All India Peoples’ Science Network (AIPSN) Draft National Education Policy (NEP) 2019

Flawed process

The Draft National Education Policy (NEP) 2019 is an outcome of a flawed process. It is out as a 484 pages document with main part being 398 pages covering 23 Sections and 38 pages with 14 Appendices. It obfuscates and misleads the publics of the real aims of policymakers. The document was drafted by a nine-member committee under the Chairmanship of Dr. Kasturirangan which was constituted on 24th June 2017 (cf. Appendix IX) wherein there is no reference to the earlier TSR Subramanian Committee whose recommendations were discussed as the draft National Education Policy 2016 in Parliament on 10th Aug 2016. The draft NEP, 2019 does not engage with the feedback given on the earlier TSR Subramaniam Committee report. In the corridors of power, there is the talk of a policy document of 30-40 pages under preparation. If the earlier feedback could have been discussed, then we would have felt assured about the sincerity of the government about seeking feedback on the proposals of this committee.

Doubts arise in our mind because in the description of the consultation process (cf. Appendix V) the draft NEP 2019 states “The grassroots consultations, covering 2.5 lakh Gram Panchayats, 6600 Blocks, 6000 Urban Local Bodies (ULBs), 676 districts and 36 States/Union Territories were carried out between the period from May to October 2015. Finally, 110623 villages, 3250 blocks, 962 ULBs, 406 districts, and 21 States uploaded the result of the consultations on survey.mygov.in. The number of suggestions, inputs and comments received included around 35,000 online suggestions from a cross-section of the population, 31 Government of India Ministries, 29 States and Union Territories, 76 Members of Parliament, 305 from Very Important Persons (VIPs), 324 Organizations / Institutions, 485 letters from individuals, 7613 electronic communications, and inputs from the Prime Minister’s Office and the President’s Secretariat.” to give the impression of a broad democratic exercise that went into formulation of this Draft NEP 2019.

The National Policy on Education 1986 was distilled through five years of several draft panels and national consultations naturally carries expectations. However, the Draft New Education Policy NEP, 2019 seems to only air some loud and naive thinking, some well-intentioned but unsubstantiated ideas and some smartly crafted statements on contentious intended action. Most members are not related to school education. No one is related to early childhood education. Such committees should also have field officers, elementary, secondary and university teachers. Further the draft policy on school education is not rooted in history of education in India. It does not take cognizance of the constitutional mandate of RTE 2010, its implementation to some extent in all states, NCF 2005, the NCERT textbooks based on NCF 2005, state textbooks thereafter. This draft National Education Policy is coming out after more than three decades. It suggests new things without having connection with where the country is today. It suggests many things which are already part of the education system (e.g. clusters working as a group of schools, continuous assessment, etc.).

Omissions and commissions

Lack of transparency and intentions being different from what is even explicitly stated the draft NEP 2019 suggests that there is an implicit agenda of the government which is on the back of the minds of the committee members but they are not willing to bring this agenda out of the cabinet as yet. We state this concern because how can what got done by an earlier exercise whose efforts were discussed in Parliament in 2016 as a draft NEP without discussing the feedback already received is now also part of this draft NEP 2019. The committee report is camouflaging the real intentions that will come out in the near future only.

The omission of progressive groups and state representatives and inclusion of Hindutva groups in consultations is evident. After this committee was formed, they have presumably interacted with 74 organizations and 217 eminent persons (cf. Appendix VII). But there is no rationale given behind this selection except the obvious unstated omission of progressive groups and teacher associations across the country. Glaringly absent are also the State level representations although in 28 Aug 2018 the Kasturirangan Committee was given an extension of 2 months for the purpose of discussions with State Education Ministers (cf. Appendix XIII).

For example, under organizations (cf. Appendix VII) are listed Akhil Bharatiya Vidyarthi Parishad, Bharatiya Shiksha Shodh Sansthan, Lucknow. Wikipedia mentions “Akhil Bharatiya Vidyarthi Parishad (ABVP) is a right-wing all India student organisation affiliated to the Hindu nationalist Rashtriya Swayamsevak Sangh (RSS)” and the website of Bharatiya Shiksh Shodh Sansthan gives their first aim as “To Publish useful literature based on Indian culture, ideals, values and spiritual beliefs keeping in view the present structure of education” with the member of the Kasturirangan drafting committee Shri Krishna Mohan Tripathi having become Chairperson of the Bharatiya Shiksh Shodh just a month before the formation of the drafting committee!

To give a trivial example starting with the sixth extension given to the Committee on 31st Oct 2018, the MHRD letter says “the Committee has informed the draft Policy/Report is ready. However due to the code of conduct of the Election Commission being in force it has been decided to extend the term of the Committee to draft National Education Policy up to 15.12.2018”. What logic is there for the Committee not to submit its report when the code of conduct of the Election Commission is in force? And how will the code of conduct disappear in one and half months on 15.12.2018? Interestingly the draft NEP 2019 has the signed covering letter submitted by the committee members to the then Union HRD Minister Mr. Prakash Javadekar on 15.12.2018. The draft NEP 2019 has an undated covering message from the Union HRD Minister Mr. Prakash Javadekar. But newspapers reported on June 1st that the draft NEP 2019 was handed over on Friday May 31st 2019 by the Kasturirangan Committee to the HRD Minister Ramesh Pokhriyal Nishank.

