The Bengaluru Collective, a citizen’s group, organized a one- day Public Consultation on the draft NEP on Sunday, 23 June 2019 at the Raman Research Institute, Bengaluru. The Public Consultation saw participation from researchers and academics from higher education institutions in Bengaluru and activists and groups working on Right to Education and Early Childhood Care and Education,  including activists from the People’s Science Movement and the Free Software Movement- Karnataka. Prior to this meeting, the group created an abridged version of the draft NEP (also accessible here) for better dissemination of the Policy among the public. The group also compiled the views of the various stakeholders into a set of comments and recommendations on the draft NEP, which was then submitted to the Ministry of Human Resource Development. Bengaluru Collective highly appreciate the tireless commitment and efforts of all the participants and volunteers, especially

• Abha Jeurkar (Research Scholar, TISS Hyderabad),
• Abhishodh Prakash (Post Doctoral Fellow,  International Centre for Theoretical Sciences),
• Dr. Anil Kumar Avulappa,
• Arun Bahuleyan (Research Scholar, Raman Research Institute),
• Deepak Johnson (Research Scholar,  ISI Bangalore),
• Neenu Suresh (Research  Scholar,  NLSIU),
• Hariprasad S,  Joshy Ravindran,
• Lohith B Dev (Student, ACS College of Engineering),
• Rohith Bisht (Researcher,  Azim Premji University),
• Rimsha Hamza (Public Policy student,  NLSIU),
• Ram Seshan (Free Software Movement of Karnataka),
• Dr. Shan S,
• Prof. Sadiq Rangwala (Raman Research  Institute),
• Prof. Sabyasachi Chatterjee (retd. Indian Institute of Astrophysics),
• Shreyas Dinesh (Research Scholar, Raman Research Institute) and
• Dr. Sidhharth

in compiling the abridged version, organizing the Public Consultation and also compiling the feedback from the Consultation for official submission.

A pdf version of the recommendations below can also be found here and here.

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Feedback and Suggestions on the Draft National Education Policy 2019

Part I- School Education

Chapter 1

Early Childhood Care and Education: The Foundation of Learning

1. The chapter on Early Childhood Care and Education (ECCE) places undue importance on Early Childhood Education (ECE) for children of age 3-6 years, shifting the focus away from a comprehensive, multi-sectoral, integrated ECCE system prescribed in the National ECCE Policy 2013. This dilutes the comprehensive understanding of ICDS programme, where the components of care, nutrition, healthcare and early education are provided in a holistic manner to young children from the age of 0-6 years.
2. Bringing ECE under the purview of Ministry of Human Resource Development (P1.3.) will lead to splitting of the administration of ECCE to two departments, from the current system of comprehensive administration of ECCE through the Ministry of Women and Child Development. Given the existing issues in ensuring inter-departmental convergence, early childhood will no longer be looked in a comprehensive manner, thereby affecting the holistic provision of services to young children.
3. The draft Policy recommends co-location of Anganwadis alongside the opening of pre-schools in schools and stand alone pre-schools (P1.2.). Such a recommendation will aggravate the drain of children of 3+ years from Anaganwadis to schools. It is not understood why the draft NEP recommends opening of pre-schools when Anganwadis are already catering to children of this age group.
4. Locating pre-schools in the school premises is feared to lead to penetration of methods of schools to pre-schools. While the recommendation for extending RTE Act to include ECE is commendable, this should not lead to a downward extension of primary school education. The provision on curricular and pedagogical framework lacks clarity on this (P1.1.).

Chapter 2

Foundational Literacy and Numeracy

1. The idea of foundational and core curriculum is not new. The NPE 1986 talked about ‘minimal levels of learning’ as well. This Draft rightly quotes ASER reports for the lack of learning levels. However, it does not refer to relevant studies from language and literacy pedagogy to understand why children are not able to learn basic literacy. It merely mentions the lack of school preparedness and rote learning as the prime pedagogic reasons for low levels of literacy. This is ill-informed.
2. The Draft Policy mentions generic pedagogic factors such as ‘multi-level, play-based, student-centered’ approaches. Language pedagogy is more nuanced than that. Recent research reveals non-sequential and emergent teaching-learning of speaking, listening, reading and writing; balancing of lower-order and higher-order skills; meaning-centered reading instruction and so on. These need to be included appropriately. Ideas like ‘language weeks’ and ‘fun puzzles’ are merely supplementary to the core principles of language and mathematics instruction. Expert advice is to be taken into consideration for more robust teaching-learning principles.
3. The suggestion that children can learn three languages (speaking, comprehension and fair level of reading) under the age of 8 does not take into consideration factors such as lack of natural exposure to languages, flawed language pedagogy and lack of trained teachers. Without correcting these parameters, the burden of learning languages is likely to increase significantly.
4. The decision of which languages need to be taught to children and when, could better be taken at the state level, in proper consultation with educationists and language pedagogy experts.
5. National Tutors Programme (NTP) and Remedial Instruction Aides Programme (RIAP) (P2.5. P2.6., P2.7.) demonstrate an attitude of de-professionalization in the teaching of foundational numeracy and literacy. Foundational language and numeracy teaching and especially remedial instruction are specialized areas that need to be addressed by well-trained teachers only. Instructional aides, as per the suggestions in draft NEP, would end up working as para-teachers. The Policy suggestion to utilize the “best performers” in each school for NTP is equally lamentable for its idea of grading the children and also leading to de-professionalization of teaching foundational numeracy and literacy. The responsibility of managing volunteers, tutors and instructional aides falls on the teacher, and this is likely to distract the teachers from their core responsibilities. The answer to lack of learning levels is more systemic, and cannot be fixed by the same shoddy quick-fixes that have proven to be ineffective in the past.

