We are herewith releasing the observations of the CPI(M) on Draft National Education Policy (DNEP) 2019 along with the covering letter of Sitaram Yechury, General Secretary of CPI(M) to Shri Ramesh Pokhriyal Nishank, Minister for Human Resource Development.


Text of CPI(M) General Secretary’s letter to Minister for Human Resource Development


Dear Shri Ramesh Pokhriyal Nishank ji,

The Communist Party of India (Marxist) has gone through the Draft National Education Policy in depth and is sending its observations for your consideration.

We strongly feel that while our observations have dealt with all aspects of the draft policy, Chapter 23 which deals with centralization of powers completely contravenes with the powers of the state governments and therefore, the constitutional scheme of Federalism and should be withdrawn forthwith.

The DNEP in the present form will ensure the centralization, commercialization and communalization of the Indian education system and structures. Instead of arriving at a balance between Quantity, Quality and Equity in the education system, this DNEP is promoting a more elitist and pro-corporate thrust.

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

Yours sincerely,


(Sitaram Yechury)

General Secretary, CPI(M)

Observations of the CPI(M) on

Draft National Education Policy (DNEP) 2019


I.            Preamble

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

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

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

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

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

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

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


II.         School Education

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

III.       Rashtriya Shiksha Aayog (Chapter 23)

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

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

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

IV. Higher Education

1.           DNEP envisages an Anti-Federal and Authoritarian structure of Governance. The DNEP differs from earlier policy in fundamental ways. While it acknowledges the need for substantial increase in public spending and coordinated efforts to increase the Gross Enrolment Ratio (GER) to 50% by 2035, it ignores the crises precipitated by successive governments who have chosen to commit to liberalise Higher Education as a tradable service to WTO-GATS and other multilateral trade treaties. The direct consequence of such actions has been seen in the decline of Higher Education as a public good, the arbitrary squeezes in funds meant for recruiting more teachers and staff, the reduction in amenities for students, freezes or reductions in research-funding (especially in the Sciences) and the overall decline in the career progression and service conditions of faculty across Higher Educational Institutions (HEIs). Public-funded HEIs have been subjected to a series of intrusions and unwarranted interference from the Union Government and UGC – chiefly in the form of the forced introduction of the Semester System, the Choice-based Credit System (CBCS) and the encroachments made by the Dept. of Expenditure, Ministry of Finance, on the financial autonomy of HEIs. None of these decisions have been reviewed or scrutinised objectively, despite glaring evidence that such top-down decisions have not been received well by teachers and students at large or have often led to questionable results in the quality of education imparted by the public-funded HEIs. Instead of addressing the crises, the DNEP has pushed for further centralisation in authority, brought the entire system under the command of the Prime Minister and the Union Cabinet (thus ignoring the fact that Education is retained in the Concurrent List of Governable Subjects, in the Constitution), further marginalisation of teachers from decision-making forums, elimination of democratic representation of teachers and karamcharis from statutory bodies and creation of managerial authority (Board of Governors) based on the corporate models prevalent in the private sector. The operative policy underlined in the DNEP encourages commercialisation and mechanical resource-efficiency at the cost of equity, social justice and academic rigour. This is at odds with the rhetorical claims of the DNEP.

2.           The DNEP does not comment on the internal democratic structures of HEIs. It is absolutely imperative to ensure this; but for which autonomy vested and concentrated with the administrative heads may degenerate into tyranny. The DNEP is silent on representation of teachers and students in institutional governance through fora like Senate, Academic Council etc. Equally, recognition of elected representative bodies like unions of teachers, students and non-teaching staff is an element of internal democracy within HEIs. This also does not find place in the DNEP.

3.           Uniform regulatory and outcomes parameters for both Private and Public HEIs stem from a fallacious notion that these two types of institutions have identical functions (Chapter 18). The DNEP ought to have acknowledged the fact that historically, public-funded HEIs have played a critical role in catering to unique local public needs, making Higher Education inclusive and democratising its processes of governance. While most public-funded HEIs have imparted a sustained quality of education and observed the minimum standards set and coordinated by the UGC, their approach to research and academic excellence has not replicated models prevailing in the advanced nations of the world. Moreover, such institutions have always had to stringently follow governmental diktats on resource-allocation, expenditure and accounting. Despite their consistency and commitment to education as a public good, these institutions have not responded well to the international ranking parameters as these parameters have tended to ignore the special emphasis on Equity and Access in the functioning of our public-funded HEIs and insist on homogenous standards of quality. The DNEP replicates this insensitivity in proposing the same regulatory principles for public as well as private institutions.