But importantly apart from the file name having the tag “draft NEP 2019 (Revised)” there is no mention anywhere inside of what the revision was and why either as an addendum message from the current Union MHRD Minister Ramesh Pokhriyal Nishank or from the committee members. Anyone having missed all the news and reading the “Revised” draft will have no clue about the changes. The basic ethics of any document publishing is that the changes or revisions are documented in subsequent versions has not been followed. More importantly, there is no mention in the draft NEP 2019 about the data on the state of the education system and how this draft differs from the previous NEPs.

Representational imbalance

In Appendix II the Peer Reviewers for the draft NEP lists 7 members none of whom are women or from URGs. The role of students and their democratic functioning in educational campuses especially higher education institutions is absent. The NEP 1986 had a separate section on the contribution of students including the need for democratic spaces of discussion. Constitutional amendment of 1976 which includes Education in the concurrent list is not even mentioned. Whereas National Policy on Education 1986 specifically talks about the importance of sharing responsibility between Union Government and State. Reservation, education of minorities, SC, STs conspicuous by the absence. Consequences of the representation imbalance and lack of attention to constitutional guarantees comes out clearly if we analyze what has happened immediately to the committee report after its announcement as a public document.

It was following the protests over the imposition of Hindi, a revised draft was put up by MHRD on its website on Monday June 3rd 2019 wherein para 4.9.5 was changed from “In keeping with the principle of flexibility, students who wish to change one of the three languages they are studying may do so in Grade 6, so long as the study of three languages by students in the Hindi-speaking states would continue to include Hindi and English and one of the modern Indian languages from other parts of India, while the study of languages by students in the non-Hindi-speaking states would include the regional language, Hindi and English” to “In keeping with the principle of flexibility, students who wish to change one or more of the three languages they are studying may do so in Grade 6 or Grade 7, so long as they are able to still demonstrate proficiency in three languages (one language at the literature level) in their modular Board Examinations some time during secondary school”.

School Education

Approach to the critique

The explicitly stated recommendations are not the real agenda. The real agenda is different and the document needs to be read not only between the lines nut also in the political context and the political dispensation proposing to use this document for evolving the policy which is yet to come out on paper. While some of the new suggestions of this draft can be read as attractive propositions, but they are suggested without considering today’s reality on the ground. We read them as impractical and even dangerous for the future of Indian education.

Education does not happen in isolation. It happens in the schools, which are within societies, run by the members of society. So, if we want equal, just culture in the school, the government has to ensure that the same will be there in the society. While the document is talking about big dreams, but the politics of BJP government is taking things in the opposite direction. When the draft NPE 2019 talks about dignity of all persons in the schools, we do not feel assured about the sincerity regarding the efforts that the government will show to realize the proposed outcomes.

Take the example of sharing of resources between school complexes. It is not practical at many places because of geographical barriers. Schools’ teachers’ and officers’ motivation level and their today’s capacities, corruption, identity-based discrimination, voice and representation of disadvantaged sections in the administration and faculty, etc. Take the simple point of how teachers should not be overburdened, especially with non-teaching activities, or with the teaching of subjects outside their expertise. The RTE Act has specifically mentioned which national duties teachers will be asked to do. But if teachers are seen as the only educated resource in the field by all departments, if they are answerable to multiple departments, this is not going to happen. There are no structural changes explicitly suggested in the draft NEP 2019 which can change this situation in respect of school teachers.

Attacks on/ dilution of constitutional mandate

The NPE 1986 clearly speaks of education as furthering the goals of socialism, secularism and democracy enshrined in our Constitution. It warns that India’s political and social life is passing through a phase, which poses the danger of erosion to long-accepted values. The goals of secularism, socialism, democracy and professional ethics are coming under increasing strain. It further says, all educational programmes will be carried on in strict conformity with secular values. While listing the Constitutional values, the draft NEP 2019 drops the words socialism and secularism, includes equality, justice, plurality, scientific temper, and incorporates among other things the value of a ‘true rootedness and pride in India’. The last phrase looks new, while secular values are conspicuously absent (p. 96).

Given that the draft NEP 2019 does not talk about secularism at all how will children learn that ‘all human beings are equal’. There cannot be discrimination on the basis of caste, creed and language. The draft NEP 2019 does not mention the important constitutional values of equality, secularism, democracy as the foundations of this policy. It talks about sensitizing students towards human values such as respect for all persons, empathy, tolerance, inclusion and equity. The draft NEP 2019 has a section on the development of constitutional values. The preamble of constitution and citizen’s duties as per directive principles should have been included as such in this section.

Equality is used as a value, but no emphasis on ‘children having equal rights. The actions suggested are against this right (e.g. NIOS for migrant and CWSN children). Equal rights are replaced by inclusion. Instead of equality and equity, the document talks about inclusion and equity. In a very flowery title of ‘multiple pathways to learning’ NIOS the suggestion is to give programmes equivalent to grade 3,5 and 8, for ‘children who are not able to attend a physical school.’. This is violation of children’s constitutional right of education and also of their right to equal opportunity. The draft NEP mentions access, equity, quality, affordability and accountability without linking them to the foundational pillars of Indian constitutional values, commitments and mandate.

The Draft NEP, 2019 undermines constitutional rights of the states of the Union. It centralizes school education as a subject of concurrent list. In fact, the proposal of Rashtriya Shiksha Aayog headed by prime minister is a clear example of extreme centralization and a violation of the Indian constitution. The rights-based approach of the RTE is replaced by mission mode. The school education as a right is made dependent on peoples’ voluntarism. The recommendation of National Tutor’s programme (NTP) – is based on the idea that peer tutoring in Gurukuls was successful. Peer tutoring in gurukuls was mugging up. There was no learning.

