Tuesday, 2 July 2019

Chander Bharti

23-06-2019
Draft NEP 2019 –Comments (School Education)
1. The National Govt. already been published a Draft National Education Policy (Draft
NEP) and have given time till June 30th for comments. The published draft document is
available only in English and Hindi. India is a country where linguistic diversity is the
reality and we are bound to uphold that reality that is why the country had included 22
languages in the 8th schedule. Majority of the people in the country who could not
understand either English or Hindi has the right to express their views, observations and
suggestions regarding such an important subject like education. Hence we demand the
national govt. should translate the document in all the languages placed in 8th schedule
and circulate it immediately.
2. The time provided for studying and commenting on the 484 pages draft loaded with
policies and action points, is not sufficient. This makes meaningful discussions on the
draft impossible. So we again demand the draft is to be published in all scheduled
languages ensuring enough time for reading the document, analysing it critically and
for providing healthy recommendations. Hence we demand the time limit for expressing
opinions on the draft of the New National Policy of Education, published by the
government should be extended.
3. Every Education policy is a political document on education. Such a document should
reflect a clear vision on the future of the nation that goes in tandem with the articles and
principles set out by the constitution of India. The draft should categorically state the
changes and modifications to be made on the existing policies and practices, in order to
materialise the new educational perspective. And the government should clearly
propose an action plan to materialise the policy visions. For this, various educational
policies and plans of the past such as the policies of 1968, 1986/ 1992 are to be reviewed
in detail and the success and failures of these policies are to be assessed. Had it been
done, the document would have given a clear picture on the reasons and contexts that
failed us in achieving the goals. In addition, it would have given many an instance of
breach of promises and negligence committed by the State and authorities. So far as a
70 years old democracy like India is concerned, it is quite serious on one side and
shameful on other side to have 30 crores of illiterates. It is also very serious that more
than 6 crores of out of school children even 10 years after the implementation of the
Right to Education Act. Many nations such as China that achieved freedom years after
Indian independence have successfully eradicated illiteracy and universalised
education. In this context, it is essential that the policy document should analyse the
factors that caused such a deficiency and recommend solutions for overcoming such a
setback.
4. Education policy should aim at developing a society that imbibes the principles upheld
by the Constitution of India. Hence education should foster qualities envision and as

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stated in the Preamble, of socialism, secularism, social justice and democracy. These
should be the guiding principles in formulation of curriculum, pedagogy and
educational administration. All learners should be provided with equal opportunities
for constructing knowledge, developing their aptitudes and skills. Unfortunately the
policy document keeps blind regarding these values and tasks. At the same time the
document views the learner as a consumer in the education market and defines
education as a process of satisfying his/ her intentions and making him/her happy.
This document discards the learner’s innate nature of questioning and enquiry and
stresses activities for developing ethical and moral qualities. It says no to all forms of
thoughts and actions that disturb “other people” and preaches the lessons of tolerance
and submission.
5. Though the policy document highlights many latest educational perspectives, it keeps
silence on the practical implications and miserably fails to propose an action plan
regarding that. Moreover the document contains many proposals that contradict those
modern academic perspectives. For example, the document defines education as a
process of developing scientific temper, aesthetics, critical thinking, communication
ability, ethics, digital literacy, knowledge about India and awareness about the
problems that India and the rest of the world face. Scientific temper is developed
through the process which encourages the learner to question and to enquire. This
develops the learner’s spirit of probing or investigating. But clauses 4.6.8 and 4.6.9
under Ethical and Moral Reasoning, the document says learners are to be taught about
the importance of ‘what is right and what is wrong’. The document cautions that such
actions should always be scrutinised for not disturbing or worrying others. Here comes
the question, who determines ‘the right and wrong’ in a world order having discrimination
and inequalities, is quite clear. The document further says that moral and ethical
reasoning are determined by traditional Indian values of seva, ahimsa, swacchata, satya,
nishkama karma, tolerance, honesty, hard work, respect for women, respect for elders,
respect for all people and their inherent capabilities regardless of background and
respect for environment, etc. On one hand the document speaks about the importance
of being aware of issues and challenges that India and the world face and on the other
hand it prescribes the so called Indian legacy for compromising with the existing social
contexts of inequality and discrimination. In short, the new policy document envisions
the development of a future society that never questions and never defies the tendencies
of which causes inequality and discrimination and also addressing the huge gaps
between haves and have-nots. That itself is against the spirit of our constitution.
6. The Draft NEP 2019 speaks about the development of the values of the constitution
(4.6.8.3). But it has skipped secularism from the list of constitutional values. It seems
that a deliberate attempt has been made not to use words like ‘secularism’ and
‘socialism’ in the document.

