A team of alumni of various institutions of India worked together on perusing the DNEP with a critical eye, and identifying points of concern. What follows is a report of the findings: a general critical overview, followed by detailed analyses of certain issues.
The draft National Education Policy (DNEP) was released by the Union government in early June. It is an almost 500 page document that proposes massive restructuring of the entire education system, both school and higher education, in the country. A period of one month’s time was given for public comments initially, which was later extended by another month to July 31, and has now been extended until August 14.
A team of alumni of various institutions in the country worked together on perusing the draft with a critical eye, and identifying points of concern. What follows is a comprehensive report of the findings: a general critical overview, followed by detailed analyses of certain issues. This analysis does not cover Chapters 1-4, 13, 16 and 19-23 of the DNEP. Some notable issues thus left out are the excessive push of Sanskrit  and the three language formula, and the thrusting of common entrance exams , that have been shown to be biased towards socio-economically advantaged students , which in the case of certain states is also in direct contravention of state policies .
The main feature of the DNEP that stands out evidently is its dictatorial nature. No supporting evidences or references are given for any of the arguments made, and a lot of the arguments are also logically fallacious. Further it is presented as if it is the first such policy of a country, and not as a policy change. It sounds like a reset button or a start from scratch, instead of as building on the existing set-up. So, understanding the nature of changes being proposed is difficult, as the policy says little about the current set-up. This is especially true for matters relating to regulation of educational institutions in the country.
Another important feature of the DNEP is that it proposes one-stop solution to all problems, caring little about federalism, state powers, institutional autonomy, or social and cultural variations demanding different approaches.
The emphasis on building multi-disciplinary capacity at all institutions, and consolidation of Higher Educational Institutions (HEIs) is extreme. The policy lacks ideas on moulding of thoughts towards inter-disciplinary education and research. As opposed to incentivizing Professors at existing multi-disciplinary institutions for introduction of new multi-, and inter-disciplinary courses, or inter-disciplinary research projects, or activities to broaden the public view of education, the policy calls for what seems only like moving around infrastructure, in fact, clumping of infrastructure in smaller number of institutions. In fact, this move-around of infrastructure is a tremendous overhaul that will affect the entire higher education system in the country. The scale of this change, without any test or pilot programmes carried out at smaller scales, and the lack of uproar in academic and political circles, sounds ominous.
The big push for liberal arts education is another key feature of this draft. The exact nature of ‘liberal arts’ that the committee has in its mind, has raised a lot of questions . It seems like addition of India specific fields of study, and an infusion of nationalism in to existing liberal spaces.
Teacher Education in multi-disciplinary institutions:
The policy emphasizes, strongly and one-too-many times, on ALL teacher education to be carried out ONLY in multi-disciplinary HEIs. It envisions this to happen by 2030. The rationale that is given for this repeatedly, is that teachers ‘require training in a range of content’ [pg. 119]. This is a hand-wavy and lazy argument, without any further evidence or explanation. The assertion that teacher education needs to make them engage deeply with the aims of education, the nature of knowledge, issues around child development, and social context of learning etc. is well-intentioned and makes sense. Yet, this doesn’t fully justify requiring all teacher education to happen in multidisciplinary HEIs. It is only a call for curricular improvement.
Further, the policy says that the process of closing down substandard standalone teacher education institutions will be immediately initiated through mandatory accreditation of all Teacher Education Institutions (TEIs) as multidisciplinary HEIs in the next 3-5 years [pg. 136]. It even goes on to say ‘single-stream programmes must be phased out’ [pg. 284]. Yet, the policy does not talk about how and whether standalone TEIs will be supported in this process of transitioning to being a multi-disciplinary HEI. Thus, it looks like a lot of these institutions are at risk of getting shut down.
Overall, this is a tremendous structural change that needs huge fiscal support. The policy has little to say on this, besides acknowledging the need.
