of providing autonomy to educational institutions to charter their own course, fees for professional education courses will be left to the management of educational institutions, both public and private.” (page 300)

Will such a sweeping autonomy really create an Equitable society? Or will it push those on the margins out of the sphere of consideration itself rendering them irrelevant to the nation? More likely to be so because education will become inaccessible and unaffordable for a large section of the society. It is not that the Committee is unaware of these reasons. It acknowledges these reasons and ‘innovated’ another term called URGs, the Under Represented Groups (or areas) of socially & economically backward people.

The Committee does not seem to recognise the Constitutional definition of Social & Educational backwardness. Or it believes there is no Educational Backwardness in the country. If that is so, why revamp and revise the system so drastically?

Whom does this draft policy want to empower with autonomy and with what goal? The empowered teachers, social workers, counsellors and autonomous school managements will only exploit the students and parents with inferior courses and discriminatory teaching methods and facilities.

We demand that government should provide same kind of infrastructure and same kind of education to all without any stratification. The revamp is required to dismantle various models of education, private and public, and make all schools and institutions government owned. There need not be any autonomy to anybody but only well researched teaching modules for effective education.

3. Revamp means Govt.’s handing over education sector to private philanthropists:  

The NEP 2019 recommends establishment of Rashtriya Shiksha Ayog (RSA) who will issue common national guidelines for all legislative Acts that will form private HEIs. These common guidelines will cover Good Governance, Financial Stability and Security, Educational Outcomes, and Transparency of Disclosures. These guidelines will enable consistency across the country, and will enable Acts to be similar to the ‘HEI charter’ and the ‘model act’. The policy believes that “such an action will ensure that establishment and functioning of such private HEIs is for not-for-profit public spirited purposes and not for commercial purposes.” (page 334) The draft goes on emphasising need for philanthropic funds in all sectors of education and recommends for complete autonomy to the investors.

In RTE revamp, draft policy recommends to “trust the Schools to do the right things”. In HEI revamp, it believes that these private HEIs will work for not-for-profit public-spirited purposes and they will not indulge in commercial activities. In School Complex models it recommends shutting down of ‘unviable’ schools. What a confused ‘out-of-the-box’ thinking!

But then you can’t blame the Committee which believes that our ancient Gurus were public spirited and taught with the aim of social inclusion!
The Committee cries hoarse about the perils of privatization and how it led to profiteering and commercialization of education making it unaffordable and inaccessible for many. But it goes on strongly recommending that very privatization for sacred cows, the philanthropists.

Addendum-1 elaborates about importance of investment on education and declares that “In summary, investment in education is perhaps the best investment for a nation.” (page 401) “This Policy unequivocally commits to raising investment in education substantially – including a significant increase in public financial investment, as also in philanthropic investment.” (page 399) As mentioned in point 1 above, the draft policy recommends fully autonomous philanthropic institutions even in early childhood education for underserved geographies and for excluded populations.

Policy states that “certain regions of the country with large populations from URGs should be declared Special Education Zones (SEZs), where all the above schemes and policies are implemented to the maximum through additional concerted efforts and funding from the Centre and States in order to truly change the educational landscape of these Zones.” (page 140) The policy recommends SEZ concept to be funded by the State and Central govt. for educational development of URGs. But as already mentioned, in “Making it Happen” section Addendum – 1 it recommends for philanthropic autonomous institutions with focus on priority areas from ECCE onwards. Another confusion!

The draft policy recommends for encouraging funding from philanthropists and giving them complete autonomy without any empirical evidence. The Committee seems to propose that the philanthropic institutions are all for charity without any vested interests and ideology. Nothing can be farther than truth considering research in developing countries from Africa.  

A published well documented research paper ( “Institutional Voids and the Philanthropization of CSR Practices: Insights from Developing Economies” concludes that –

“This is akin to aid that hardly contributes to structural changes, but rather leads to complacency, corruption, dependency, boutique projects, disguised exploitation, and the misuse of corporate political power to achieve corporate bottom lines. The implications of the results are vast, and they are generalizable to all weaker institutional settings. Thus, weaker institutions create the necessary regulatory, political, economic, and governance climate that perpetuates a pattern of abuses and ethical violations that are then masked with philanthropy.” India is no better than any developing country when it comes to weaknesses of the public institutions.

If privatization is bad in education it is bad even with philanthropy funds. These must not be sought at the cost of autonomy to the donor. Such a system will defeat the very purpose of equitable and quality education to all. The donor will try to introduce curriculum to create slave labour for his own enterprise.