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7. The whole document curtailed the Childs Right to Education. It seems the most brazen
attack is on the Right to Education Act, which while being proposed to be extended
has been hugely curtailed with. Its most basic requirements like the quality of
provision, qualification of teachers, and so on will be removed, “to allow alternative
models of education such as gurukulas, paathshaalas, madrasas, and home schooling” (p.
71,Chapter 2 – 3.12) to flourish. A ‘flexible’ market model with minimal regulations, to
give “greater flexibility (and) create greater educational choices for students and
healthy competition among schools”, is sought to transform the nature of school
education. The euphemism of multiple ‘alternate models’, helps to also include the
huge industry of low-cost private schools, ‘philanthropic-public partnership’ schools,
religious schools, and the largest network of Rashtriya Swayamsevak Sangh schools,
including its single-teacher Ekal Vidyalayas in predominantly tribal regions, for
which “multiple pathways to learning” through non-formal methods, technologies
and National Institute of Open Schooling courses (equivalent to grades three, five and
eight) are being justified. These models are violative of the fundamental right of
children to good quality education in regular schools; removing Right to Education
regulations amounts to depriving the poor and disadvantaged of their most basic
entitlements. This will lead not only to total privatisation and corporatisation of the
school education structure but also the communal forces could make use of
communalising education.
8. The present reality is that Niti Aayog, is increasingly getting involved in education. It
has in fact taken a few states and has been asking for school mergers and closures, which
even the education ministry has not done. Thousands of schools are being closed or
merged in different states. If this happens, how are we going to have a more equitable
public education system? This will also encourage a lot of low-cost private schools to
come up, which is a big market and is completely unregulated. These policies are also
being promoted by leading corporate organisations which are near to ‘the power centre’.
9. One of the basic features of this policy document is that instead of decentralised
administration, it directly and indirectly advocates for centralisation of powers. It scraps
many of the existing structures and proposes new Structures like Rashtreeya Siksha
Aayog, National Higher Education Qualification Framework, National Higher
Education Regulatory Authority, State school commission; State School Regulatory
Authority, etc. These shall be used for centralisation and will foster beurocratic
dominance and corruption. This will finally enable the State to have total control over
the whole process and system of education. This will ultimately damage all kind of
democratic functioning and diverse governance which is the strength and beauty of a
federal system. Chapter 23 of the draft NEP proposes and describes a new structure
namely Rashtreeya Siksha Ayog which eventually leads to a comprehensive
disempowerment of the Indian states in the sphere of education. With education in the
concurrent list, the present rights of the states under the Indian Constitution are

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eliminated and they are reduced to mere coordination with the Centre and implementation
of policies decided by the Centre. At the Centre, also, all effective powers are
concentrated in the hands of the five members RSAAC, with majority ensured to the
ruling party. The proposal for setting up of a structure like RSA which finally results in
over centralisation should be withdrawn.
10. The document comments on the development of critical thinking. Critical thinking
needs higher level of thought process which can be possible by analysing all kind of
dynamisms of the society or by getting opportunity to relate what the child learn in a
classroom to child’s surroundings. There child must get opportunity to raise questions.
Critical thinking will be attainable to all learners only when it is being operated and
processed by relating with the socio-cultural and political realities of the child’s
surroundings. By totally neglecting the need of socio- cultural and political association
of learning it is not possible to develop the ability to think critically. Questing and
enquiry are the basic features of critical thinking. But the document also demands the
promotion of moral and ethical reasoning which in turn discourage all kind of
inquisitiveness in the world of inequality to where the child belongs to. Hence the
intention of the document is clear by making the child not to disturb others interest in
the name of morality and ethics otherwise the concept behind ethical and moral thought
is not clear. It proposes values like Seva and Nishkaama karma. The democratic method
of taking logical decisions valuing the beliefs of all is not focussed here. The idea of
Secularism is not mentioned at all. The document never recognises education as a social
construct by maintaining a collaborative platform with a view that every child is a
citizen. The policy document should aim at the development of values for the
sustenance of a healthy democratic society as envisaged by our constitution.
11. The document places the need for academic enlightenment romantically. But when the
question comes regarding its implementation the non-commitment by the Central Govt.
is very evident. The document claims that it will be the policy for the next 20 years. It is
nonnegotiable that for addressing the quality issues the teacher’s presence is inevitable.
Even in this document the school will consider as a unit for teacher appointment. No
class/grade specific teachers are proposed in the document. It is very clear where the
commitment of the State is needed the State is consciously keeping blind. In chapter 2
the document put a passing regarding the teacher appointment that Teacher vacancies
will be filled as soon as possible (page 58). Without teachers how could we address quality
issues age appropriately and also addressing the development need of a child.
12. But unfortunately the State is reluctant to provide minimum support for the majority of
the students and proposes lesser input and demands more output. What kind of a magic
wand that the central govt is envisaging for quality up gradation. Each and every child
in the country is the right to get equal opportunity to learn. If we consider the facility of
the central school as a base it is the duty of the State to provide at least the facility of the