Change from (3-year bachelors + 2-year B.Ed.) to 4-year integrated B.Ed.:
The policy says that ‘by 2030, the minimum degree qualification for teaching will be a four-year liberal integrated B.Ed. degree’ [pg. 120]. The present route to teaching, consisting of a 3-year bachelors + 2-year B.Ed., will continue to exist, albeit only in those multi-disciplinary HEIs that also offer the 4-year integrated B.Ed. The thought behind this move is not fleshed out in the policy.
Firstly, do we have an estimate for the number of students coming out of school today who immediately want to pursue a teaching career? This seems like an important statistic that will affect the success of the 4-year integrated B.Ed. programme.
Secondly, it seems that this programme is aimed at a specific group of students, and that could be a problem. The policy says a large number of merit-based scholarships will be instituted for study in this programme. It further says that students from underprivileged socio-economic backgrounds, rural or tribal areas, and female students will be special targets for these scholarships [pg. 121]. There is little doubt that these initiatives, including guaranteed jobs, will be extremely useful for female students and economically poor students, and help them come up in life. But, possibly deleterious consequences need to be given some thought. Female students are not encouraged to take up professional courses like engineering, medicine, business or law in society today. This targeted approach to recruiting students for 4-year B.Ed. programmes may end up strengthening the existing bias. Opportunities for exploration and seeking one’s calling, in regard to career and life path, are being limited by this change. A student who does a Bachelors in Science may get inspired to pursue a research or technical career. On the other hand, a student in the 4-year B.Ed. is unlikely to pursue an interest leading to a non-teaching career. By the nature of the 4-year B.Ed., this will mainly affect economically poor and female students.
Access and Inclusivity in the move towards school complexes:
The establishment of school complexes is good for coordination in management, professional development of teachers, and improved learning resources for students. But, according to the policy, the route to this may involve closing down of ‘unviable’ schools [pg. 168]. This is a cause of concern without any other counter-measures, because it compounds the problem of accessibility. Already, a lot of states have cited fund crunch to merge or shut down a number of government primary schools that have less attendance . While the policy says on the one hand that it ‘considers all financial support and spend on education as investment and not expenditure’ [pg. 399], it fudges this increasingly pressing issue of preventing government schools from shutting down.
The policy mentions that significant autonomy will be given to school complexes towards providing integrated education, and to experiment with pedagogies, curriculum etc. It also mentions that schools and school complexes will form their development plans, and lists a number of factors these plans should include. It will be good to also recommend that these development plans include local access and inclusivity related goals and outcomes, for e.g., in terms of primary enrollment rates. The social workers associated with school complexes could help in this process. It will also be a concrete way to ensure teachers are invested in their communities. This will also help in getting grass-root level data about primary enrollment rates across various groups including URGs, which will be very helpful for future planning.
While the grouping of schools into school complexes has several benefits, it must be ensured that this doesn’t compromise the fundamental facilities and resources at each individual school. The policy states that ‘school complexes will also share counsellors, social workers, technical and repair staff’ [pg. 118]. This doesn’t sound ideal, and looks like a budget cut move. The presence of technical staff at all times seems essential, for example, especially with future classrooms expected to be increasingly technology driven.
Deregulating private schools:
The policy says that private schools will continue to be non-profit entities. While it proposes regulation on fee increase and elimination of unanticipated fees under any ‘fees head’, it gives near-full freedom for private schools to set their fees [pg. 191]. The policy doesn’t propose any solid measures to combat education becoming a business. It doesn’t address the existing problem of private schools working around the bar on profiteering .
Moreover, it calls for a review of RTE Act 2009 Clause 12(I)(c) which obligated private schools for providing 25% free admission to disadvantaged and weaker section children in class 1-8. Prevalent misuse of this clause is cited in calling for this review, yet no data about the extent of misuse, or studies conducted on this issue, is given or cited [pg. 193]. Both these matters give increased freedom to private schools, and one could reasonably fear that this may compound the problem of widening socio-economic disparity.