Remedial Instructional Aides Programme (RIAP) – The failure of curriculum and system is put to local community volunteers. Local community members holding remedial classes means tuition classes. The RTE speaks about right to quality education till completion of quality elementary education. The draft NPE at most places talks about ‘Access to quality education, or opportunity to participate in quality education.’ The substantive approach taken by NCF 2005 of equality of outcomes is missing from this document.

Dilution of RTE

The Right to Education (RTE) Act has a definition of ‘school’ and gave minimum norms on infrastructure. The draft NPE 2019 dilutes this (See Page 187). The draft NPE 2019 speaks only of multiple pathways to learning involving formal and non-formal education modes, (CWSN and children of migrant workers are mentioned here – page 71 -this suggestion should be outrightly rejected) NIOS to offer education at A, B and C level (grade 3, 5 and 8) for children who cannot reach physical school. The RTE – Section 8 – Responsibility of the government to ensure good quality education for every child till completion of elementary education.

The RTE explicitly mentions that it is responsibility of the govt to ensure that every child gets education of good quality. The draft NPE Page 366 suggests– Responsibility of the school to ensure that all students continue to remain in school till completion of grade 12. Central and state government have concurrent responsibility of funds. The draft NPE 2019 does not explicitly give the responsibility to the government this, neither does it reject this. The draft NPE 2019 explicitly encourages private philanthropic school sector and “public-spirited private schools”-a new imagined category to support the schools run by RSS.

The RTE explicitly speaks of ‘every child learning to the fullest of her potential and completion of elementary education’ as child’s constitutional right and government’s responsibility. The draft NPE 2019 directly and indirectly suggests the path of skill education for underachievers, and for performers speaks of the path of competitive exams and merit-based scholarships / incentives. This is discriminatory. It is against the constitutional right.

The RTE speaks of education as a constitutional mandate for the government. The draft NPE 2019 sees education as a national agenda. The RTE defines ‘child belonging to disadvantaged group, child belonging to weaker section’. The draft NPE 2019 speaks of ‘Underrepresented groups’-a category which is not clearly defined. The RTE provides for 25 % admission to disadvantaged and weaker sections compulsory for private schools. The draft NPE 2019 suggests to make this optional and suggests to motivate the managements to do it voluntarily.

Early Childhood Education –

The RTE Act did not provide for early childhood care and education (ECCE). The Draft NEP 2019 includes ECCE. The Title of the section dealing with early childhood education is ECCE. It is not early childhood education (ECE). The ECE is as important as the care (nutrition, immunization etc.). The early childhood care is looked after by the Ministry of Women and Child Welfare (MWCW). The draft NPE 2019 is talking about the system of ECE institutions (page 48). There are no such ECE institutions. There are very few training institutions for preparing the teachers for the ECE. The ECE has two important periods of child development to take care of. The 0-3 component of ECE can be assigned to anaganwadis as neighborhood institutions. The anganwadi workers would have to be upgraded and absorbed as regular cadre. The draft NPE 2019 has failed to state this policy measure and take the demand of the democratic movement on the anganwadis workers on board.

Education is not just literacy and numeracy but much deeper–thinking and self-expression, awareness, etc. The ECE is considered to be a precursor to something–like primary education, jobs, etc. The 3-6 component of ECE needs to be the responsibility of again the neighborhood institutions. The democratic movement has been demanding publicly funded institutions to look after this phase of child development. The draft NPE 2019 ignores this and proposes vaguely linking to primary school professional help and activity-based curriculum. However, this component of the ECE is important in itself. That needs to be taken seriously. Otherwise the first standard curriculum will be pulled down. It seems that the draft NPE 2019 is planning to give one extra anganwadi worker to anganwadis for ece (p.50).

Elementary education

The draft’s eponymous chapter on ‘foundational literacy and numeracy’ describes a severe “learning crisis” and warns that the country could lose “10 crore or more students — the size of a large country — from the learning system”. It then goes on to resolve that this cannot be allowed to happen. “The cost is far too great— to crores of individuals and to the nation. Attaining foundational literacy and numeracy for all children must become an immediate national mission,” it notes. It then goes on to state, almost tautologically, that the reason behind this is a “lack of school preparedness”, a problem which the draft says acutely ‘afflicts’ children from disadvantaged socio-economic backgrounds without access to pre-primary education. Foundational skills do not include thinking. Students of grade 5 are expected only foundational literacy and numeracy. The RTE Act assures completion of quality education up to class 8. The Draft NPE 2019 talks about ‘access to quality education’ at most places. The RTE and NCF 2005 mention higher order learning objectives. The draft NEP 2019 speaks of foundational literacy and numeracy.

Learning objectives downgraded

The draft NEP 2019 asserts that early grade schooling does not lay emphasis on reading, writing and speaking or on mathematical ideas and thinking, but moves quickly on to rote learning. In actual fact, ‘rote’ learning frames all of schooling, its expectations, syllabi, texts, teaching and assessment at all levels, as has been recognized and discussed by all the earlier policies. So how does this policy acknowledge, understand or face that systemic challenge? It does not, but continues with “If and when rote learning is used, it will always be pre-accompanied by context and motivation and post accompanied by analysis and discussion” (p. 76).