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central school to each and every student. Instead of meeting the commitment the Draft
NEP proposes through 3.12 of chapter 2 ‘the focus will be to have less emphasis on inputs
and greater emphasis on output potential with respect to desired learning outcome’. This clause
reveals the Central Govts position that it won’t invest money for the majority of the
children even not ready to take the responsibility of complying RTE. This position will
deny the right of the children to get access and quality education at least as per RTE
norms. This will increase inequality.
13. The objective of Draft NEP 2019 in the area of school education is defined as Achieve
access and participation in free and compulsory quality school education for all children in the
age group of 3-18 years by 2030. This is a major retreat from RTE 2009 read with NCF 2005. ‘Equality
of outcomes’ of NCF 2005 is replaced by mere ‘access and participation’ in Draft NEP 2019. A strong
aspect of the NCF 2005 is the linking of ‘quality education’ with ‘equality’. NCF 2005
defines quality education as that which delivers ‘equality of outcomes’, not just ‘equality
of access’. The most fundamental disadvantage of Draft NEP 2019 is the abandonment
of this perspective on quality for equality, which is, in fact, a central objective of the NCF
2005, which should continue. NCF 2005 on the issue of ‘what is quality education’
explains as the formal approach, of equality of treatment, in terms of equal access or equal
representation for girls, is inadequate. Today, there is a need to adopt a substantive approach,
towards equality of outcome, where diversity, difference and disadvantage are taken into
account. A critical function of education for equality is to enable all learners to claim their rights
as well as to contribute to society and the polity. We need to recognise that rights and choices in
themselves cannot be exercised until central human capabilities are fulfilled. Thus, in order to
make it possible for marginalised learners, and especially girls, to claim their rights as well as
play an active role in shaping collective life, education must empower them to overcome the
disadvantages of unequal socialization and enable them to develop their capabilities of becoming
autonomous and equal citizens.
14. NCF-2005 has two very significant things to say about the twin major concerns
expressed above. First, universalisation of education and second, quality in education are
not to be regarded as two ‘opposing’ needs. They are complementary and reinforce each
other. Quality cannot flourish for long in a society that is not based on equality and
justice for all. Likewise, universalisation can be an empty slogan unless quality is
assured for all. NCF-2005 interprets the quality dimension holistically, departing from
its narrow connotation of excellence in particular subject areas. NCF 2005 considered
‘quality’ is inclusive of universalisation. The document clearly explains that quality is a
systemic characteristic rather than only a feature of instruction or attainment. The
attempt to improve the quality of education will succeed only if it goes hand in hand
with steps to promote equality and social justice. Equality in education can be brought
by enabling all learners to claim their rights as well as to contribute to society and the
polity. Quality education should promote these social values necessary for a democratic
society such as ours. As is clear from the above , the crucial mandate of ‘Universalisation

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of education of good quality’, which is the substantive content of the RTE Act, is
truncated in Draft NEP 2019 to mere Universalization of ECCE. Except for one mention
of Universalization of ECCE, in the entire document, the word ‘universalization’ is
absent or consciously absconding. While adding ECCE and also secondary education
up to the age of 18 to the mandate of RTE is welcome, the price cannot be a withdrawal
and retreat from existing rights under RTE 2009 as explained in NCF 2005.
15. The document prescribes two ways for ensuring quality one is National Adult Tutor
Programme (NATP) and Remedial Instructional Aides Programme (RIAP) also
manifests this partiality. The draft policy makes mockery of the rights of
underrepresented groups through its National Tutor Programme (NTP) “where the best
performers in each school will be drawn in for up to five hours a week as tutors during the
school for fellow (generally younger) students who need help” (p. 60-Chapter 2-2.5). The
beneficiaries of these programmes are low achievers or under achievers. These learners
are to be taught not by untrained volunteers, but by qualified teachers having proper
training and maturity. They have to provide individualised attention to the learners.
Providing educational support to underachievers is higher level academic task. It can’t
be undertaken by a student or anybody who is not trained properly. The proposals for
remediation by unpaid volunteers, the service of ex-service men, locally available social
workers, women and qualified unemployed people are not acceptable because this
suggestion itself is counterproductive. Teachers having sufficient academic skill and
qualification have to be appointed for individualised instruction. In fact the proposal
will not help meaningful educational support and mainstreaming of those alienated in
the class rooms. This will enlarge the degree of inequality among student community.
Instead of enquiring why the learner failed in Maths or any other subject, we have to
examine the socio-political circumstances that led to that failure and formulate alternate
measures to help the learner. The draft NEP has failed to maintain such an approach.
It should also note that contrary to known theories of learning and experience in India,
it still advocates for ‘each-one-teach-one’, for schools and also for adult education.
16. The proposal for setting Remedial Instructional Aides Programme (RIAP) is also
questionable. It also results in poor students cheated of quality education. We believe
that it is based on a brazen agenda to short shrift the poor, who need nurturing
attention from qualified teachers, is the Remedial Instructional Aides Programme
(RIAP). The term ‘remedial’ is demeaning and demotivating, indicating a deficit or
illness in need of a remedy, and the Ministry of Human Resource Development had
stopped using it soon after enacting the Right to Education. Initially, RIAP has been
presented as a 10-year project to employ instructional aides — especially women from
socio-economically disadvantaged communities (who have completed the highest
grade in school available in their region) — to hold such classes during and after
school, and during the summer. The draft says ‘true local heroes’ will be trained to
teach foundational literacy and numeracy, to bring back students who might drop out,