In this regard, inconsistency of the policy is evident. While the policy acknowledges that ‘private schools have, over the last 50 years, become much less diverse in socio-economic profile’ and that ‘it harmfully stratifies the school system and access to it’, it goes on to say that ‘giving schools the autonomy to do the right thing is in general the better way’ [pg. 191]. It also calls for regulation of private schools within the same framework as public schools, and an end to what it calls ‘the loading of regulatory requirements only against private schools’ [pg. 190]. The listed principles for the development of School Quality Assessment and Accreditation Framework (SQAAF) omits any parameters that may measure socio-economic diversity and inclusivity [pg. 186]. In light of this, it is imperative for organisations invested in social equity of education, to actively watch the development of SQAAF.
Phasing out single-stream Higher Education Institutions and the move towards large multi-disciplinary institutions:
The policy envisions a complete moving of all Higher Education to multi-disciplinary institutions. It justifies this using vague undefined arguments like “21st century requirements”, “preparing for the next industrial revolution” etc [pg. 202]. Being specific about the need for this move, the rationale behind it, and supporting evidences or studies, is necessary to understand the vision of this document.
Moreover, the glorification of ancient universities like Nalanda and Takshashila as first multi-disciplinary institutions, talking about them at par with modern universities, the repeated invoking of nationalistic pride, and the clarion call for ‘bringing back this great Indian tradition’ [pg. 206], do nothing but raise more suspicion, and makes one wonder about the kinds of thought that have gone in to the making of this draft. When scholars are divided over whether Takshashila was a university in the modern sense , references to the number and varied composition of students, and the multi-disciplinary environment of these universities are not valid claims, and definitely cannot be valid justifications for a policy in the 21st century. Further, by calling it “great” outright, the draft simply asserts that it is the correct way forward, without any evidence.
The notion put forward by the draft that students are benefited only from being in large multidisciplinary institutes is unjustified, and has no evidence. Small liberal arts colleges in the US like Sarah Lawrence and Barnard harbour great thought. India also has some great institutions like CMI, IMSc, NCBS, HRI etc. that are focused on one or two disciplines. A lot of great cutting edge research in Europe and the US comes out of specialised research institutes because the focus allows them to have more funding, equipment and other resources. At the personal level of students, small colleges and large universities each provide varied environments that suit different students well. It is a matter of compatibility with each student personally and psychologically. The draft says ‘all single-stream HEIs will be phased out, or will move towards becoming multi-disciplinary’ [pg. 207]. This is extreme. Besides, doing this also risks the scenario where universities have namesake multidisciplinary departments in order to keep running – ending up wasting resources. Hence, mixed portfolios – having large HEIs and also small ones – is ideal.
The criteria for an institution to be called multi-disciplinary, as specified in this draft, is that it offer at least two programmes or majors in the arts and humanities, at least two in science and mathematics, and at least one in the social sciences [pg. 212]. The need for a multi-disciplinary environment makes sense for people doing a general Bachelors degree in arts (as in US) and people inclined towards basic sciences and research etc. But, the need for medical colleges to be in a multi-disciplinary environment is miniscule. Instead it is crucial for them to be in a hospital and biological research environment. Also, for people looking to do professional courses and practice as an engineer, lawyer etc after their studies, what are the demonstrated benefits of doing their studies in a multi-disciplinary environment? The draft ignores all these issues.
Further, it is also extremely difficult to imagine how all of the professional educational institutions of today, which are numerous, will transform and grow in to multidisciplinary HEIs.
One of the main driving points of this whole move is that ‘India’s higher education has developed rigid boundaries of disciplines and fields, along with a narrow view of what constitutes education’ and that ‘silos need to be broken between disciplines to encourage more multi-, inter-, and cross-disciplinary conversation, interaction, events, education, and research’ [pg. 203, 235]. This is agreeable. Yet, the proposed solution is too extreme and doesn’t address the issue at hand. There are existing institutions, like DU, Xavier’s, Josephs, the public Universities of Madras, Mumbai, Calcutta, Pune etc., that already have a multidisciplinary environment as mentioned in the draft. What will the newly proposed Multidisciplinary Education Research Universities (MERUs), or all the HEIs that manage to transform successfully into multi-disciplinary institutions, do differently that will break these silos? There is no solid implementation idea for that in this draft.