4.           No clarity on challenges facing Access, Equity and Social Justice in Higher Education. The DNEP observes that unevenness in access to Higher Education and inequitable conditions obtain from uneven regional development (Chapter 9). It hence proposes a focused drive to establish HEIs in backward and remote districts of India. However, uneven regional development is not the sole factor that determines lack of access and equity. Social divisions based on caste, gender, class, disability and religious identity are important determinants of Access too. The Draft NEP has chosen to skirt the surface as far as these divisions are concerned. In fact, it has maintained an unnerving and dishonest silence on how these divisions might impinge on the educational needs and prospects of those sections that are marginalised based on these divisions. Hence, there is no discussion or review in the accomplishments or challenges in implementing the Reservation Policy on admissions and appointments, enabling institutional processes, institutional interventions in discriminatory situations, institutional justice for students and teachers belonging to marginalised sections or the accommodation needs of students with disabilities. The DNEP is totally silent about the challenges faced by students with disabilities in accessing and pursuing higher education.

5.           Three-tier Institutional Setup ignores diversity of learning needs and local priorities, while also encouraging wastage of resources. While proposing an entirely top-down chain of authority and decision-making, the DNEP (Chapter 10) ignores the diversity and organic needs of institutions. It proposes three types of institutions – Multidisciplinary Research Universities (Type 1), Multidisciplinary Teaching Universities (Type 2), and Autonomous Multidisciplinary Colleges (Type 3). These have standardised and homogenous functions that are at cross purposes with many HEIs that have been founded on specific legislations in order to cater to unique regional and communitarian needs (for instance, Tribal universities, Agricultural universities etc.). Additionally, in recommending the closure of affiliating-type universities and affiliated colleges, the DNEP overlooks the positive potential in this type of institutions. Affiliating systems allow for pooling in of resources. Affiliated colleges and the affiliating university have a symbiotic relationship that is manifested in collaborative work on curricula-building, teaching and examinations. Delhi University is a prime and successful example of this. Pooling in of faculty and other resources helps prevent duplication of work and wastage of resources. Colleges also obtain strength from the value of the university, thus attracting academic talent and student-interest. Autonomous colleges do not enjoy such benefits and most of them (except those that already enjoy a high-brand value) will be forced to start from scratch if they are expected to establish a prestigious academic reputation in the due course of time. They will be forced to replicate already existing resources.

6.           Autonomy remains hostage to paradoxical and contentious formulations. The Draft NEP does acknowledge that innovation and creativity in the education system have been stifled by the lack of academic autonomy. However, in proposing solutions, it renders academic autonomy of teachers and researchers subservient to a heavily bureaucratised apparatus of institutional Boards of Governors (BOGs) and Institutional Leaders (who are to be specially developed for Executive and Administrative purposes over time). Autonomy of teachers is further hit by the absence of any democratically elected representation of the academic community in the decision-making chain. Teachers presently elect their representatives to the academic and executive councils/senates of universities. These elected members represent the collective concerns of the academic community. The proposal to do away with democratic composition is not only at variance with the larger democratic principle of authority in public institutions, but also weakens the voice of the academic community in considerable ways.

7.           Confusions in the Liberal Arts Approach and Lack of Feasibility of Four-year Degree Programmes (Chapter 11): The Liberal Arts approach expects students to develop a multi-disciplinary and composite perspective on issues and chart their own course of study. However, in order to be practicable, the Liberal Arts approach requires an academic and cultural environment that completely absorbs students and rigorously engages them to their fullest potential. It may be a successful model in many fully residential universities that are well endowed with resources to cater to all practical needs of students and teachers. Unfortunately, the practical scenario in most Indian universities and colleges is different. A few exceptions apart, the general lack of hostels and proper mess facilities, considerable distances between students’ homes and campuses and inadequacy of learning infrastructure impedes the complete absorption of students into rigorous academic programmes. The existing Choice-based Credit System in undergraduate education has already extended the daily timetable for students across colleges and universities. Too many class hours comprising Core, Electives and Skill-based Courses have created long timetables that do not allow students recreational time or opportunity to apply themselves in Remedial Learning. Students who are forced to travel long distances between their residence and campus are facing practical challenges in coping with the rigours of the CBCS. The Liberal Arts programme will only compound their problems.

The Liberal Arts programme proposed in the Draft NEP packs in too much. It combines academic disciplines with vocational education and does not insist on a student’s core competence in any discipline/subject of study. The eclecticism it promotes is not only impractical, but also potentially confronts the students with a bewildering array of academic and vocational choices that are bound to confuse the students, unless they are individually and adequately mentored or enabled to make informed choices. The combination of academic and vocational subjects is a unique but unconvincing feature of the Liberal Arts model proposed in the Draft NEP; it runs the danger of diluting the focus of undergraduate education and leaving students with half-baked ideas that may cripple the imagination instead of empowering it.