Does the government want to leave all URGs and excluded sections at the mercy of so-called Not-for-Profit Philanthropists while giving all the autonomy and access to natural resources for setting up SEZs and School Complexes? Will it secure equitable, affordable, accessible quality education for them? Will it secure the fundamental rights of children for free and compulsory education as per RTE which the draft proposes to extend to the 12th standard?

We demand that the Government takes responsibility of educating its own people with the same kind of infrastructure for the URGs. They should not be left at the mercy of outsiders in the name of philanthropists.  

4. Revamp means to create dubious diversionary codels like school complexes and SEZs?

The policy recommends yet another ‘out-of-the-box’ thinking model of School Complexes and SEZs. The School Complex concept is borrowed from earlier policies without going into any study as to why it did not even start for all those years. The Committee recommends  
“Multiple public schools will be brought together in an organisational and administrative unit called the School Complex. This will not require physical relocation of schools. Each individual school that is viable in size will continue to function even as it is integrated administratively into a school complex.” (page 160) It is self-contradictory. On one hand it says no relocation and in the same breath says individual school that is viable in size will continue.

What is unviable school which may not continue? If it does not continue, then what happens to it? What are the parameters for deciding viability? If that is ‘income’ or even ‘saving on Teachers’ salaries’, then it is commercial consideration. How the policy expects that philanthropists will have no similar commercial considerations about viability?

Doesn’t this committee believe that education is need of the nation and needs to be taken to the doors of the people? If that is the objective of the policy, then the committee miserably fails in imagination to suggest strong measures. School Complex is a bad idea if the viability of school is based on its size instead of its need for the children. SEZ is equally bad if it is targeted at URGs to groom them to be slave labours of the sponsoring party. It is an evil idea to deprive these classes of people from quality higher education which will only perpetuate the inequalities of caste system.

We demand that the first criterion for viability of any school should be its accessibility and proximity to the children depending upon their age. The school complex and SEZ are discriminatory models for the URGs which must not be implemented.

5. Revamp means the creation of confusing parallel functionaries?

The draft policy recommends “Adequate numbers of social workers will be appointed to the School Complexes depending on the student population and the population of adult learners in that geography. While the teachers will have the central role in student care and well-being, each school complex will have one or more capable counsellors available.” (page 162, 163)

The arrangement for Social Workers and Counsellors appears to be parallel to teachers and education administration considering their role in School Management Committees and reporting authority. It will be very chaotic at local levels and demoralizing for the teaching community.

More than that they will be agents to perpetuate various kinds of discriminations prevalent in our society. In a recent infamous, but not isolated, episode of using colour bands to denote different caste status of students in certain schools in Tamil Nadu, the Director of School Education, Chennai observed “Allegedly, these practices are enforced by students themselves and supported by influential caste persons and teachers.”

There are umpteen cases of gradation and discrimination on the basis of castes all over the country. In all those cases local influential people and teachers are responsible for perpetuating these practices. With the parallel structure of Social Workers and Counsellors, it will only get institutionalized. There are enough reasons to believe so because of nature of the +4 structure as a modular secondary education.

We demand that there should not be any intermediaries in education sector between teacher and the pupil unless their duties and responsibilities are well defined. They should be professionally trained.

6. Revamp means offering trivial & deceptive modular Secondary Education?

The draft policy recommends that “The Secondary Stage will comprise four years of multidisciplinary study, and will build on the subject-oriented pedagogical and curricular style of the middle stage, but with greater depth, greater critical thinking, greater attention to life aspirations, and greater flexibility and student choice. Each year of the Secondary Stage will be divided into 2 semesters, for a total of 8 semesters. Each student would take 5 to 6 subjects each semester. There will be some essential common subjects for all, while simultaneously there will be a great flexibility in selecting elective courses (including in the arts, vocational subjects, and physical education) so that all students can expand their horizons as they see fit and explore their individual interests and talents.” (page 75, 76)  “All school subjects will be considered curricular rather than extra-curricular or co-curricular, including sports, yoga, dance, music, drawing, painting, sculpting, pottery making, woodworking, gardening, and electric work.” (page 78)    

It is far-fetched an idea to expect that students can expand their horizons as they see fit and explore their individual interests and talents at secondary stage of schooling. Offering vocational subjects as academic education itself is pushing them away from the opportunities of higher education. There is every chance the wards of illiterate rural populace, SCs, STs and OBCs, even Muslim minorities and women will be thrust upon with more of vocational courses strengthening their respective caste vocations in many cases. Should the education be to overcome caste disabilities, or to strengthen them?