Liberal arts education:
The policy places undue emphasis on liberal arts education, and presents it as the magic wand solution to lead us in to the 21st century. A country’s policy change requires more evidence and justification than that a liberal arts education ‘enriches one’s life, and makes it so much more meaningful and joyful when one is able to appreciate many worlds’ [pg. 224]. The policy mentions about world’s greatest innovations having occurred due to cross-fertilisation of ideas, and Nobel prize winning scientists being three times more likely than the average scientist to have an artistic hobby [pg. 225], to fallaciously argue for the importance of liberal arts education and to drive home the point that ‘high quality liberal education and high quality research must go hand-in-hand’ [pg. 235]. Correlation is not the same as causation. These Nobel winning scientists with artistic hobbies could just be individuals who are inherently better at managing their time for instance. After one eliminates such fallacious arguments, the draft is severely lacking in justification for the extremely strong push for liberal arts.
Further, one cannot but call in to question the nature of the proposed ‘liberal arts’ education . Liberal arts gets equated in the policy with adding India-specific fields of study, namely ‘Indian languages, Indian literature, Carnatic, Hindustani, folk, and film music, Indian philosophy, including Buddhist and Jain philosophy, Indology’ etc. to all universities [pg. 226]. This cannot be an excuse to infuse nationalism into our existing liberal spaces. If this has to become truly liberal and addressing “21st century problems”, it has to be broad-based and global.
The humanities and social sciences section of the proposed core curriculum is also limited to India [pg. 229]. This needs to be expanded to stay globally relevant. If the aim of this policy is to prepare one for jobs in the global market of the 21st century, this will only stifle the student’s prospects.
The policy also strongly encourages ‘research and teaching in the languages, culture, and history of India’s neighbours’ to promote regional peace and mutual economic growth [pg. 236]. Yet, there is no answer to how these fields and the content of these courses will be decided. Ensuring that the learning is truly independent of govenrnment’s policy towards the neighbor is extremely crucial for these programmes to be of true worth.
The policy suggests that research and teaching programmes will be dynamically and proactively introduced to promote quality research and foster quality liberal education. It identifies some relevant fields classified under one of “strategic areas”, “economic importance” and “emerging fields” [pg. 236]. There is no mention of public health, social inequality, climate emergency – all of which are globally relevant crisis fields, but funding typically goes to technology and innovation related fields. If liberal arts education also focuses mainly on subjects decided by the government as important to national interests, this is not liberal in any sense.
The draft policy says that ‘students will be required to attain proficiency in discussing their major in at least one Indian language’ [pg. 230]. It also calls for ‘all doctoral students to take a unit on communication in at least one Indian language other than English’ [pg. 233]. These hinge on a lot of factors. Firstly, they presuppose the creation and promotion of technical vocabulary for all major fields of study in all languages of the country, at least the 22 languages recognized under the 8th Schedule of the constitution. Further, it also requires that institutions allow equal choice of language for all students, and has adequate support facilities for all languages. Without these fundamental provisions, it is unethical to make this a graduation requirement. The very fact that this policy document, which is going to lead the country in to massive change and which seeks public inputs, was released only in English and Hindi is not particularly reassuring.
Access at Higher Education Institutions:
Among the many challenges currently facing India’s higher education system, the draft policy identifies as first “Fragmentation of the Higher Education System”. It says ‘India has over 800 universities and approximately 40,000 colleges, reflecting the overall severe fragmentation and small size of HEIs in the country’ [pg. 203].
Having a lot of educational institutions is being presented as a problem, provoking a lot of questions and extreme worry. The situation may also be described as representing the ‘accessibility’ of higher education, instead of “fragmentation”.
For comparison, US has around 4300 higher education institutions. The population of India is a little more than 4 times the population of US. Furthermore, the social culture at a lot of places in the country, especially in rural areas and among weaker sections of society, like fear of safety of girls etc., places huge hurdles on students, especially girls, to travel far, or stay in hostel, to pursue higher education. So, having HEIs remain accessible in terms of distance from home, is extremely crucial in this regard. Any closing down of existing institutions will affect access detrimentally.