Chapter 3

Reintegrating Dropouts and Ensuring Universal Access to Education

1. Despite acknowledging the lack of secondary schools and school infrastructure as the key reason for drop-outs after the primary stage, the draft Policy suggests a consolidation of schools into school complexes (P3.1.). Its recommendation for consolidating existing stand-alone schools- especially those having low attendance of children- into composite schools/school complexes will in effect lead to closure of government schools and adversely affect the accessibility of education for children from the marginalized sections of the population.
2. Recommendation for loosening the RTE input restrictions (P3.12.), which are itself bare-minimum, is not substantiated by any research. School inputs and student outputs being intricately linked, it is not understood how a suggestion for less emphasis on inputs and more focus on outputs will improve the quality of education. It is feared that reducing the norms for inputs will encourage the proliferation of sub-standard private schools. With its suggestions for school complexes and loosening of RTE inputs, the push for privatization of education is writ-large in the draft Policy.
3. Commitment towards education by the government has its roots in the Karachi Congress, right from the Indian freedom struggle. The draft Policy completely drops its commitment towards the Common Schooling System (as introduced in the 1968 and reiterated in 1986/92 National Education Policy) and instead recommends school complexes, which is nothing short of shying away from the fundamental state responsibility of providing access to equitable and quality education to children in the country.

Chapter 4

Curriculum and Pedagogy in Schools

1. The rationale behind the shift to the 5+3+3+4 system (P4.1.1.) is unclear. Its implications to school infrastructure, teacher training, teacher appointments and nature of assessments need to be spelt out clearly.
2. While the draft Policy places much impetus on the need for moving away from rote-memorization, it states “…if and when rote learning is used, it will always be pre-accompanied by context and motivation, and post-accompanied by analysis, discussion and application” (P4.2.1). This is in complete contradiction with its call for developing high order skills of critical thinking and creativity.
3. Multilingualism is a desirable outcome in children. However, the planning for achieving proficiency in multiple languages needs to be done a lot more thoroughly and not by introducing ad-hoc courses like “languages of India” (P4.5.12.). The draft Policy’s suggestion for exposure to three or more languages to all students from pre-schools (P4.5.3) lacks credible research support. The Policy also falters in its commitment to home language/mother tongue as the medium of instruction. While RTE Act mandates that medium of instruction, shall, as far as practicable, be in child’s mother tongue, which in itself is a dilution in commitment to learning in mother tongue/home language, the draft Policy further weakens this commitment by stating that “When possible the medium of instruction- at least until Grade 5 but preferably till at least Grade 8– will be home language/mother tongue/local language” (Emphasis supplied) (P4.5.1.). In fact, there is much more emphasis on classical languages than that for one’s home language/mother tongue/local language in the document.
4. By suggesting that the choice of vocational courses will depend on the needs of local community and, schools may choose a subset of livelihoods and related skills that are of value to the local community (P4.6.6.1.), differentiation of schooling is feared to get exacerbated. For instance, children in villages are likely to have access to low-paying, caste-based and traditional occupations. On the other hand, children in urban schools are likely to have access to more lucrative and modern vocational skills such as artificial intelligence, computational courses, and creative use of ICT. Early vocationalization is likely to create a two-tier schooling system, wherein the “poor or poorly performing” children will be trained to become cheap labour, while well-performing elite children get access to forward-looking and modern vocational skills that can bolster their chances in the white-collar job market. The flexibility in choosing the available vocational courses is a pseudo-choice when it is restricted to vocations available near the school.
5. Constitutional values (P4.6.8.3.) are mentioned only as a sub-section of ethical and moral values. Constitutional commitments go way beyond teaching ethics to children. Constitutional commitment to free education to all need to inform the Policy in its entirety. Exclusion of secularism, which is a constitutional goal, from the section on Constitutional values is deplorable, especially given the erosion of secular values in Indian society today.
6. Digital Literacy section (P4.6.7.1.) does not define the nature of digital literacy that the draft Policy envisions. It is highly inappropriate to understand digital literacy as computational thinking, which the document defines as “the thought process involved in formulating problems and solutions in ways that computers can effectively execute” and “programming and other computer-based activities”. There is no adequate reference to the 2012 National Policy on Information and Communication Technology (ICT) in School Education. Use of technology for enhancement of educational processes is not conceived; it is referred to as a stand-alone skill. The mode in which the IT @School programme in Kerala allowed the teachers to integrate ICT in classrooms to enhance the experience of teaching through is proven to be very effective. The draft Policy lacks caution on the danger of digital programmes leading to substitution of teachers in classrooms, instead of enhancing their teaching methods.
7. There is a marked difference in the educational outlook of the National Curriculum Framework 2005 and the draft Policy. NCF 2005 was a far more enriching document, based on theories of learning which respected the “child as a natural learner” and “knowledge as the outcome of a child’s own activity”. The draft Policy falls short of imbibing this crucial aspect of education and instead speaks the language of developing skills for 21st century, employability and return of investments (as also seen in its focus on learning outcomes and census examinations). The revision proposed of NCF 2005 (P4.7.1.) to incorporate the Policy points will only dilute the vision of NCF.
8. The introduction of census examinations at grade 3, 5 and 8 (P4.9.4.) will increase the stress on children as already seen with the ‘board examination’. Commitment towards continuous comprehensive evaluation promised in the RTE Act will be substantially weakened by conducting multiple state-level census examinations in this way. Coupled with the focus on learning outcomes in the draft Policy, such examinations will divest the education system from being “process-oriented” and “child-centric”. Introduction of Modular and Additional board examinations (P4.9.5.) is likely to increase and not decrease the stress on students. Even as the document states that tests should not be used to evaluate teachers or school complexes, it commits to regulating the schools largely based on student outcomes. A weakened input system to the schools and strengthened output-based system of regulation is a recipe for systematically killing the government schooling system.
9. Introduction of National Testing Agency-administered tests (P4.9.6.) is likely to, (a) cause a boom in the private tuitions and (b) increase subjectivity in admission criteria. Both are proven to be hazardous for equity consideration in education. Instead, existing board exams should be made more flexible and modular in nature.
10. Sex education needs to be an integral part of education, especially at the middle and secondary school level. Further, environmental education also needs to be included in the curriculum.

