CPI(M) sent its observations on the Draft National Education Policy (DNEP) 2019, to Ramesh Pokhriyal Nishank, minister for human resource development, on  July 20. In the covering letter to the minister, Sitaram Yechury, CPI(M) general secretary said, “We strongly feel that while our observations have dealt with all aspects of the draft policy, Chapter 23 which deals with centralisation of powers completely contravenes with the powers of the state governments and therefore, the constitutional scheme of federalism, and should be withdrawn forthwith.

“The DNEP in the present form will ensure the centralisation, commercialisation and communalisation of the Indian education system and structures. Instead of arriving at a balance between quantity, quality and equity in the education system, this DNEP is promoting a more elitist and pro-corporate thrust.

“This DNEP in its present form, is hence, not acceptable. Wide consultations are required to arrive at a NEP, suitable for our condition, today,” he said.

Below we publish the first part of the observations.

I.           PREAMBLE

Coming as it does 33 years after the last national policy document on education commissioned by the Government of India, the Draft National Education Policy (DNEP) 2019 was expected to objectively review the achievements and failures of the last National Policy on Education, assess the new challenges that have emerged in the intervening years, and articulate a vision that can robustly connect ground realities and democratic aspirations to constitutional directives in this key area of nation-building. Instead, we have before us a document that frustrates these expectations. For instance, significant initiatives like the National Literacy Mission (approximately 30 crore people are still illiterate!), the Right to Education Act, and the National Curricular Framework (NCF, 2005) have been left unassessed and, as a result, stand diluted.

An obvious shortcoming of the DNEP lies in its failure to identify and address the socio-economic challenges that have daunted India’s educational progress. While the cost of quality education continues to rise, increasing numbers of pupils drop out before completing compulsory education. Scientific temper is on a decline and civic values are facing vicious attacks from an environment that is actively promoting obscurantism, deepening social divisions and encouraging backlash against the already-marginalised sections. Educational institutions are unable to retain academic talent and secure a just and equitable environment for students, teachers and researchers. Student-suicides are on the rise. Religious education in the garb of Shishu Mandirs, Ekalavya Vidyalayas and Madrassas are proliferating even as the Union Government orders the closure or merger of public-funded primary and pre-primary schools. Municipal schools are being leased off to private corporate bodies while the affluent classes are beginning to prefer home-schooling to the institutional nurture of regular schools. Instead of halting this, the DNEP proposes to escalate it further by amending the RTE Act.

While the DNEP pays more importance to Higher Education and Research than has hitherto been given, it builds castles in the air instead of assessing the impact of growing commercialisation and privatisation at this level of education. It sets up an ambitious GER target of 50% by 2035 but hopes that the target will be achieved without binding the Union Government to funding commitments. Its policy recommendations are based on one-sided diagnoses derived entirely from the NITI AAYOG’s Action Agenda. It replicates currently identified evils by advocating increased private investment, uniform regulatory and assessment parameters for public-funded and private Higher Educational Institutions (HEIs), private-funding of institutional infrastructure through corporate philanthropy, CSR and capital markets, greater contingency in teaching appointments and career progression leading to more professional insecurity and iniquity, and the shutting-down of large affiliating-type universities – thus negating the potential to pool resources and improve the standards of affiliated colleges.

The most disconcerting feature of the DNEP is its failure to recognise the clear Constitutional delegation of equal authority to the states and the Centre, on education. Educational policy has been a prerogative of states, keeping in mind the diversity of regional interests and needs. The Constitution was amended to include Education in the Concurrent List, giving the responsibility of coordination and funding allocations between states to the Centre. The DNEP has virtually robbed the states of their pre-eminence and given overarching powers to the Centre. It has done this by creating an excessively centralised structure of authority and vesting overarching powers with the PM-led Rashtriya Shiksha Aayog (RSA). States are expected to function merely as local-level units of the RSA, without having the freedom to establish their own priorities or position themselves critically against the policies of the Centre. The RSA hierarchy of decision-making is an insult to the Federal character of our Constitution and its clearly defined relationship of the states to the Centre.