While the policy recognizes “Lack of access” as the third challenge, measures to combat the above-mentioned cultural problem are lacking. As the proposal of ‘consolidating Higher Education in to smaller number of large HEIs’ is poised to exacerbate this problem, no concrete ideas have been proposed in this policy to counteract and tackle the same. It is crucial that social organisations keep a watchful eye on Gross Enrolment Ratio (GER) in higher education of women, socially backward categories, and disadvantaged geographies, if this suggested change is undertaken.
One of the mains aims mentioned in this draft policy is to achieve a GER of 50% in higher education [pg. 201]. The policy intends to leverage the full potential of “Open and Distance Learning (ODL)” to enhance access, and expects that it ‘must play a significant role in increasing GER to 50%’ [pg. 247]. But, the problem of access to a reliable internet connection, a key requirement for the providing and success of online learning courses, is completely overlooked. Further, some recent pedagogical research suggests that online courses may not be quality substitutes for in-class learning and may even lead to underperformance of disadvantaged students . This leads one to be skeptical about inflated GER numbers in the future, not representing reality accurately.
Finance of private HEIs:
The draft says that ‘a National Scholarship Fund will be established which will ensure that all students who require financial support to attend a public HEI will receive it’ [pg. 245]. This is great, if it can be implemented and gets implemented well.
For private HEIs, the draft policy provides full freedom to set their fees, but mandates that 20% of its students get a full 100% scholarship, and another 30% of its students get a scholarship of at least 25% [pg. 334]. The proper implementation of this is a regulatory criteria for private HEIs. This overarching regulatory principle about providing financial support needs to be thought in to, with a lot more care. The various kinds of institutions, that India has, pose a big challenge. A number of them, small and catering wholly to local students coming from poor or middle class backgrounds, and running on minimal fees, may be forced to shut down unless they are able to find sufficient capital, and expand to attract students from richer backgrounds as well. Will these institutions be supported in this process? No. The policy is clear in that ‘private HEIs will arrange for their own financial autonomy’ [pg. 319].
The bigger aim of the policy to ‘consolidate’ the ‘fragmented’ higher education system, and ‘move it entirely in to large multidisciplinary institutions’, may very well hinge on the effective implementation of this regulatory apparatus and the shutting down of such small institutions.
Issues related to learning environment in HEIs (caste, class, gender):
The current issues affecting learning environments in Higher Education have been cited as ‘rigid and narrow curricula’, ‘faculty lacking autonomy to design their curricula’, and finally, ‘student support being non-existent at most institutions’ [pg. 240]. This is extremely reductive. The policy manages to reduce the diverse nature of issues a country like India will definitely face, into a few paragraphs. Common issues students face has been incredibly generalised and is acknowledged as nothing more than ‘the stress and pressures’ resulting from it being the ‘first time in students’ lives when they are living and working independently’ [pg. 239]. There is no mention of specific issues around caste, gender or class. Ideas seem to have been formulated without due consideration of India’s specific problems.
Sensitisation of students to caste, and the reservation system, is a very pressing need today. It is a crucial time educationists address this issue. The extremely harmful culture of quota-bashing and the isolation of socially backward students, that is prevalent and on the rise in all institutes, especially IITs, AIIMS etc, a lot of which have been documented and reported on in the last two decades , needs to be tackled. Students must be sensitized to the nature of reservation as affirmative action, and be informed of the channels for reporting and the strict measures against discrimination.
While the policy talks about ‘meaningful opportunities for social engagement of students in HEIs’ and their ‘involvement in institutional processes’ [pg. 243, 245], it doesn’t say anything concrete. Involving graduate and senior undergraduate students in organizing such orientation events, and monitoring of issues, presents a concrete avenue for the same.
Moreover, any institution needs to have adequate grievance redressal mechanisms at all levels for all kinds of issues. For example, a women’s cell with adequate mechanisms in place to report instances of sexual harassment, Human Resource cells, conflict resolution mechanisms etc, are compulsory for all educational institutions. The pervasive problem of workplace harassment in academia needs to be addressed, by enabling the provision of strong institutional help and support to those affected. It may prove useful to involve graduate student representatives in such cells. The draft policy doesn’t talk about any of these issues, necessitating a rethink. There is also no mention of student bodies like unions etc, or the possibility of student bodies partaking in the administration. This needs to be given some thought as well.