Chapter 5

Teachers

1. Merit-based scholarships to encourage outstanding students to enter teaching profession (P5.1.1.) should explicitly mention the affirmative action that the Constitution guarantees to the Scheduled Castes, Scheduled Tribes and Other Backward Classes. It hides behind words like ‘underprivileged’ and ‘rural/tribal’.
2. Deployment of teachers to school complexes (P5.1.5), instead of schools is likely to have disastrous effects on smaller primary schools. In spite of the stress on breaking the hard separation of arts and science, vocational and academic streams and contents into curricular, extracurricular and co-curricular areas, the draft Policy proposes to share teachers within a complex for certain subjects such as art, music, physical education, languages, and vocational crafts. This suggestion will affect both teachers and children. Firstly, with reduced number of available posts, existing teachers will lose employment opportunities. Secondly, students in the school complexes will suffer without a specialized teacher in these subjects. Moreover, they will be discouraged from choosing a professional career in these areas of specialization. The Policy’s suggestion to hire local experts as “specialized instructors” to teach local traditional art, music, vocational crafts, language, poetry, literature or business after a short (10 day) orientation programme provided by the school complex questions its commitment to these specialized areas (emphasis supplied) (P5.5.3). Defining and identifying the local expert are prone to subjective considerations and also not all local experts will make good teachers. Consequently, these suggestions will lead to de-professionalization of education in these crucial subjects.
3. The draft Policy remains completely oblivious of the need to ensure adequate facilities in every school. This becomes clear in its recommendation that “All schools will be provided with adequate physical infrastructure, facilities and learning resources, either individually or within their school complex” (emphasis supplied) (P5.2.1).
4. The nature of remedial instruction (P5.2.4.) must be specific and different from the usual classroom instruction. Several remedial programs in schools conducted so far have failed owing to their failure to comprehend the specifics of a good remedial program. Volunteer-driven remedial instruction is not the solution to the severe learning crisis faced by students in our country.
5. Tenure track system of hiring teachers (P5.4.1.) must be discouraged completely. It is highly stressful and extremely complicated, destabilizes teaching profession and consequently affects the imparting of quality education in schools. Such suggestion also implicitly places the blame of deteriorating quality of education on teachers, while recent research evidence shows it is mainly the lack of infrastructure and amenities that have adversely impacted the motivation of teaching staff and the quality of education system.
6. The draft Policy suggests sub-standard B.Ed. colleges to be shut down with priority (P5.5.4). Building of high-quality, university-based government teacher training colleges must be made the topmost priority. Appropriate teacher education faculty must be hired in adequate numbers. The Policy fails to give any significance to this aspect. Existing documents on the regulation of B.Ed. colleges such as NCTE Regulations of 2014 are not mentioned in the draft Policy. Online, self-directed teacher training courses should not be prioritized, and this can never replace quality full-time teacher training.

Chapter 6

 Equitable and Inclusive Education

1. The terminologies used for constitutionally recognized disadvantaged groups such as the Scheduled Castes, Scheduled Tribes, and socially and educationally backward classes of citizens, have been largely avoided and replaced with a term underrepresented groups. This is likely to affect the rights and entitlements of these groups.
2. Zoning of schools (P6.1.2) has had negative consequences in the past and needs to be studied thoroughly before recommending it as a policy solution.
3. The suggestion of hiring local teachers who are well-versed in children’s languages is a welcome one and needs to be implemented properly.
4. Issues of minority language speaking and migrant population need to be studied thoroughly to include them and their languages in mainstream schooling.

Chapter 7

Efficient Resourcing and Effective Governance through School Complexes

1. The concept of public school complexes (P7.1.1.), in the name of economic efficiency, goes against the basic commitment of the state to provide equitable education to all children. This negates the concept of the common school system. Closure of individual schools that are not “viable in size” looks at education from the point of view of financial viability for state and not as a right of children. Accessibility of the poorest and marginalized sections to quality education is bound to get affected by this suggestion. Closure of government schools is already undertaken in full swing in many states and this has only worked for the benefit of private schools.
2. The draft Policy exhibits complete apathy to the basic right of children to quality education when it recommends that the secondary school may have a good laboratory, library, musical instrument and playgrounds with sports equipment and students from other schools in the complex may be given access to them (P7.2.1.). This will prevent children in certain schools from obtaining holistic education and puts them at the mercy of other schools within the complex. Children going to public schools come from the poorest sections of the society. Their educational needs are totally neglected, to make space for the privatization of education. Building of new school infrastructure will receive less priority as compared to shutting down of small and ‘unsustainable’ schools. Ironically, during elections every measure is taken to reach even the remotest locations to obtain one vote; but for closing schools, it is the numbers that count and not the basic rights of people.
3. Recommendation to share teachers in the school complex (P7.2.2.) will aggravate the issues facing the public education system today. It is unfortunate that the draft Policy assumes certain areas such as language, sports, and arts and music do not require a teacher for every school by nature of the curriculum. Despite research evidence that Pupil-Teacher Ratio for English language teachers is extremely poor in many parts of the country, the draft Policy suggests sharing of language teachers in the school complexes. These recommendations will add to the burden of the existing teachers and affect the quality of teaching in these subjects. Such stances in the Policy also question its commitment to holistic quality education for all.
4. The draft Policy’s commitment towards providing counselors to school complexes is similarly dubious. The document fails to recognize the importance of professional counselors when it relaxes the qualification required for counselors in schools and says that some teachers or social workers will be trained to give counseling considering the practical realities (P7.2.4.).
5. There already exists a hierarchy between the primary and secondary schools in terms of focus given to teaching-learning at these stages, the number of teachers allocated for these grades, and the status of teaching at these levels. By allocating resources to the secondary schools and making the secondary school headmaster the head of the school complex (P7.1.3.), this divide is likely to grow further.
6. The solution of providing safe transport facilities (P7.5.1.) after organizing schools into school complexes is likely to cause more drop outs, especially of girls even at the primary stage.
7. A significant power differential exists between parents and teachers of the school. Wide powers are given to School Management Committees (SMCs), including performance management of teachers and head teachers and endorsement of their evaluation and assessment (P7.7.3.). Considering the hierarchical relations characterizing the Indian society, SMCs in school complexes may not be adequately constituted and informed to perform these extensive functions.