In order to be fully implementable, the Liberal Arts approach requires the extension of the existing three-years degree programme in the Arts and Sciences to a fourth year. The additional year, despite exit points provided at the end of the third years, will impose additional financial burden on students. Students from the marginalised sections, especially women and the poor may be discouraged to continue up to the fourth year. Moreover, a four-year Bachelor in Liberal Arts/ Liberal Education (BLA/BLE) will automatically devalue the existing B.A. and B.Sc. degrees. These problems came into light in the Four-year Undergraduate Programme that had been hastily started in Delhi University and had to be rolled back within the span of two years, due to growing public dissatisfaction and the collective pressure of students, parents and teachers.

The Liberal Arts model is entirely choice-based. Hence, it will create problems in the optimal utilisation of resources, result in fluctuating subject workloads and create problems in determining teaching posts.

Undergraduate research projects (as has been proposed as a possible fourth-year engagement for students) are valuable in themselves but cannot be expected to adequately prepare students to undertake Doctoral research. In four years of undergraduate study, students cannot be expected to develop the maturity and academic expertise required to embark on original research, exceptional cases notwithstanding. Hence, the proposal to grant eligibility for admission to Ph.D. to a Liberal Arts graduate with research credits is fanciful and fraught with dangerous consequences.


Inadequate understanding of the practical implications of the Liberal Arts approach has led to the proposal for an over-ambitious and impractical programme that will promote inequity. Hence, the approach to Undergraduate Education in the Arts and Sciences requires considerably wider consultations and more awareness of ground realities.


8.           DNEP fallaciously advocates over-reliance on ICT and Digital Online Learning. There is thin evidence to suggest that digital communication and online courses can serve as a viable alternative to classroom-based teaching learning. Digital technology and interactive multimedia have thrown up many interesting possibilities but there is no substitute for contact mentoring and guidance that students need. The spontaneous and collective energy of a classroom is also completely missing in online courses and cannot be simulated. Laboratory practical experiments have complex dimensions that cannot be simulated on virtual platforms. While digital technology can certainly complement regular classroom and laboratory-based work, it cannot replace the wholesome atmosphere of learning in the classroom. American universities have, in recent times, seen considerable attrition in online courses. Hence, the DNEP’s emphases on ODL and Massive Open Online Courses (MOOC) (Chapter 12.3) are misplaced. Basing expansion plans on the increased and extensive use of ICT and e-learning platforms is, at best, naïve; the claims made by the Draft NEP are empirically unsupported and seem like a desperate ploy to match the need to achieve an ambitious GER target with the grossly insufficient resources that governments have been willing to commit to such expansion.


9.           DNEP recommendations on Recruitment and Service Conditions of faculty and non-teaching employees will have a disastrous impact on talent and morale. The Draft NEP does not address the long-standing concerns and insecurities of people employed in HEIs. Short-term contractual employment, arbitrary freezes in permanent recruitment, cuts in pensions and other post-retirement benefits, the withdrawal of time-bound career progression schemes, quantified productivity like API, and the marginalisation of teachers from academic decision-making have combined to make academics an unattractive profession. Teachers need attractive pay; but they also need job-security and decision-making agency in order to commit themselves fully to the institutions that employ them. Increasing corporatisation of governance, the decline in collective grievance redressal mechanisms and the lack of academic democratisation have contributed to brain drain in the academia. Internationally renowned universities in the UK, Europe and China have retained permanent recruitment of teachers and assured pensions as a routine feature of their education system. India is following the American model wherein the largest section of young teachers is employed in adjunct capacity. They lead precarious lives and are subjected to alienating service conditions that push the rate of attrition high in the teaching profession. The Draft NEP replicates this corporate, adversarial model that is unsuitable to India’s present needs.


The Draft NEP allows institutional BOGs complete freedom in determining variable pay and service conditions for teachers, provided BOGs show a consistent inclination towards keeping recurring costs down. The lack of standardisation of pay and service conditions, especially in public funded HEIs, is unacceptable on several grounds. If authorities are given complete control over teachers’ pay and service conditions, institutions are bound to undermine the intellectual autonomy of teachers, penalise dissent and encourage conformism. This will have a negative impact on the confidence of teachers and suppress the creativity and intellectual fearlessness that is central to the success of academic initiatives. It will also negatively impact the collective and collegial spirit of education.


Career advancement based solely on the notion of merit undervalues experience and is demoralising for the academic community. Teachers often require time off to explore new areas of enquiry and research; academics is a complex process that cannot be measured in terms of consistent productive outcomes. A system of time-bound, assured promotions based on seniority is more conducive to teachers and non-teaching employees. Hence, time-bound promotions should be allowed to continue. The notion of pure merit is also subjective in the Indian context where deep social prejudices prevail and often influence peer and student perception against teachers from the socially marginalised sections and castes. The Draft NEP ignores the social fault lines that may impinge on the objectivity of appraisals and hamper career-progression for large sections of teachers.