Moreover, it adds, “If students are given a solid foundation in reading, writing, speaking, counting, arithmetic, mathematical and logical thinking, problem-solving…then all other future lifelong learning will become…more enjoyable.” Enumerating counting, arithmetic and mathematical thinking as different elements of foundational numeracy indicates a lay understanding of ‘learning’ that runs through the document, often hiding behind the repeated use of terms such as ‘flexible’ and ‘fun’. In Curriculum and Pedagogy (chapter four), we get a dream menu of permutations and combinations of this ‘fun’. From ‘interactive fun classrooms’ (p. 76), to language teaching in a ‘fun and interactive style’ (p. 85) as done by Samskrita Bharati and Alliance Française, for Sanskrit and French (but probably not for those in their early years).

Hiding behind terms like ‘fun’

Elementary education needs to be defined in a rigorous way. The whole framework is task or activity based (See p.48). The image of a child as a capable learner needs to be articulated as the curriculum will emerge from it. Contrary to theories of learning, it recommends harnessing the “extremely flexible capacity” (p. 79) of young students, from pre-school onwards, who would be “exposed to three or more languages with the aim of developing speaking proficiency and interaction, and the ability to recognize scripts and read basic texts, in all three languages by Grade 3” (p. 81). It also states that during grades six to eight every student will take a ‘fun course’ (p. 86) on the languages of India. Multilingualism and an understanding of diversity are important aims but not done in such an ad-hoc manner. It adds that puzzles or competitions to write on a topic without a given sound/alphabet can offer a “fun way to understand and play with language” (p. 93). Incidentally, such ideas have been used in NCERT language or mathematics textbooks, but not as arbitrarily and definitely not for ‘fun’, as they seem to be listed in the policy.

Work and Education

A crucial theme on integrating work and education, not for a vocation but as a medium of learning from life and for life, which has been implemented by the Zakir Hussain Committee (1938), has not been seriously discussed at all. The draft claims that “exposure to practical vocational-style training is always fun for young students” (p. 94) and recommends, without any modalities, that every student will take a fun year-long course on a survey of vocational skills and crafts, sometime between grades six and eight, with some hands-on experience of carpentry, electric work, gardening, pottery, and so on. It states that the National Curriculum Framework of 2005 has given excellent strategies for “accomplishing a more constructivist type of learning” (p. 101).

Determining core and its implications

The draft NEP 2019 gives no understanding of how the “shrinking of the curriculum content to its core” (p. 102) will be achieved or what the ‘core’ implies. It states that the National Curriculum Framework of 2005 has given excellent strategies for “accomplishing a more constructivist type of learning” (p. 101). Indeed, this is still relevant, but the draft gives no understanding of how the “shrinking of the curriculum content to its core” (p. 102) will be achieved or what the ‘core’ implies.

Approach to quality

The most brazen attack is on the Right to Education Act, which while being proposed to be extended has been hugely curtailed with. Its most basic requirements like the quality of provision, qualification of teachers, and so on will be removed, “to allow alternative models of education such as gurukulas, paathshaalas, madrasas, and home schooling” to flourish. A ‘flexible’ market model with minimal regulations, to give “greater flexibility (and) create greater educational choices for students and healthy competition among schools” (p. 71), is sought to transform the nature of school education.

The euphemism of multiple ‘alternate models’, helps to also include the huge industry of low-cost private schools, ‘philanthropic-public partnership’ schools, religious schools, and the largest network of Rashtriya Swayamsevak Sangh schools, including its single-teacher Ekal Vidyalayas in predominantly tribal regions, for which “multiple pathways to learning” (p. 69) through non-formal methods, technologies and National Institute of Open Schooling courses (equivalent to grades three, five and eight) are being justified.

Poor students and quality education

The proposed models are violative of the fundamental right of children to good quality education in regular schools; removing Right to Education regulations amounts to depriving the poor and disadvantaged of their most basic entitlements. It needs to be kept in mind that after all the BJP government is pushing citizenship bill which explicitly discriminates against Muslims. It is already under implementation in the North East and the executive orders have been given to the states by the Home Ministry to create panels for the same outside the North-East. The BJP government needs a network of supporting institutions promoted by the non-state actors like the RSS.

Moreover, the draft policy makes mockery of the rights of under-represented groups through its National Programme of Tutors (NTP) “where the best performers in each school will be drawn in for up to five hours a week as tutors during the school for fellow (generally younger) students who need help” (p. 60). Contrary to known theories of learning and experience in India, it still advocates for ‘each-one-teach-one’, for schools and also for adult education.

Another brazen agenda to short shrift the poor, who need nurturing attention from qualified teachers, is the Remedial Instructional Aides Programme (RIAP). The term ‘remedial’ is demeaning and demotivating, indicating a deficit or illness in need of a remedy, and the Ministry of Human Resource Development had stopped using it soon after enacting the Right to Education. Initially, RIAP has been presented as a 10-year project to employ instructional aides — especially women from socio-economically disadvantaged communities (who have completed the highest grade in school available in their region) — to hold such classes during and after school, and during the summer.

Foundational learning offers a new garb to segregate the disenfranchised into ghettos of low cost, minimalist skill programmes. The draft says ‘true local heroes’ will be trained to teach foundational literacy and numeracy, to bring back students who might drop out, not attend, or never catch up. Glorifying de-professionalization in education is being used by different governments for their own agendas. Foundational learning offers a new garb to segregate the disenfranchised into ghettos of low cost, minimalist skill programmes, while allowing unqualified unregulated ‘heroes’ to be ’employed’ and to influence the agenda of schools.