Chapter 8

Regulation and Accreditation of School Education

1. Delineating responsibilities of accreditation, regulation, standard-setting and funding to different bodies is a welcome move to avoid conflicts of interests. However, the fact that all these bodies need to report to a centralized body of Rashtriya Shiksha Aayog (RSA) is extremely worrisome for the resulting concentration of power. Government should have adequate mechanisms and legislations to minimize conflicts between the bodies. Responsibilities must be clearly chalked out and redistribution of human resources within these organizations must be made carefully.
2. The draft Policy denounces the current inspectorial approach while making recommendation for the State School Regulatory Authority. It also hopes that putting all relevant information of the school in public domain will help parents make informed choices and make them de facto regulators (P8.1.1.). However, it misses the crucial point that mere availability of such information will not be sufficient to make informed choices, given the lack of understanding of holistic quality education among parents. Often, future aspiration of gaining successful employment is the key factor driving parents’ choices and they remain ignorant of scientific approaches to education. Moreover, not all parents are in a position to access such information owing to their socio- economic vulnerabilities.
3. Rajya Shiksha Ayog is mentioned in the draft extremely briefly (just once) (P8.1.3.) and therefore, the state-level structure of coordination is extremely unclear. State-level bodies must be strengthened in order to maintain the essential federal structure of governance of the country and the constitutional commitment to education as a concurrent subject.
4. Cancelling the RTE Section 12(1) (c) mandate and leaving it to the school’s volition to ensure diversity on private schools is reflective of the Policy’s lack of comprehension of on-ground realities. Draft NEP trusts the private institutions to “do the right thing” and places undue emphasis on the autonomy of education; however, this comes at the cost of ensuring quality education for all. It blames Section 12(1) (c) for increased corruption in the education system, though there is evidence that it has been implemented to a fair amount of success in states like Delhi. Without doubt, the issues in implementation of this provision need to be studied sincerely, and appropriate measures need to be taken for integration, scientific remedial instruction as well as sensitization of school staff. Scrapping the provision in haste will instead adversely impact the need for ensuring equity in education.
5. The recommendation to allow flexibility to schools in making decisions on inputs-physical and infrastructural- based on their local needs and constraints (P8.4.2.), is feared to allow mushrooming of sub-standard private schools, especially given the fact that most of them already run in violation of the prescribed mandatory norms.
6. The recommendation for adding educational outcomes in RTE Act will shift the focus away from providing contextualized experiences to children to that of setting pre-defined competencies which are to be achieved by them at each year of age. Such constrained understanding of education can also be found in its recommendation for Census examinations to assess schools.

Part II – Higher Education

Chapter 9

Quality Universities and Colleges: a New and Forward Looking Vision for India’s Higher Education System

1. The draft Policy aims to phase out all single-stream HEIs and build a higher education system consisting of large, multidisciplinary universities and colleges on the lines of Nalanda and Takshila (P9.1.). Though the idea of multidisciplinary HEIs is commendable, the Policy’s prescription for operationalizing this is deficient. The vast number of single-stream HEIs spread across the country has to an extent provided access to higher education. Given the fact that existing premier HEIs are already facing drastic fund and resource cuts, it is not clear how world-class HEIs (the Policy prescribes at least one such large high-quality multidisciplinary HEI in each district) catering to a large population of prospective students can be built. With its thrust for encouraging and empowering private HEIs, the draft Policy prescriptions will lead to increased privatization of HEIs, commodification of higher education and denial of higher education to a large section of students, especially those from socially and economically weaker backgrounds.
2. Autonomy to faculty in terms of pedagogy and curriculum development (P9.3.) is indeed an excellent thought. However, faculty and institutional autonomy only flourish and meet the desired objectives provided the faculty comes with a matured understanding of critical pedagogy. If not, it can instead lead to a very regressive system of affairs. A critical evaluation of these aspects needs to be taken into account before proposing autonomy. Rather than granting immediate autonomy, steps should be taken to improve the quality and critical pedagogical skills of the faculty. Autonomy to private HEIs to ‘strive for excellence’ may lead to commodification of education and violation of the basic right to education.
3. While it is laudable that the draft Policy recommends improving the quality of Open and Distance Learning (ODL) programmes, its stress on ODL to expand the reach of higher education and improve accessibility (P9.4.) should not come at the cost of physical, economic and social access to quality HEIs for students. This should be clearly mentioned in the Policy.
4. There is no mention of constitutionally guaranteed reservations in the provisions on faculty recruitment (P9.5.). Recruitment and promotion solely on the basis of merit will lead to dilution of the existing constitutional guarantees and reservation policies.
5. The draft Policy recommends creating competitive funding from National Research Foundation (NRF) based on the social relevance and usefulness of the research proposal (P9.6). The idea of social relevance and usefulness is extremely subjective and consequently, the decision of funding can become skewed depending on the interests of the funding agency. When funds are sought from private players, the funding would entirely depend on the stake that the private player has on the research proposals. In a market-driven economy, the stake of the private player on a particular proposal would be determined by its market demand. In short, the draft Policy aims to open up market-driven research which will effectively lead to prioritization of certain research areas, thereby adversely impacting research aimed at the benefit of society at large, in particular the weaker sections.
6. Reservation policies are completely ignored in the appointments of Board of Governors, Vice-Chancellor/Director/Chief Executive of HEIs, when the Policy prescribes “clear merit-based procedures” for these appointments (P9.7.).
7. The draft document says that regulations would be “light, but tight” (P9.8). This is feared to further deteriorate the quality of higher education, which is already populated by unregulated and under-regulated multiple players with varied motives in higher education.