We demand that the extra-curricular and co-curricular subjects should not be converted into curricular ones because it will stray students from core subjects meant for higher education. Its thrust on URGs is disturbing. Govt should ensure that all sections of the students get same quality school education after which they should be able to choose the vocations of their choice for higher education.

7. Revamp to abolish reservations?

The draft policy recommends that “All private HEIs shall be governed and regulated with norms identical to public institutions, unless otherwise specified. Private HEIs shall not be mandated to adhere to reservation guidelines other than those stated in this Policy and their formative Acts with respect to local State students.” (page 334)

It is so deceptive that the ‘reservation guidelines other than those stated in this policy’ are nowhere to be seen in the whole policy. In the entire draft of about 500 pages, word “Reservation” appears only once on page 334 and that too in denial as stated above.
The private HEIs though privately funded will be enjoying several state benefits and regulatory norms identical to public institutions, they shall be made liable to provide constitutional reservations to ensure diversity. Indian HEIs are notoriously exclusive which needs to be corrected to achieve the stated vision of equitable education.

We demand that Government should ensure compliance with Constitutional provisions for affirmative action by way of reservations in education so that adequate well qualified young people are available for giving representation in government positions at all levels. It should reflect well in the policy document. The concept of reservations should be implemented in its true letter and spirit without yielding to the subjective concept of merit based merely on score in any examination.  

8. Revamp to abolish scholarships?

The draft policy recommends that “a special National Fund will be created specifically for providing scholarships and developing resources and facilities for students from URG. Students will be able to apply for financial support in a simplified manner – from a single national agency or a “single window” system – and will be able to register complaints if they are denied due support or services.” (page 143)

The issues of reservations, scholarships and higher education are examples of how callous this ‘out-of-the-box thinking’ Committee was to the needs of the URGs which constitute not less than 90% of our population. Just as Reservations, this word ‘National Fund’ appears only once in the whole policy document. There is no explanation how this ‘single window’ concept of dispensing scholarships to the lakhs of needy will be implemented, what will be the structure of that ‘National Fund’ and other modalities. The draft policy is notoriously ambivalent about the educational needs of the discriminated sections of the society, for whom it has evolved a wholly unconstitutional term of URG.

We demand that the scholarships should be offered to the needy students at their door steps considering their socio-educational backwardness and other suitable aspects in deserving cases. The scholarship should be available to the students without making them struggle to get it. It should reflect well in the policy document.

9. Revamp to create “Ghettos” of URGs?

It should not be a surprise, though. The Committee, rather maliciously, says in chapter titled “Recruitment of teachers from SC and OBC communities: Affirmative action in higher education space has allowed for a significant number from marginalised communities acquire teaching degrees. However, due to the various disadvantages they carry forward, many find it difficult to obtain a job.” (page 148)

The remedies it suggests in the same chapter are still atrocious. The draft policy says “Special initiatives should be taken up by the concerned ministries and departments to up-skill them and prepare them to be recruited as teachers in schools, especially in their home regions where they can become excellent role models. In addition, in geographies where SC and OBC teachers are underrepresented, scholarships will be offered to the best students and IAs from SC and OBC communities to enter outstanding teacher education programmes and become teachers; efforts will be made to employ them in these areas after they complete their education.” (page 148)

One wonders whether our draft NEP 2019 intends to create ‘Ghettos’ for the SC/ST/OBCs and other URGs through the SEZ and such recruitment policies as mentioned above!

We demand that the concept of SEZ should be dropped completely from the policy. It is the worst kind of stratification to limit URGs to the education of liberal arts to make them slave labours.

10. Revamp to relegate women to the status of secondary citizens?

The draft NEP 2019 is written like some definitive novel when it comes to education of girls and women. A two-page exclusive chapter on page 145/146 mentions various measures for ensuring safety and discrimination free environment in schools and colleges. It also speaks about formation of ‘Gender-Inclusion Fund’ to build the nation’s capacity to provide quality and equitable education for all girls, focusing on five pillars.

Elsewhere though it looks at women in society as someone different than the normal human being inviting discrimination. Considering its “ghetto” like environment and stress on liberal arts till graduation, focus on women education within URGs will result into promoting obscurity rather than empowerment. This is important in the light of policy’s overall focus on family oriented Indian values which are basically patriarchal in nature.  