Ironically, qualified teachers, who are not available for these children, are expected to consistently monitor their learning, and also this army of volunteers, peer tutors, and instructional aides will motivate others. The draft’s highly centralising agenda also comes to the fore. The government-controlled Rashtriya Shiksha Ayog and the well-funded National Research Foundation, with links with the industry cannot ensure research on most urgent national issues of school education.

Education, economy and corporatization

The draft NPE 2019 sees Education in the language of return on investment (ROI), capital rather than through the lens of public purpose-at national, regional and local levels. The NPE 1986 says – Education develops manpower for different levels of the economy. It is also the substrate on which research and development flourish, being the ultimate guarantee of national self-reliance. In sum, Education is a unique investment in the present and the future. This cardinal principle is the key to the National Policy on Education. The word self-reliance is missing from draft NPE 2019. This Policy considers all ﬁnancial support and spend on education as investment’, and not as ‘expenditure’. Clearly, monies spent on education are all investment into the future of our nation. However, when the draft NPE 2019 talks about ECCE it says – Investment in ECCE is among the very best investments that India could make, with an expected return of Rs. 10 or more for every Rs. 1 invested.

The draft NEP 2019 says – India ‘aspires’ to become the third largest economy by 2030-32. Our ten trillion economy will not be driven by natural resources, but by knowledge resources. So, the priority has shifted from welfare of all to the economy. Corporate model of education management. E.g. Performance appraisal process for teachers. The draft NPE 2019 forgets that education is about public purpose and human well-being.

Extreme privatization

Although there is discussion on ‘public education’ and increase in public funding, but the draft NPE 2019 favours extreme privatization in its policy practice. Private schools will be equally treated and encouraged. It talks of autonomy to drop compulsion of 25%. It allows the private institutions to increase fees. It speaks of reasonable fees. It speaks of Philanthropic / public spirited private schools etc. It does not talk about public purpose. It speaks of giving return on investment to the consumer rather than creating a citizen and equality and secularism valuing human beings.

School complexes are a way to closure of small government schools. Several states are moving towards closing schools having less than 20 students. For example, in Maharashtra 1314 schools having less than 10 children were decided to be closed. Most of these schools have parents who have no voice in this system. Most of these have 100% SC/ST students. In Akole block of Ahmadnagar district 14 schools were in this list. Out of that 9 were having 100% ST children. About 300 such schools have been closed before there was any noise from teachers, parents and communities. School complexes are going to be treated as investment in infrastructure and real estate.

In the NEP 2019, there is on the one hand the policy recommendation of increase in expenditure on education, and on the other hand it talks about

‘finding’ funds quickly

philanthropic funds for infrastructure, learning materials, workbooks etc.

It talks about merging of schools having less than 20 students by calling them ‘non-viable’.

Creating parallel structures instead of strengthening the existing ones. E.g. high-quality stand-alone preschools will be built in areas where existing anganwadis and primary schools are not able to take on the educational requirements of children in the age 3 to 6 (page 50). National tutors’ programme (NTP) + Remedial instructional aides programme (RIAP) instead of special training as per RTE are also examples of continuing with and expanding the policy of extreme privatization

The most basic requirements of the Right to Education like the quality of provision, qualification of teachers, and so on will be removed. Attempts to control and dictate research topics through the government’s wish list have been made earlier but with an influx of funds, this can have crippling consequences. Similarly, high dependence on technology through the National Educational Technology Forum, for all kinds of ‘adaptive’ assessments which obscure the agency and autonomy of teachers, and the National Repository of Educational Data which will house digital records of all institutions, teachers and students is a contentious proposition triggering due concerns on data privacy.

A highly contentious recommendation in chapter three proposes school ‘rationalisation or consolidation’ through the setup of ‘school complexes’. This would be done through mergers and by closing down ‘unsustainable’ small schools, something which has long since been targeted by corporate NGOs and funding agencies. Many states under pressure from Niti Ayog have already closed thousands of schools; this policy’s claims of ensuring access through buses, paid walking escorts or rickshaws to parents, are not practical or realistic.

Distortions in theoretical and political approach

Ethical/moral reasoning instead of evidence based rational reasoning
CCE in various forms to computer based adaptive assessments
Opportunity to participate instead of capacity building
Learners instead of ‘every child’
Obligatory for ‘public system’, instead of obligatory for the ‘government’
Communication instead of expression