Chapter 10

Institutional Restructuring and Consolidation

1. The Policy recommendation to create a new institutional architecture for higher education by 2030 (P10.3.) is feared to destabilize the entire higher education system. While building multi-disciplinary HEIs is a requirement, the categorization and operational mechanism fall short of appreciating the on-ground realities. The categorization between research universities, teaching universities and colleges furthers the existing fragmentation of research and teaching. At present, many premier HEIs concentrating on undergraduate education suffer from lack of faculties who have solid research experience. The Policy’s suggestion that faculties of Type 3 HEIs- Colleges, which are thought as exclusively high-quality teaching institutions, “…will be encouraged to apply for research funding and conduct, and be able to give senior undergraduate students a flavour of research” is grossly inadequate to capture the essentiality of good research for improving the quality of teaching.
2. Public HEIs in the country have proven to be far superior in quality and accessibility than their private counterparts. Still, a pervasive trend in the draft Policy is its thrust for privatization of education. Draft NEP places equal emphasis towards encouragement and empowerment of private HEIs by the government, as explicitly found in its statement, “…government will treat them on par with public institutions, and empower them equally”) (P10.10.). This undoubtedly reflects a waning commitment to the vision of education as a public good. Treating both the institutions at par for empowerment is a key recipe for commodification and commercialization of education.
3. The draft Policy’s emphasis on ODL programmes should not in any way lead to a mechanism for compensating the lack of accessibility to HEIs (P10.11). ODLs can never replace the significance of on-campus learning. This needs to be clearly specified in the Policy.
4. While on the one hand, the draft Policy aims at building high-quality multi-disciplinary universities, on the other it allows autonomous colleges to grant degrees (P10.13.). At present, there exists at least some amount of quality check mechanism with universities alone having the degree-granting powers. The new recommendation will lead to the degeneration of higher education and the exploitation of the most vulnerable sections, especially in light of the information asymmetry characterizing higher education system in the country.

Chapter 11

Towards a More Liberal Education

1. While the draft Policy’s emphasis for liberal arts education is commendable, its operationalization is ridden with difficulties. It envisages providing a transformed liberal undergraduate education programme of four-year duration or redesigning the current three-year undergraduate programmes with the same objectives and principles. While the reading of the document indicates that the liberal arts education is aimed at an overhaul of the current education system and this is actually a philosophy that should inform higher education, at certain places it relegates liberal education to just another degree for undergraduate education. For instance, the Policy says “There shall be at least one high quality HEI offering the four-year undergraduate BLS programme in or near every district in the country” (P11.1.3).
2. Though it is essential to glean insights from good practices of other countries, the Policy should primarily respond to the situations, exigencies and issues facing the system in the country. In its rush to adopt foreign models of education, the draft Policy, many a time, adopts a simplistic approach and remains completely aloof of the problems facing higher education system in the country today. The suggestion to call masters and doctoral programmes as graduate programmes (11.2) is one such instance. Further, the Policy prescriptions on revamping the institutional structure of HEIs may actually lead to destabilizing the entire current public higher education system and work for the benefit of the private institutions that have the resources to swiftly adopt the Policy recommendations.

Chapter 12

Optimal Learning Environments and Support for Students

1. The draft Policy recommends leveraging ODL for enhancing access to higher education. It envisages a significant role for ODL in increasing GER to 50%, prescribes looping in the best faculty for ODL and also conducting certain programmes exclusively in the ODL mode (12.3). It also recommends allowing students to take part of their total requirement in a particular semester through ODL, especially the subjects that are not yet represented at HEIs. While ODL can enable continuous professional development and enhancing of skills, the Policy recommendations imbibe an ongoing trend of replacing in-class learning with ODL. Knowledge construction is not confined to the interaction between teacher and student. In-class learning provides an ecosystem where teachers and students collectively participate in the construction of knowledge. Moreover, maintaining quality of education through ODL is a daunting task and this may actually lead to aggravating the inequities in the higher education system. The Policy should have clear prescription against replacing in-class teaching with ODL.
2. Giving complete autonomy to institutions and faculty (P12.1.1) on curriculum, pedagogy and assessment, even before them becoming capable of effectively putting into use such autonomy, might aggravate the disparities in the quality of higher education system. As suggested above, it is essential to improve the quality of faculty and institutional mechanisms in HEIs before granting them autonomy. Moreover, there should be strict prescriptions against autonomy leading to commercialization of education and education becoming a commodity accessible to the privileged few.

Chapter 13

Energised, Engaged and Capable Faculty

1. Higher Education Institutions are given complete autonomy in recruiting the faculty of their choice (P13.1.4), deciding their confirmation and the compensation and promotional avenues (P13.1.6) available to them, and the number of faculty (P13.1.11). A tenure track system is proposed for the faculty. Deciding on the confirmation, including the process of confirmation, the probationary period, career progression, promotions and salary conditions (P13.1.10) is the responsibility of institutions. Leaving these crucial aspects to the discretion of the institution will affect the quality of faculty recruitment and also the stability of academic careers. Putting the criteria and process of selection in the public domain is not sufficient, especially as the draft Policy leaves recruitment to the “choice” of the institutions. This will affect faculty autonomy and may even lead to them becoming subservient to the institutions. Giving the institutions the choice to decide the number of faculty and also leaving the decisions on faculty recruitment and service conditions to their discretion will allow institutions to limit their faculty recruitments and force the existing faculty to work extra hours, even at no compensation for such extra work. All these will have ramifications on the quality of higher education. A liberal arts education is impossible when the faculty loses motivation to work.
2. The draft Policy gives a total miss to the constitutional guarantee of affirmative action in recruitments and promotions and merely says the recruitment criteria should include diversity among other aspects.

Chapter 14

National Research Foundation

1. The draft Policy recognizes that the lack of research culture, research capability and funding has contributed to the present crisis facing research and innovation in the country. The recommendation to set up a National Research Foundation (NRF) to catalyze and expand research and innovation is welcome. However, the composition and funding aspects of NRF need to be revised if they are to actually be of use in developing scholarship.
2. There is a danger of certain areas of study getting prioritized, especially as one-third of the fund for the NRF budget is to come from public and private enterprises and private organizations (P14.4.5). Potential for national benefit, funding offered and NRF’s expertise and previous engagement are the deciding factors for the Governing Bodies and Divisional Councils while choosing research requests from private and public enterprises. According to the draft Policy, such provision “will help enterprises and organizations identify academic groups in the country with the expertise they are looking for. They will also benefit from the peer-review process of NRF for allocation of projects to specific research groups, and be able to ensure that their research projects receive adequate oversight”. It is feared that such prominence accorded to accepting research funding from private organizations by the National Research Foundation will effectively lead to using the skills of the academia for the benefit of private interests.
3. Making RSA the appointing authority for Governing Body of NRF is problematic. RSA is the newly proposed apex body on education in the Policy. With Prime Minister and Union Minister for Education as the Chairperson and Vice Chairperson of this body and 50% of the membership coming from Chief Ministers and bureaucrats, research and scholarship will skew in favour of “national interest”.
4. Draft NEP totally ignores the research support required for scholars from the depressed communities and emphasizes merit as the sole criteria for selecting research proposals.