The DNEP is emphatic on global challenges and India’s emerging position in the Knowledge Society. Yet, it ignores latest research on the non viability (and increasing unpopularity) of Online Learning and MOOCs as alternatives to regular classroom interaction between teachers and learners. Its enthusiasm for the application of digital technology in education is not echoed globally, even though digital infrastructure in many countries across the globe is far more advanced than in India. The unsaid agenda in its recommendations on Online Distance learning seems to be focussed on the twin objectives of cutting costs and increasing enrolment exponentially without having to create adequate physical infrastructure and appoint more teachers.

In its general advocacy of State-promoted private expansion of education and modularised courses and curricula, the DNEP undermines social equity and democratic access to education. It impedes unconventional, critical thinking and free enquiry by tying value-education up with a Vedic belief system that is not in consonance with current times and Constitutional principles and by again allowing a centralised National Research Foundation (NRF) to identify, approve and fund all research projects and topics. It insists on an Outcomes-based Model (derived from the iniquitous Reagan-era regulatory framework that has already become discredited and disputed in the advanced countries) that shifts the emphasis from insistence on minimum inputs and standards to a mechanical efficiency in resource utilisation and greater financial liability of institutions. Through this, it imposes uniformity and one-size-fits-all solutions on a diversity of learning needs and circumstances that require nuanced policy responses.

While the DNEP is voluminous enough to provoke substantial debate and discussion, its operative part is thin compared to its subjective articulation of what is desirable. As a public policy document, it inexplicably leaves out the basic responsibility of public funding out of its scope (pg. 33, DNEP) – relying, instead, on the imagined benevolence and commitment of governments. As such, it merely leaves itself to be taken up as a set of guidelines rather than actionable policy that is binding on governments. In the rest of this document, we will state our critical observations – point wise – on the specific policy recommendations made by the DNEP, in relation to School Education and Higher Education.

II.         School Education

1.           The DNEP has not assessed the impact and shortcomings of the National Literacy Mission (NLM). As a result, literacy goals are not matched by a realistic and sustainable roadmap that can be implemented to ensure that literacy levels are raised across social groups, classes and communities. India’s current literacy rate of 74.24% is way behind many other developing countries, including Sri Lanka. Hence, it is disappointing that the DNEP does not give adequate attention to the challenges facing the National Literacy Mission.

2.           Malnutrition has not been given the consideration it merits. India presents alarming figures of malnutrition among children. It tops the list of global malnutrition figures at 46.6 million children (2018 figures, Global Nutrition Report). While the DNEP argues that “over 85% of cumulative brain development occurs prior to the age of six” (pg. 47, Chapter 1), it fails to see the role that such a shamefully high rate of malnutrition plays in stunting the brain development of the vast majority of Indian children. There are no observations on the shortcomings of the Mid-day Meal scheme or the inadequacy of budgetary allocations towards it. In fact, the chapter on early Childhood Care and Education (ECCE) (Chapter 1) is scandalously silent on the need to commit adequate public resources and efforts to eradicate the problem of Malnutrition. The abstract reasoning in this section of the DNEP has very little connection with ground realities and concrete challenges.

3.           Three-Language Formula at the Primary level is lop-sided, impractical and overburdens students. While language skills are central to the development of cognitive abilities, the imposition of three languages at the formative level is lop-sided and will overburden students. There is merit in introducing a third language at the secondary level, not before. Primary learning should involve the mother-tongue (language of domicile) in all its emphasis.

4.           The DNEP has failed to account for the policy shortcomings that have led to the decline in Science Education. Schools are short-staffed and are made to function with inadequate funds. While practical learning and laboratories are integral to the accomplishment of learning objectives in the Sciences, few schools have proper laboratory infrastructure to accommodate the desirable practical hours for all students. Systemic checks to ensure adequate provisions for school labs are absent. There is a dearth of quality textbooks in different Indian languages. The DNEP ignores the growing crisis in Science Education.