It uses the word ‘unfortunately’ for talking about biases. They talk about prejudice and bias based on gender, economic status, but do not mention caste and religion.
It talks about sensitizing learners for inclusive education. But doesn’t talk about sensitization of the system from government to teachers.
It talks about change in school culture, to sensitize everyone for respect and dignity of all persons. In a country of killings of rational people and mob lynching how is this going to work only inside schools?
Right diagnosis and right principles on many issues, but wrong solutions. E.g. many children of class 5 cannot read, write and do arithmetic. The proposed wrong solution is over-emphasis on foundational literacy and numeracy.
Objectives of NCF 2005 are lost in the programme like foundational literacy and numeracy. (page 55)
In Remedial instructional aides programme they have suggested to group children by level and pace. (so, merit for the toppers and skills for the weakers???? As hidden agenda??)
Statements like ‘a large proportion of students who fall behind during their elementary school years in fact fall behind during the first few weeks of grade 1’ are against pedagogical principles and spirit of NCF 2005. They are proved wrong in practice in examples like Kumathe Beet and many others.
The schools need autonomy and strength. – Right diagnosis. Schools complex will give it may not be the right solution.
The processes which are already supposed to be there (e.g. making of school development plan to SDP) are suggested as new solutions, without addressing the issues of why they are not properly functional.
Subject selection at class 9? Also allowed to drop some key subjects at class 9? Dilution of rigorous subjects.
DSE must facilitate accreditation but DSE officials will not be involved – How would they own the observations?
Accreditation of schools, promotions of teachers etc dependent on SMC, peer schools/ teachers and SCMC. What about the corruption and politics there?
School complex –
- It may not be possible to share resources because of physical distance and geography.
- Closure of smaller schools seems to be on agenda
- Team at school complex may have too many bosses.
- Entry to corporates may be easy in school complexes
- Hostel/transportation cannot be relied upon in today’s circumstances.
A major effort of data collection is suggested. Are they taking into consideration their own tampering of data in NSSO? अशा गोष्टींमुळे त्यांचे सगळेच शब्द पोकळ वाटत आहेत.
Wrong data page 82? – 54% Indians speak Hindi?
Pedagogically correct point picked up for pushing hidden agenda e.g. 3 language point page 80
Trying to ‘establish unity’ instead of/before celebrating ‘diversity’
Sometimes tradition and scientific temper may clash, or ethical reasoning may clash with evidence-based reasoning. What is the reference point to resolve these issues?
Ethics being taught as a subject?
Only essential core content in NCERT textbooks? (page 102).
Private people encouraged to write textbooks (page 103)
Assessment has to be closely linked to learning. NPE proposes to disconnect it. Creating parallel structures – National testing agency (NTA).
Singular interest groups to be run on funding, rigorous merit has funding, remedial etc to be based on voluntary.
High respect for teachers is to be restored. Want best future for students and nation. This can be done only by giving ‘best possible present’ to our teachers. No such plan seen. Performance, merit, performance-based confirmation and salary (only for teachers?), incentives etc is suggested as solutions. Corporate ways. नवनवी कुरणे तयार करण्याच्या जागा.
Local language speaking teachers in rural areas. …???

Motivation smacks of half-truths/ lies used to push RSS agenda

The draft accepts that the entire system needs motivation. But instead of having constitutional dream of “Every Indian citizen being able to live with dignity, in equal and just society and having decent living” it has a dream of “bringing back the ancient Indian education system”. It is silent on girls and children of some casts not having access to education in ancient India.

Ancient tradition is mentioned by over emphasis, but doesn’t talk about exclusion of other casts and women from that system. e.g. page 27
The Right of Children to Free and Compulsory Education Act, 2009 (RTE Act) which came into force in April 2010, entitles every child of the age of six to fourteen years to the right to free and compulsory education in a neighbourhood school till the completion of elementary education. However, despite progress in some aspects, a mind-numbing uniformity prevails in the education system today, one in which students are not nurtured for their individual potential, in complete antithesis to our ancient traditions.

Extreme centralization as approach to harmonization

The main reason is lack of quality in spite of multiple efforts was lack of harmonization between dept of education, various bodies under it and SSA. Therefore, SCERT was declared as an academic authority. Other bodies were either merged with SCERT or were supposed to work in close coordination with it. There is evidence that when all bodies work in harmonization quality of education can be improved. The draft NEP 2019 has proposed exactly the opposite. It proposes that Rashtriya Shiksha Aayog (RSA) will take care of policy, Department of school education (DSE) will take care of operations and State School regulatory authority (SSRA) will take care of regulation and SCERT will take care of academic matters. This will create new issues of harmonization and coordination.

Higher education and research

The approach, objectives and policy measures of the draft NEP 2019 are stated as:

Revamping the existing higher education system by doing away with the affiliating university and university having affiliated colleges; will give a policy framework and programme for the creation of Three-Tier HEI System-research universities, teaching universities and autonomous degree granting colleges;

Establishing a three-tier system of HEIs- Type I (research universities), Type II (teaching universities) & Type III, autonomous degree granting colleges; creating world class multidisciplinary HEIs across the country by consolidating and restructuring existing private and public HEIs, building new world class HEIs,

Equal treatment to private and public HEIs in respect of access to public funding; equal encouragement to private HEIs to develop into Type I, II and III type HEIs; getting the states to develop plans for the Special Education Zones; developing a fair and transparent system for determining public funding;

Moving gradually towards full autonomy-academic, administrative and financial; granting faculty and institutional autonomy in respect of revamping of curriculum, pedagogy assessment, and student support, creating incentives to encourage colleges to attain excellence across fields;

Reaffirming merit-based appointments and career management, establishing a national research foundation, governance of HEIs by independent boards with complete academic and institutional autonomy, light but tight regulation

Support for National Post-Doctoral Fellowships to encourage research within state universities; readjusting the system to get specialised HEIs to become multi-disciplinary HEIs; moving towards a more liberal undergraduate education with the aim to strengthen holistic education,

Increasing GER to at least 50% by 2035, expanding access through open and distance learning; launching Mission Nalanda (MN) for 100 Type I and 500 Type II and Mission Takshashila (MT) for establishing at least one high quality HEI in or close to every district of India, with 2 or 3 such HEIs in districts with large population, each with residential facilities for students;