Chapter 15

Teacher Education

1. The draft Policy makes a strong recommendation to close down substandard and dysfunctional teacher education institutions (P15.1.1.), which is laudable. The recommendation to move teacher preparation programmes into multidisciplinary higher education institutions (P15.2.1.) is also welcome. As the Policy itself recognizes, this would require creation of substantial new teacher preparation capacity (P15.2.3). This thrust is however not followed strongly in the recommendations for strengthening the departments of education in Universities. It leaves the setting up of departments of education to “interested universities” depending on requirement of teachers and availability of faculty (P15.3.1.). As the shift in teacher education will require substantial building of capacity, leaving such decisions entirely to the discretion of universities is untenable.
2. The draft Policy advocates school teacher preparation to be multi-disciplinary and encourages entry of PhDs in education and related disciplines such as science education, mathematics education, child development, psychology, sociology, and so on to contribute as faculty of teacher education programmes. While the Policy recognizes that some of them may have expertise to teach, but would lack the experience of the practices of teacher preparation, it leaves it to the discretion of individual departments of education to design the induction programmes for these faculty (P15.4.1). Given the need for ensuring uniform quality in teacher education across the country and the disciplinary requirements of teacher education, it is suggested that there should be a curricular framework prepared by an apex body, perhaps National Council for Teacher Education, for all the departments of education to follow and such framework should also include details on duration and mode of such induction programmes.
3. While the draft Policy calls for substantial reform in the teacher education in the country, the suggested faculty profile in departments of education is inadequate to achieve this objective. It relaxes the requirements for faculty, by openly stating that “Not everyone would be required to have a PhD, but teaching experience and field research experience will be highly valued”. This in fact undermines the significance of strong research capacities in the faculty of teacher education. Another lapse in the Policy recommendation is that only 50% of faculty needs to have experience of research/working with children and teachers (P15.4.2.). Teacher education involves developing basic skill sets in teachers for equipping them to impart the subject knowledge to children in the most effective manner. For instance, teaching psychology or linguistics to future psychologists and linguists will be different from the way it is taught to future teachers. Such a relaxation in the faculty requirement will effectively reduce the rigour needed for developing quality teachers.

Chapter 16

Professional Education

1. The idea of vocational education adopted in the draft Policy needs a relook. The Policy recommendations on vocational education mirror the existing hierarchical relationship between professional and vocational education (P16.1.3. and P16.1.4.), and hence paves way for creating a cheap labour force in accordance with the market interests. According to the draft NEP, the vocational educational curriculum and prospective vocations are to be decided by various stake holders including the employers. It is feared that this will inevitably result in vocational education being tailored in such a way that it only imparts the minimum skills for a particular job as required by the employer.
2. The recommendation for a mandatory qualification of Master’s Degree in Teaching and Research (P16.4.1.) in addition to a mandatory degree in subject specialization for all aspiring teachers lacks clarity on purpose. A teacher is expected to have a deep understanding of the subject and the various possibilities that the subject offers in terms of meeting the societal needs. A Master’s degree essentially calls for developing research skills in that particular subject. Higher educational degrees further advance one’s research skill capabilities. This being the basic understanding of a Master’s degree, requirement of a separate Master’s degree in Research and Teaching is infructuous. Instead, what is required is the strengthening of research and teaching components in the Master’s level education. The current structure and curricular framework of the master’s degree in many courses do not have such a focus. For instance, the current 1-year LL.M. degree fails to provide a solid foundation for research and teaching in Law with, its short course duration and inadequate curricular framework.
3. Measures recommended for mitigating faculty shortage, such as sharing faculty, inviting rolling faculty from superannuated scientists/professors/ experts, provisioning teaching assistantships for doctoral students, inviting overseas researchers and making use of talent from private sector (P16.4.2), will only aggravate the current crisis of quality faculty. Such adhoc measures are widely undertaken by many higher education institutions today, resulting in a culture of adhocism in professional education. This can be stopped only if students are attracted to enter research and teaching in professional education, a culture for research and teaching is developed in professional education, students are properly trained and, there are proper recruitment policies in place to provide faculty fair and transparent entry to higher education institutions and also an assurance of fair pay, decent working conditions and opportunities for professional growth.
4. The Policy prescription that research will not be mandatory for all teachers in professional education (P16.4.3.) fails to recognize the importance of research in teaching. This failure is also reflected in its recommendation to divide higher education institutions to research universities, teaching universities and colleges.
5. Leaving the responsibilities of preparing curriculum and the improvement of academic performance through reforms in curriculum, teaching and preparation of teachers completely to HEIs, in the name of ‘autonomy’ (16.5), will lead to uneven quality in higher education. Higher education in country already suffers from the issues of quality and accessibility. Leaving such vital decisions to the HEIs will aggravate the disparities in education, with HEIs that are able to attract quality faculty providing exemplary higher education and becoming islands of excellence, while the majority of them continue to remain inferior in quality.
6. The draft Policy subverts the understanding of education as a public good, when it gives full liberty to educational institutions to impose fees for professional education in line with the “spirit of providing autonomy”. The Policy displays a lack of commitment towards ensuring quality higher education for all. Instead, it treats education as a charity, as seen from the prescription that “some degree of scholarship” should be provided for 50 percent qualifying for admission to HEI and a 20 percent should receive full scholarship. It is not clear how these ‘magical figures’ are arrived at. Quality higher education is already a distant dream for most of the young students in the country and with such recommendations inclusive and equitable education will become ever more elusive.
7. Agricultural Universities in the country have not been effective in providing the much required support for small and marginal farmers in the country. Despite this, the draft Policy provides lip-service to this aspect, including it as an extension/community service (P16.6.1. and P16.6.3.).
8. Legal research in the country remains highly inadequate. Very few students in the legal profession pursue careers in legal research. Much of the legal research is limited to the doctrinal work done by scholars for the sake of gaining requisite grades for promotion in their teaching careers. Even the pursuance of doctoral degrees in law is largely influenced by the formal requirements for teaching career. For the organic growth of law, evidence- based law-making needs to be encouraged. Empirical legal research needs to be supported. The Policy needs to recognize this and make recommendation for developing legal research in the country.
9. Legal profession is yet to recognize the indispensability of multi-disciplinarity in the study of law. Despite law being rooted in the socio-economic and political setting of the society, law is taught in a black-letter form devoid of the context in which law is made and operates. P16.7.1. while calling for the law curriculum to reflect socio-cultural contexts, fails to capture the essence that law in totality should be taught in context and not as a mere text. It is not sufficient to incorporate some element of history of legal thinking or principles of justice into legal study. Further, this provision roots for a study of legal systems even from mythology and curiously, the relevance of constitutional values is missing from this provision. This needs to be amended.
10. The draft Policy recommends a centralized exit examination for MBBS education (P16.8.3.). It is not understood why such an examination is proposed when there is no such common examination for other professional education degrees.
11. Making nurses compensate for non-availability of doctors (P16.8.4.) is not acceptable. It allows for continuation of status quo in the health system which is plagued by shortage of doctors. Allowing lateral entry of graduates from other medical disciplines to MBBS course should be supported by clear regulations. In the name of promoting pluralistic healthcare education and delivery, the quality standards of healthcare should not be downgraded in any manner. Given the information asymmetry characterizing health system in the country, such moves will impact the poorest sections of the society the most.