Above mentioned ten issues, and many other, are critical for any forward-looking nation with the best ever demographic dividend in the world. It is important that we focus our education policy to harness it to the best possible capacity to create world class scientists and humanists to defend our nation and democracy. The draft NEP 2019 absolutely fails in these objectives because of lack of vision and partisan approach to educating our own people. It is ‘We’ and ‘They’ approach rather than ‘We the People of India’.

Therefore, the draft NEP 2019 is against the principles of the Constitution of India and deserves to be rejected outright.

It violates the Articles 15 and 16 of the Constitution of India by not identifying and not making recommendations for the Socially and Educationally backward classes. In fact, while defining URGs it relies on socio-economic backwardness. Ironically, the draft policy on Education has no comments neither any data on prevalent educational backwardness in the country.

It violates the Fundamental Right to Education of all children as envisioned in the Constitution of India and is ignorant about the role of the government to provide free, compulsory and equal education to all. Instead, it further promotes drastic stratification of education for elite, the middle class and URGs. Why URGs should be restricted to SEZ and graduation in liberal arts which is not suitable for higher education.

It violates the Fundamental Rights of Equality by creating stratification in the models of education, not only for HEIs but even at school level, thereby strengthening inequality and discrimination in education, employment opportunities and self-emancipation.

It has failed to offer detailed study and analysis of what is wrong with the present system in various sectors thereby negating the Constitutional spirit of scientific temper and reasoning in policy formulation for the nation.

It is confused about financial outlay for such a drastic revamp of education system which it suggests. While it supports the State spending to the extent of 6% of GDP as recommended in earlier policies but at the same time strongly favours for linking it to the present levels of about 10% of the government spending and introduces uncharted funding from the philanthropists which is nothing but disguised private funding with complete autonomy for privatization and profiteering.

The draft policy fails on fathoming the complex issue of languages in a diverse nation of ours and proposes to offer obsolete and irrelevant Sanskrit at all levels. It will be thrust on students and parents who has no say in such matters. This violates their freedom of choice denying opportunities for potentially beneficial languages and disciplines for higher education.

Therefore, the draft policy should be rejected outright for the above reasons.

Sir, you will agree with us that no amount of corrections can improve it.

We demand that a new Education Commission shall be appointed to frame a comprehensive policy commensurate with Constitutional objectives of Inclusion and Diversity to cater to the needs of diverse communities for prosperity of all people of India.

Sir, please raise these issues in the parliament and also at other forums which are accessible to you. We assure that we are not politically affiliated to any party or ideology. These are the views of concerned citizens from diverse fields of India. Please feel free to seek any additional inputs if and when necessary.

With high regards and best wishes,

Yours sincerely,

Harishchandra Sukhdeve                      
Shikshan Sangharsh Samanwaya         
Samiti, Nagpur Distt                

Ramesh Bijekar
Shikshan Sangharsh Samiti,

Vijay Meshram (IRSS Retd)
National President,
Samata Sainik Dal
Former National President,
Dr Babasaheb Ambedkar
National Association of Engineers

E Z Khobragade            
IAS (retd)                
Founder President,            
Maharashtra Officers’ Forum         

Milind Fulzele
Resident Editor,
Jantecha Mahanayak,

Ashish Fulzele                        
Human Rights Protection Ambedkar Forum,

Shashikant Humane
Bahujan Hitay Sangh,

Kuldeep Ramteke
Former National President,
Dr. Babasaheb National Association of Engineers

Amitabh Pawde             
Jawahar Edu. Society         

Dr Suchit Bagde
Dr Babasaheb Ambedkar
Health Organization

Dr Subhash Nagrale                       
Dhamma Sangoshthi Group                                           

Prof. Ghansham Dhabarde                       
Buddha-vihara Samanwaya Samiti

Sudhakar Dubey           
Bahujan Maitri Sangh,

Shriram Bansod                 
Dhamma Sangoshthi Group             

Satkam Ghodke        
Samyak Sankalp Sangh

Milind Jadhav        
Bahujan Maitri Sangh

Pradip Satisevak                
School of Scholars                

Ms Jamuna Dagaonkar
Vandana Sangh

Ms Dipti Meshram
Sujata Sangh

Nandu Nagrale                    
Samyak Sankalp Sangh                

Vistari Waghmare    
Bahujan Maitri Sangh

Nilakanth Raut    
Dhamma Sangoshthi

Tejaram Bhagwatkar                    
Noble Though Group            

Yashwant Dupte          
Prajasattak Shikshak Sangh