Critique of the objectives, rationale and approach

While the claim is made that the policy measures will enable the government, but the draft NEP 2019 can be expected to strengthen the pathways of extreme privatization and extreme centralization. First of all, we state here below the rationale provided:

to revamp the higher education system for sustainable livelihoods, economic development of the nation;

to help achieve human wellbeing and develop democratic, just and socially consciousness, self-aware, cultured and humane nation with spirit of liberty, equality, fraternity and justice for all;

to create a hub for developing ideas and innovations that will help propel the country forward and not tailor people for jobs that exist today and focus on jobs of the future and competencies for future work roles, creates multidisciplinary HEIs;

to help overcome fragmentation, break silos, eliminate early specialization and streaming of students into silos of disciplines, grant autonomy by providing freedom to innovate, to compete, to cooperate, to govern more locally, to optimise resources, to break silos and to excel;

to increase GER in HEIs from 25 to 50 % to tackle the challenge of lack of access, especially in socio-economically disadvantaged areas and backgrounds;

to create a fair and transparent system of selection, tenure, promotion, salary increases and other recognition and vertical mobility of faculty;

to engage successfully with the challenge of lack of research at state universities by providing for mechanism to seed and mentor research through the national research foundation (NRF);

to empower HEIs to manage their own teams and empowering teams using differential compensation,

to overhaul the regulatory system, eliminate fake institutions and to achieve excellence and innovation by doing away with regulations that constrain the achievers

There is nowhere even a mention of how the proposed system of higher education is going to reduce the wastage and overcome the crisis of public purpose, funding, quality and mis-governance. While the NEP 2019 makes a number of new and old proposals to trigger a process of transformation, but it will be clear from the critique here that its proposals are not only unrealistic in scope but also capable of damaging the system as such in many ways.

Multidisciplinary HEI is not a radically new idea or even a new innovation for the country; liberal arts and humanities also exist; revalorising ‘liberal’ means cultivating a socially transformative mindset promoting dignity to labour, willingness to transform structures that are political, economic, social and cultural; it is an enigma that even when the draft recognizes that the existing multi-disciplinary HEIs have been practicing mostly discipline based teaching and research it fails to ask why most have not been able to practice challenge-based collaboration in teaching and research,

The draft NEP 2019 avoids tackling the question of how the policy approach is going to overcome the challenge of growing wastage due to the problems in the integration of system of supply and demand of human resources within the Indian economy, society and state; when employers are being allowed cheap labour and cheaper regulation, socially conservative administration is seeking conformity from the faculty and students, political establishment is perpetuating social divides in order to build majoritarianism and homogenised “cultural identity” and the ruling party is mobilizing on the ground mobs to allow primitive accumulation to the ruling class;

The draft NEP 2019 has made a set of big claims’, but the misplaced non-systemic supply-based diagnosis prevents the committee from making a break with the past approach followed by even the UPA II government in abundance. The draft NEP 2019 is not willing to reverse extreme privatization, transform simultaneously the national system of education, research, production and innovation’ in private sector, public sector and revamp the institutions of welfare delivery and economic, social and environmental justice;

The Indian system of higher education institutions (HEIs) is faced with the crisis of public purpose, funding, quality and mis-governance. These weaknesses are an outcome of extreme privatization- domination of predatory private sector poaching on public universities and HEIs for teachers, duplicative imitation, commercialization, costly, burdensome for parents, employers complaining rather than helping to improve poorly developed teaching-learning environments, upgrading of infrastructure. The draft NEP 2019 is not taking the system out of the beaten path of extreme privatization and centralization. HEIs will continue to be encouraged to practice the path of commercialization of public and private higher education, the promise of loans and scholarships will not change the situation radically, identified challenges require systemic solutions.

The draft NEP 2019 has failed to move towards a path of trans-disciplinary integration of teaching, research and outreach; it is unable to compel the government and private employers to provide commitment to provide for public purpose based competence building, work and job experience through a mechanism of apprenticeship which is compulsory and not reduced to training but productive for the system of knowledge production, capability building and enhancement of state capacity to deliver novel solutions.

The draft NEP 2019 is putting the system on the road to further privatization, corporatization and centralization when manufactured consent is the political necessity and HEIs are promoting social conservatism, killing diversity and democratic governance and moving away from critical thinking, cultivating cultures of discrimination and institutionalized discrimination of students and teachers from disadvantaged sections, transformation not possible. The draft NEP 2019 has no place for democratic student and faculty representation in the bodies charged with the responsibility of governing HEIs.

In the draft NEP 2019, this omission or commission is unpardonable when HEIs are today compelled by the political establishment to resist the practice of secularism and progressive values, encourage social conservatism and valorise conformity to the emerging political, social and economic order, to tackle the challenge of building of the transformative spaces even the draft recommendations do not even think of promoting statutorily the participation of students and faculty in governance.

The draft NEP 2019 is seeking voluntary service (seva) or voluntary commitment of employers will be tokenism and will perhaps help the ruling party to legitimize and strengthen itself but this cannot provide the ecosystem for a system of transformative higher education. However, one thing is quite clear that the NEP 2019 is still treating higher education as a commodity. The students and parents are required to buy this commodity and make an investment on which the return is uncertain.

The draft NEP 2019 is treating higher education as not only a commodity but also a differentiated product to be sold as a scare wherein scarcity is being created for no reason or rhyme. The Indian elite system of Tier I HEIs will be allowed to convert their degrees as a merit elitist good. The public funding will continue to flow with some private institutes of dubious record (Jio Institute of Eminence) being also declared as world class without any basis. The Draft NEP 2019 is continuing on the path of aggravating segmentation even further.