5.           The DNEP does not address the hostile attacks on Scientific Temper. Obscurantism and hostility against scientific temper is being promoted at every level of culture. Representatives in public offices are often heard promoting unscientific ideas and values. A National Education Policy is expected to address the gap between people and scientific ideas by doing active Science advocacy. Governments are expected to raise awareness of scientific ideas and aid the people to inculcate scientific temper through mass media. The DNEP ignores the growing threat to scientific temper.

6.           The DNEP does not enquire into the causes for the failure of government-run schools. While the private sector dominates school education, government-run schools have drastically declined in terms of their quality and enrolment. Government schools are also showing alarming rates of dropouts in the last decade. Barring few exceptions, government schools have become unpopular and ineffective as instruments for a robust implementation of the Right to Education Act. The causes for this overall decline have not been investigated properly in the DNEP. Instead of analysing the failures and suggesting concrete ways of strengthening government-run schools, the DNEP advocates multiplicity and Public-Private Partnership.

7.           ‘School Rationalisation’ threatens local access for the underprivileged. The DNEP’s recommendation of ‘School Rationalisation’ wherein schools with less than 50 students may be merged into ‘School Complexes’ (Chapter 7, DNEP) is unacceptable. Such a move will reduce local-area access for students and the underprivileged students in remote and tribal areas will be especially impacted by such mergers. The School Complex radius of 3 kms is too wide to cater to students who do not possess the means of travel. If such a recommendation is hastily adopted, it will contribute to increased rates of dropout and undermine the Right to Education.  Further, this will be more disadvantageous to children with disabilities.

8.           Proposed Amendment to Sec. 12 (c) of the Right to Education Act: The proposed amendment to Sec. 12(c) of the RPD Act to do away with the 25 per cent reservation for the “disadvantaged” category will deprive children coming from backward classes and communities to avail of quality education.

9.           Welcoming Multiplicity is a wrong step as it defeats the “Equal Outcomes” objective of the National Curricular Framework and encourages teaching shops. The DNEP is short-sighted in welcoming multiplicity in schooling. It mentions several different kinds of schools (including schools that provide explicitly religious instruction) and even homeschooling as possible alternatives to the shortage in public-funded school infrastructure. Multiple types of schools that include gurukulas, madrassas, home-schooling etc. will lead to unevenness in the pedagogical pursuit of learning outcomes and encourage more privatisation. It will also undermine the “Equal Outcomes” objective of NCF (2005). The DNEP fails to recommend minimum standards that are essential to make the Right to Education meaningful.

10.        National Tutor Programme (NTP) and Remedial Instructional Aides Programme (RIAP) are dismissive of quality parameters in teaching. The DNEP’s recommendation to institutionalise NTP and RIAP in schools by drawing the best performing students into ‘para-teaching’ is a fallacious exercise in improving the performance of a students who may not be at par with their peers. Such teaching requires more experience and sensitivity to the learning challenges that such students face. Teachers are trained to respond to learning challenges and help students overcome them. To replace trained teachers with para-tutors and peer-tutors is to ignore the question of quality teaching for such students. Additionally, “Remedial” connotes a defect in a child that has to be “remedied”. It can have adverse psychological impact on children segregated for such “remedy”.

11.        Parents in School Management Committees. Parents are legitimate stakeholders in education. However, to accord them a role in evaluating the performance of teachers may lead to conflict of interest.

12.         Dilution of Board Examinations and replacement with NTA-conducted tests adds to the academic burden on students and encourages commercialisation. Tests and competitive exams have created an informal and highly commercial sphere of activity related to private coaching shops and dubious publishers of guidebooks and solved question-papers. Dilution of Board Examinations and the addition of NTA testing will only promote this exploitative commerce and add to the financial burden on students and parents.