Chapter 17

Empowered Governance and Effective Leadership for Higher Education Institutions

1. The responsibilities of Board of Governors should state social justice as one of its responsibilities (P17.1. and P17.1.7.). At present, there is no mention of social justice and this will lead to non-compliance and dilution of public commitment of HEIs.
2. Composition of the Court (or Senate) as a mechanism for public accountability of HEIs do not account for student participation (P17.1.3.). Many universities and institutions have elected student representatives as members of the Court (Senate) and this system should be continued and extended to all HEIs.
3. Students and research scholars should be included in the composition of Academic Councils (AC) as they are the impacted by the decisions taken by ACs. The draft Policy has omitted students and research scholars in elaborating on the membership of ACs (P17.1.16.).
4. Autonomy of HEIs is not discussed with regard to compliance with Constitutional values. HEIs are given freedom to “decide the criteria and number for student admission” (P17.1.20.a.) and “Private HEIs will be free to set the fees for their programmes subject to discharge of social responsibility in the form of scholarships for 50% of students in all their programmes” (P17.1.20.c.). However, there is no mention of the responsibilities to be followed by HEIs while exercising autonomy. The Policy should spell out on how autonomy will be exercised in relation to Constitutional values.

Chapter 18

Transforming the Regulatory System

1. The regulatory system, termed as “light but tight,” does not account for a systematic review/regulatory process. It also states that only in relation to education outcomes will the regulatory framework conduct continuous assessments. Instead of this, there should be effective monitoring of HEIs in relation to good governance, financial probity and stability, and educational outcomes. Technology can be harnessed for this purpose. This is required to assess whether HEIs comply with the overall regulatory framework in a timely manner.
2. The draft Policy does not specify the path for accreditation of all HEIs by 2030 (P18.2.1.). Affiliating colleges and independent institutions are treated on par unfairly. There may be appropriate relaxations provided by extending the timeline for accreditation process for affiliating colleges (P18.5.2.).
3. Private accreditation institutions (AIs) will lead to a dilution of accreditation process. There will be serious conflict of interest issues if HEIs are allowed to set-up AIs and if licenses are provided to them (P18.2.4.). Therefore, the policy recommendation of setting up a network of AIs should be reviewed again and private HEIs should not be empowered to set up AIs.
4. The presentation of ‘graduate attributes’ under the functions of General Education Council (GEC) is not substantiated. The desired outcomes of good education are not completely in consonance with constitutional values (P18.3.2.). There should be a wider consultation on this before the ‘attributes’ are decided.
5. The existing mandate of UGC to ensure parity between staff among HEIs and to recommend a range of salaries is repealed with the introduction of Higher Education Grants Council (HEGC) (P18.4.1.). This mandate is also not transferred to the regulatory body. Without any regulatory mechanism, there will be disparity between employees in HEIs. This has to be brought under the regulatory body NHERA.
6. The design and architecture of the regulatory system (18.1.) do not give importance to regional specificities within a large country like India. States of India should be taken into confidence before a centralised regulatory mechanism is formed as the policy states that “the State Department of Education and SHEC will not have any regulatory role or administrative control over the HEIs.” (P18.4.2.).
7. The Policy should be more specific on how many ombudspersons will be set up to handle grievances (P18.4.2.). There should be ombudspersons in each State and their appointments shall be made in concurrence with States.
8. Private HEIs should be mandated to adhere to reservation guidelines in the interest of public spiritedness and inclusive policy (P18.6.1.). The extension of reservation to private HEIs does not subvert the guidelines for scholarships proposed in the policy.
9. The principles for good governance (P18.6.4.) should specify provisions against discrimination. At present, the independent decisions of board in setting cultural tone for the HEI can affect the marginalized and minority community (principle 6). The policy should also specify that the minutes and all the discussions regarding HEIs taken by Boards to be made public (principle 9).