The Draft NEP 2019 has not even considered the possibility of co-creation for public purposes that it has mentioned as the problems of development that the professions need to address in a transdisciplinary way by co-producing knowledge and co-designing solutions. Systemic integration and public engagement challenges of the HEIs with the real world are consciously left out from both diagnosis and solutions, there is no doubt that what will actually get implemented is going to be the implicit agenda of the ruling party; complete lack of appropriate strategies chosen for integration HEIs do not have requisite access to eco-system for linking them with the country’s national system (s) of production and innovation;

The draft NEP 2019 has chosen to opt for the pathways of extreme privatization and extreme centralization. It is promoting direct control through the PM and PMO’ office. The talk of independent boards for governance, autonomy, accountability, fairness and transparency seem more of hollow claims of the members of the committee who are blind to the as existing reality; the draft NEP 2019 sticks to the path of promotion of new public management-based system of rankings, accreditation despising public purpose and lacking in accountability;

In the draft NEP 2019 evaluation system promoted is proposing to promote quality as merit, ranking on the tested online parameters of excellence in doing well in exams and not even problem solving. The promotion of competencies is for quality as merit or ranking. Certainly not providing for quality as the ability of the institution to contribute to transformation of local, individual, collective, economic, social and cultural contexts. Forget about treating quality as achieving excellence for transformation of the society and economy.

The draft NEP 2019 is going to cast a growing shadow of uncertainty on the future of Indian higher education. The rise in cost of access to higher education for the common people and disadvantaged sections, a heavy hand of the right-wing governments at the Centre and states, administration promoting extreme privatization and authoritarian governance, curtailing academic freedom and administrative autonomy loom large over the horizon of higher education in India

Annex

Role and Aims of Education: A comparison

NPE 1986	Draft NPE 2019
THE ESSENCE AND ROLE OF EDUCATION 2.1 In our national perception, education is essentially for all. This is fundamental to our all-round development, material and spiritual. 2.2 Education has an acculturating role. It refines sensitivities and perceptions that contribute to national cohesion, a scientific temper and independence of mind and spirit – thus furthering the goals of socialism, secularism and democracy enshrined in our Constitution. 2.3 Education develops manpower for different levels of the economy. It is also the substrate on which research and development flourish, being the ultimate guarantee of national self-reliance. 2.4 In sum, Education is a unique investment in the present and the future. This cardinal principle is the key to the National Policy on Education.	From ancient India – The aim of education in ancient India was not just the acquisition of knowledge, as preparation for life in this world or for life beyond schooling, but for complete realisation and liberation of the self. The vision of India’s new education system has accordingly been crafted to ensure that it touches the life of each and every citizen, consistent with their ability to contribute to many growing developmental imperatives of this country on the one hand, and towards creating a just and equitable society on the other. We have proposed the revision and revamping of all aspects of the education structure, its regulation and governance, to create a new system that is aligned with the aspirational goals of 21st century education, while remaining consistent with India’s traditions and value systems. It seeks to ensure that human capital, the most vital form of capital that would fuel the necessary transformation, is secured and strengthened. Highest priority is accorded to the task of ensuring universal access to an education of high quality and breadth that would support India’s continued ascent, progress, and leadership on the global stage – in terms of economic development, social justice and equality, environmental stewardship, scientific advancement and cultural preservation, and help develop and maximise our country’s rich talents and resources for the good of the individual, the country, and the world.
The National System of Education will be based on a national curricular framework, which contains a common core along with other components that are flexible. The common core will include the history of India’s freedom movement, the constitutional obligations and other content essential to nurture national identity. These elements will cut across subject areas and will be designed to promote values such as India’s common cultural heritage, egalitarianism, democracy and secularism, equality of sexes, protection of environment, removal of social barriers, observance of small family norm and inculcation of scientific temper. All educational programmes will be carried on in strict conformity with secular values. India has always worked for peace and understanding between nations, treating the whole world as one family. True to this hoary tradition, education has to strengthen this world-view and motivate the younger generations for international cooperation and peaceful co-existence. This aspect cannot be neglected. To promote equality, it will be necessary to provide for equal opportunity for all, not only in access but also, in the conditions of success. Besides, awareness of the inherent equality of all will be created through the core curriculum. The purpose is to remove prejudices and complexes transmitted through the social environment and the accident of birth. National Policy on Education, 1986	The common core curriculum shall aim to develop broad capacities and important dispositions, including but not limited to: critical thinking (e.g. courses on statistics, data analysis, or quantitative methods); communication skills (e.g. courses on writing and speaking); aesthetic sensibilities (e.g. courses in music, visual art, or theatre); scientific temper and the scientific method; an understanding of India, our context, and our challenges (e.g. courses on India’s history and diversity, or on the social realities of contemporary India); Constitutional values and their practice; social responsibility and moral and ethical reasoning; an adequate exposure to multiple disciplines and fields including the arts, humanities, and sports; and science in relation to society and the environment. (Secularism deleted from list of Constitutional Values)
Commitment RTE – Right to good quality education. Quality defined by NCF 2005 which is notified as per RTE – The formal approach, of equality of treatment, in terms of equal access or equal representation for girls, is inadequate. Today, there is a need to adopt a substantive approach, towards equality of outcome, where diversity, difference and disadvantage are taken into account. A critical function of education for equality is to enable all learners to claim their rights as well as to contribute to society and the polity. We need to recognise that rights and choices in themselves cannot be exercised until central human capabilities are fulfilled. Thus, in order to make it possible for marginalised learners, and especially girls, to claim their rights as well as play an active role in shaping collective life, education must empower them to overcome the disadvantages of unequal socialisation and enable them to develop their capabilities of becoming autonomous and equal citizens.

Members of the Drafting Committee hand over the Draft New Educational Policy 2019 to HRD minister Ramesh Pokhriyal on May 31. Source: Twitter/@HRDMinistry