One stop solution for everyone and everything:
The essential feature of this draft policy is that it proposes a one stop universal solution, caring little about variations. The call for all HEIs to become large multi-disciplinary institutions, with little care about the benefits a specialized institutional environment may provide, is representative of this feature.
The draft also ignores wholly the existence of regional, cultural or demographic variations in any given issue. One of the main goals set, is a Gross Enrolment Ratio in higher education of 50% over the period of this policy. It is to be noted that Chandigarh and Delhi already have a greater than 50% GER in higher education in 2017-2018, and Tamilnadu has a GER of 48.6%, while the national average is 25.8% . The draft policy doesn’t mention this, or take this in to account in any way. Tamilnadu’s approach to attaining this GER has been focused on increasing accessibility by increasing the number of HEIs. The proposed consolidation into large HEIs will tamper with this approach, for example, and may even reduce GER in the state.
The draft also stresses on ‘equitable distribution’ [pg. 221] of all institutions across states and regions. While this may sound like a good thing to some, or naïve to others, it is extremely scary as it is in tune with the increasingly authoritarian attitude of Union governments with respect to the constituent states, and represents another threat to federalism. Since the subject of education has been under state purview for a long time, and then moved to concurrent list, there is a disparity in how various states have handled the subject. Some states have invested heavily, while others have not. Any Union body acting with the aim of ‘making’ the distribution of HEIs equitable across states, needs to tread its path carefully, and states have to be watchful to protect their interests. Since the policy calls for ‘integration in to one higher education system’ [pg. 213], and all regulatory and accrediting powers are being transferred to the National Assessment and Accreditation Council (NAAC), an autonomous body at the level of the Union, the situation is all the more scary [pg. 325].
Regulating HEIs, autonomy of HEIs, and state powers:
The draft policy proposes to ‘have only one regulator for all higher education’ [pg. 210], even though it starts out by saying that ‘the regulatory system has been rife with basic problems, such as concentration of power within a few bodies’ [pg. 205]. The separation of the various distinct functions of funding, standard setting, accreditation, and regulation sounds good. Yet, there is a great need for clarity and details, both in terms of explaining the current situation, and the proposed change.
Furthermore, the policy states that the regulatory and administrative powers of State Departments of Higher Education and State Higher Education Councils will be abolished [pg. 332]. Instead, NAAC will issue licenses to new Accreditation Institutions (AIs) to do the job [pg. 327]. These will be public or private not-for-profit institutions, or agencies set up by HEIs. The Institutional Accreditation Frameworks (IAF) will be created by the National Education Commission, a new apex body headed by the Prime Minister. So, effectively, the existing state bodies are dismantled except for being financial-support providers (they transform into facilitative bodies), and new bodies at the level of the Indian Union are being or have already been formed to overlook all matters regarding education in the country. It makes one wonder if state powers have been grabbed as swiftly and quietly, ever before.
Talks about ‘gradual granting of autonomy to higher education institutions’ [pg. 208, 319] present the policy as a reset button, instead of a policy change which ought to be the case. What happens to existing institutions that already have financial autonomy? Does the policy propose to take this away, citing regulation under new guidelines? When premier research institutions like IISER and NCBS that had lots of funding in the beginning, are struggling to sustain themselves facing huge financial cuts currently, one is left to wonder what will happen to existing financially autonomous institutions under such a change in policy.
. F. W. Thomas (1944), in John Marshall (1951; 1975 reprint), Taxila, Motilal Banarsidass, Delhi
. Professor Sukhadeo Thorat Committee report about differential treatment of SC/ST students in AIIMS http://www.nlhmb.in/Reports%20AIIMS.pdf
Disclaimer: The opinions expressed in this article are the personal opinions of the author
The other articles in this series can be found here.
Errata (05-Aug-2019): The name of the second author was wrongly spelled in the original post. The mistake has now been corrected.