Part III- Additional Key Focus Areas

Chapter 19

Technology in Education

1. The draft Policy recommends setting up an autonomous body, the National Educational Technology Forum (NETF), to provide a platform for free exchange of ideas on the use of technology to improve learning, assessment, planning, administration, and so on (P19.1.1.). NETF is presented in a very generic manner and the Policy displays a lack of clarity in defining its role and the scope of its functions for aiding education. Roles and responsibilities of NETF need to be clearly outlined.
2. NETF is envisioned to facilitate a regular inflow of authentic data from multiple sources (P19.1.2.). It is not clear as to what the data that is to be collected is and the mode of data collection. This can lead to the collection of private data by private players and infringement of right to privacy.
3. The Policy prescribes NETF to be supported initially with public funding; it can also receive funding from other sources such as memberships, and other neutral technology industry bodies such as NASSCOM among others (P19.1.3.). However, it remains silent on the composition of NETF and the power of its members. It is not clear if these private organizations can also become part of NETF. Without clarity on these crucial aspects, NETF can essentially lead to an autonomous organization represented by private stakeholders furthering their interests in technology, with full support of state and its resources.
4. Though the draft Policy requires teachers to be empowered through adequate training and support to lead the activities and initiatives related to the use of appropriate technologies in classrooms, and for all other uses of technology in educational institutions (P19.2.1.), there is no clear indication of the structure and content of the training that would be imparted to the teachers. Teachers should be involved in the planning stages of training rather than be mere consumers of the training. At the same time, the document should clearly indicate who should provide the training. This is important as encouraging private entities to be trainers will lead to furtherance of their interests.
5. As per P19.2.4, the first component forming an integral part of technology based interventions is hardware and the draft Policy recommends commodity hardware solutions such as cloud-based commercial infrastructure and personal computing devices for end users to be preferred. Owning hardware equipment involves a lot of cost and this will affect the economically marginalized sections. Unavailability of internet amongst 50% of the population makes the usage of cloud a distant dream. More practical methods need to be thought of to make technology accessible to all.
6. On the question of acquiring the rights to distribute the technology, the draft Policy prescribes that the government will pay for professionally developing and maintaining the software, and will also acquire the rights to distribute it to learners, teachers and institutions for free-and-unlimited offline usage. The Policy should rather be reframed in such a way that the government has the ownership of the technology. Distribution rights are an inherent feature of ownership and we would need an explicit clause when the government owns the software. The government should enforce releasing the software under a FOSS license so that many contributors across the country can also be a part and contribute to the technology developed by the country.
7. While the draft Policy calls for teacher preparation and continuous professional development using educational technology, it is not clear as to who the master trainers will be. The qualification and experience of master trainers and their trainers should be clearly provided.
8. There is an overemphasis on internet based learning and learning of computer languages. The thrust for pedagogical development using computer-aided technologies is missing. The document needs a rethinking on how technology can effectively aid in improving the quality of education. With the way technology is presently envisioned in the Policy, it would in effect lead to replacement of in-class mode of teaching by tutorial videos etc. and creating more disparities in education.
9. Policy assumes that availability of adequate number of access devices (rapidly becoming smart phones or iPads and equivalents) and controlled access (for safety purposes) to the Internet can empower teachers as well as students to make use of these resources and even contribute to creating more (19.4). At P19.4.1, it says “Given the diffusion of devices and their affordability, all students are likely to have access to connected personal computing devices by 2025”. It also recommends the school curriculum to promote digital literacy using personal devices and available digital infrastructure. Such assumptions are totally divorced from any understanding of ground realities. According to TRAI, the total numbers of internet subscribers in India is 571.95 million, which is less than 50% of the population.
10. Towards integrating educational technology in school curriculum, the draft Policy recommends that from age 6 onwards, computational thinking-“the thought processes involved in formulating problems and solutions in ways that computers can effectively execute” will be integrated into the school curriculum (P19.4.1.). Such an idea of computational thinking from age 6 onwards is completely unscientific and limiting the exploration capabilities of the child.
11. The recommendation for creating “IT Ambassador Fellowships” for students completing their senior secondary courses to provide support for maintaining and using the hardware and software of educational institutions (P19.4.5.) is yet another instance where prospective jobs are being clothed as a service. It is not understood why the educational institutions should not actually be employing people for these professional jobs, instead of extracting services in the nature of “rural service” and “military service” (as the Policy itself describes it).
12. The draft Policy requires all learners to have access to high quality educational content, copyright-free educational resources, teaching materials etc. and such materials are to be created, curated and available in online digital repository, such as National Digital Library or NROER. But then, the draft assumes maximum dissemination can happen with the charging of a nominal fee. This questions the Policy’s commitment to accessible and inclusive education. Ironically, this recommendation occurs in the very section on enhancing educational access.
13. The draft Policy requires validating employment records of teachers and credits earned by learners through an identification based on Aadhaar numbers. This should be omitted.
14. Draft NEP requires the National Repository of Educational Data to maintain all records related to institutions, teachers and students in digital form. P19.2.4 (c) mentioned that the ownership of the data remains with the individual, and P19.6.1 (d) required privacy has to be ensured. But, then the document mentions all this records are to be maintained in digital form. This undermines the significance of consent and violates privacy. The draft Policy also prescribes using such data for assessing learning outcomes and even predicting failures to meet outcomes. Such stress on educational outcomes is again divesting the education from being a ‘process oriented’ one and makes it a mechanical pursuit of goals. A further infringement of privacy lies in giving all stakeholders access to official institutional communication channels.
15. Considering AI as a disruptive technology (19.7.) should be withdrawn. The socio economic impact of AI should be well researched and measures should be taken to understand and develop AI technologies in a self-reliant manner which can help in overcoming the employment loss issues. Skilling and deskilling (P.19.7.3.) based on technology advancements in the global market is not a scientific approach. This would only result in production of cheap labour force for the growing AI market. Rather steps and policy directions should point towards developing indigenous research and technologies.

Part IV- Transforming Education

Chapter 23

Rashtriya Shiksha Aayog

1. The draft policy says RSA will have “a few Chief Ministers (CMs) of States, in rotation, as its members” (P23.5.). There is no reason provided for why all CMs cannot be members of such an apex body which is required to meet at least once a year (P23.3). Since this is an important body that oversees implementation of the new policy, membership of RSA should include all the CMs (including Union Territories).
2. The new structure proposed to assist RSA has many committees with overlapping functions. The Executive Council, RSA Advisory Council, and the Secretariat have mandates to function with different levels of education system to collect and analyse data related to education and to monitor the implementation of the new policy. The proposed new committees may be simplified to reduce overlapping functions.
3. The Joint Review and Monitoring Board (JRMB) will be tasked with reviewing “performance of the various schemes of both the Central and State governments” (P23.14). However, the composition of JRMB and what is meant by review of schemes of State Governments are not explicitly stated. This can lead to incursions into the federal rights of States. Therefore, the provision of reviewing State Government schemes should be avoided from the policy.
4. The role of States in the framework is not considered separately in the policy. The Rajya Siksha Aayog (RjSA or SEC) to be formed at the State level are to be set up to “facilitate better coordination with the Centre” (P23.19). The policy has not paid specific attention to States’ right. It should emphasise States’ autonomy and federal rights in having independent policies within the framework of Constitution.