10.        Research Undermined. The National Research Foundation (NRF) is another centralised, top-down model of administering research initiative in Higher Education that is fraught with many ills. The NRF is conceived as a national apex body directly under the RSA (Chapter 14), invested with the authority to decide on research priorities and allocate funding to projects through its Divisional Councils and empowered Subject Committees. This centralised hierarchy undermines the autonomy of HEIs in determining their own research priorities, building unique capacities and identifying research potential. The NRF is anti-federal too, as it does not allow diverse state-level research initiatives to emerge organically from different regional circumstances. The NRF is potentially open to political and ideological policing as well. Its Divisional Councils and Subject Committees are authorised to scrutinise and approve every research proposal. Since these bodies have a fixed composition for two years, institutions and individuals can feel encouraged to lobby with them for approval. Presently, research councils and departmental research committees have membership by rotation; as a result, there is some desirable confidentiality in the process of review and approval. A fixed composition for Divisional Councils and Subject Committees may promote prejudice and corruption in the form of favouritism.


The NRF is mandated to synergise the research potential in HEIs with the R&D requirements of Industry and commercial businesses. In this way, it is bound to prioritise commercially attractive research proposals over socially valuable or critically inclined research. Moreover, its centralised and impersonal character may undermine the value of personalised supervision and goal setting in research. It will pave the way for a mechanical and dry kind of efficiency that reduces research to professional productivity at the expense of individual quest for knowledge.


11.         Outcomes-based Model is Illiberal and ignores the need to regulate Inputs. The Outcomes-based Model seems guided by the desire to impose a mechanical efficiency of resource utilisation on institutions. The DNEP uncritically promotes it as an overarching philosophy of institutional regulation and governance. This model negates the importance and role of educational institutions in securing justice for their students and employees, in their affirmative potential for positive discrimination in favour of the marginalised and disempowered. It narrowly quantifies productivity and sets measurable parameters of accomplishment that are expected to be reflected in the Institutional Development Plans (IDPs). These IDPs become the basis for funding and decision-making autonomy. The Outcomes-based Model also ignores the need to insist on minimum inputs that institutions need to invest in to offer an adequate and just academic and cultural environment to students and employees. It is a model that homogenises the direction of growth for HEIs and adopts an insensitive attitude towards differences and the diversity of needs. It lends itself to illiberal and one-size-fits-all solutions to problems and challenges – a model that is unsuitable for sustaining the social value of education in the long run.


12.        DNEP Perpetuates Gender Discrimination: Conspicuous by its absence in the DNEP are gender-related themes and provisions across curriculum and the failure to recognise gender as a cross-cutting concept. The policy fails to recognize that gender is not just a women and girls’ issue, it also pertains to boys, men, and the LGBT community and the inherent discrimination both in policy and implementation. That there is gap between genders and the low numbers of women in Science, Technology, Engineering and Mathematics research and higher education is also not noted in the policy.


13.        Post the NALSA judgment the DNEP 2019 does not recognise the need to take measures to ensure a conducive atmosphere in schools for children who may not identify with the gender assigned at birth.


V. Conclusion


The DNEP is tilted towards structural transformations rather than an honest assessment of the potential of the existing system, or the need to repair it and eliminate its inadequacies. This is made clear by its refusal to engage with the vision and proposals outlined in earlier landmark documents related to India’s Education Policy – chiefly, the Radhakrishnan Committee Report (1948), Mudaliar Committee report on technical education and the Kothari Commission Report (1966) – that had clearly outlined the public value and purpose of Education in independent India’s nascent stages of development. The DNEP’s discontinuous engagement with evolving challenges in the field of Education is marked by a singular disdain of democratic principles, federal governance and public trust. It ignores the balance of power in the Indian Constitution and gives all decision-making powers to the Executive, leaving nothing for the Parliament and state legislatures that have hitherto been actively involved in creating many institutions and resources that cater to the people’s educational needs. The Global Market’s consumerism looms large in the backdrop of the DNEP which sets out to align India’s Education Policy with the needs of private investment. The DNEP fails to come good with the slogan “Sabka Saath, Sabka Vikaas”, not to speak of the additional “Sabka Viswas”. The Drafting Committee has apparently consulted a wide range of experts but is guilty of ignoring collective aspirations represented by democratically elected bodies of teachers and students at all levels. The outcome is derivative and oblivious to many genuine challenges that need to be overcome in order to ensure a fair and confident participation of the India’s young population in its educational programme. We reject the DNEP in its present form and urge the Government of India to authorise wider consultations with heterogeneous sections of civil society and polity for inputs towards a credible and justifiable exercise in redrafting the NEP Document.  Such a document should be made available in all languages recognised under the 8th Schedule of the Indian Constitution as also in accessible formats.