13.        Lack of insistence on inputs is against the interests of students and teachers. To ensure the accomplishment of learning outcomes, policy must insist on adequate infrastructure, teachers and learning resources. By leaving the concern for inputs out of the regulatory parameters, the DNEP shows scant regard for an adequate and secure learning environment that students and teachers are entitled to. Regulation cannot be done solely on the basis of outcomes measurement. The preconditions (input requirements) and causes for failure or deviation must be examined thoroughly and insisted upon, both in policy and in regulatory practice.

14.        Value Education invokes selective ideas and is not in consonance with a modern, democratic and secular outlook. The Ethical and Moral Reasoning (4.6.8) and Knowledge of India (4.6.9) components in School Education indicate a narrow moral compass wherein ideas and figures are selectively invoked. The Constitution of India has been given a short shrift. Principles of Secularism and Socialism have been left out in order to project a partial picture of the Indian democratic ethos. While India is a diverse and historically evolving entity, the perception of its historical stages of development has been muddied through mere thematic references to the philosophy, yoga, mathematics, literature and political ideas in Ancient India. In fact, Value Education in the DNEP seems to have been held hostage to propaganda of Brahminical ‘virtue’, while anti-caste and anti-racism voices like Ambedkar and Nelson Mandela are included as token diversions. Since Value Education is a serious component of School Education – more relevant in current times than ever – the DNEP ought to have given a far more serious consideration to the Indian Constitution and to the ideas of modern Indian leaders who represent the entire ideological spectrum that has been active in India’s public life.

15.        Universal Access: The principle of universal access is missing from the DNEP. “Access” is understood in the traditional term and confined merely to ramps, handrails and toilets.

16.        Rights of Persons with Disabilities Act: The DNEP does not acknowledge the Rights of persons with Disabilities Act, 2016, which has various provisions for children and adolescents with disabilities.

III.      Rashtriya Shiksha Aayog (Chapter 23)

It is proposed that the centralised Rashtriya Shiksha Aayog (RSA), led by the Prime Minister, will be the apex body deciding on, monitoring and regulating all levels and processes that relate to the generation, dissemination and movement of educational resources and skills. It will comprise of union ministers and senior bureaucrats attached to the Union Government. The prerogatives of federal agencies like state and local governments will have to remain subordinate to the Centre’s will or, at best, are likely to be accommodated in token fashion. The concurrent equality between states and the Centre (in all matters pertaining to education) remains overlooked in the Draft NEP. Therefore, the proposal to concentrate all authority on the RSA is constitutionally not just unacceptable, but untenable. The RSA will make policy decisions, budgetary allocations, review plans and monitor the bodies that will separately fund, set standards, accredit and regulate institutions.  It will also retain the authority to shut institutions down if it so deems necessary.

While investing such immense centralised power with the RSA, the Draft NEP does not make it accountable to any public review. The RSA Executive Council will review and judge all state-level plans and Institutional Development Plans (IDPs) of HEIs but is, itself, not open to scrutiny. In its essential character and purpose, the RSA appears to be a Behemoth neither respecting the Federal character of the Union nor subject to any checks or balances against possible authoritarian excesses and invasions.

The Draft NEP makes a case for substantial increase in public spending. However, it does not make it binding on the Government to commit itself to increased public spending. In fact, it carefully relieves the Government from all responsibility on this count by hoping, wishfully, that its recommendations are carried out over time. In the Preamble to the Draft NEP itself, the crucial aspect of Public Financing is kept out of the ambit of the Policy: “We must […] find the funding that education needs and find it quickly. For the sake of completeness, we have included a rough and preliminary estimation of the financing need for this Policy to be translated into reality within the next decade or so. Similarly, the broad steps we need to take to implement this Policy are also included in the Addendum. Both of these are more in the nature of guidelines for implementation and not directly part of the Policy.” (pg. 33, Preamble, Draft NEP).