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not attend, or never catch up. Glorifying deprofessionalisation in education is being
used by different governments for their own agendas. Foundational learning offers a
new garb to segregate the disenfranchised into ghettos of low cost, minimalist skill
programmes, while allowing unqualified unregulated ‘heroes’ to be ’employed’ and
to influence the agenda of schools. Ironically, qualified teachers, who are not available
for these children, are expected to consistently monitor their learning, and also this
army of volunteers, peer tutors, and instructional aides.
17. Regarding language learning, the document proposes the continuation of three
language formula. On one side the document argue the need for reducing the
curriculum load, at the same time it proposes learning of classical languages like
Sanskrit. And imposing too many languages in primary level is not desirable as it
increases the learning load. So a rethinking is needed on the number of languages to be
taught in the primary level in the context of minimising the learning load of the learners.
At higher level of schooling the possibility of including some languages as optional can
be thought of. We feel that the placing of Hindi or Sanskrit language is with political
intention rather than academic interest. Segregating the society by using languages is
objectionable.
18. Regarding teacher training, the document suggests a total revamping of the teacher
training system in order to increase the quality of teachers. It proposes 4 years integrated
degree (BA/BSc Ed.) as the qualification for teachers. This proposal also lacks clarity.
Four years of continuous professional education is envisioned here. At the same time
the document recommends continuing the existing pattern of two years BEd courses
also. The document it is not clear why the traditional B Ed courses are continuing. It is
very clear that the document fails to maintain a clear stand point on how the teacher
training institutions should function for catering the future demands.
19. The new policy document suggests the formation of new structures like Rashtriya
Sikshak Aayog. Constitution of more structures like these ultimately curtails the
creative freedom of teachers. Instead of enhancing quality, constitution of more
monitoring structures often creates administrative confusions and burocratic
domination. The document authorises SCERT as the academic authority of the state and
at the same time proposes more monitoring institutions. This will decrease the
importance of academic aspects. So it is better to retain institutions like SSRA as a
subsidiary of SCERT.
20. It is also noted that SCERT was declared as an academic authority at state level. Other
bodies were either merged with SCERT or were supposed to work in close coordination
with it. There is evidence that when all bodies work in harmonization quality of
education can be improved. Draft NPE has proposed exactly the opposite. It proposes
that Rashtriya Shiksha Aayog (RSA) will take care of policy, Department of school
education (DSE) will take care of operations and State School regulatory authority

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(SSRA) will take care of regulation and SCERT will take care of academic matters. This
will create new issues of harmonization.
21. Providing schooling facilities and good quality education to all is the essence of
democratic education. But the suggested bench mark for inclusion given in the
document is of low rate. It aims at an increase of revenue expenditure of 1% per year
and a total of 20% in the coming 10 years. Will that be 6% of the GDP? At the same time
it proposes increased private participation which will result in the intervention and
pressure of agencies having vested interests in the academic sector. Increased inequality
and decrease of quality will be the results. Increasing public expenditure in education
sector is the only solution for this. Unfortunately the document takes a negative stand
in this regard.
22. Every State must have one or more Boards of Assessment (BOA) which conduct the assessment
for the school leaving certificate and certify the same. The Boards of Assessment will completely
reform and improve the examination system - they will have no role in setting curricula or
creating textbooks: says the policy document. Private agencies are also permitted here. This
approach views assessment as a process out of learning and separates the two. No action
has been proposed to maintain the objectivity and accountability of the assessment
mechanism. It is very clear that the policy is for giving full freedom to the private players
which in due course enable them to sit in the driver’s seat of the education system.
23. The document recommends 5+3+3+4 structure of schooling. But it doesn’t say whether

the states have the flexibility to adapt the structure considering the state specific socio-
political and academic conditions.

24. In addition to the proposal to teach Sanskrit in all levels as part of the study of Indian
culture, the document suggests teaching any one of the classical Indian languages such
as Pali, Prakrit, Sanskrit, and Persian from middle classes onwards. It is not desirable
to set apart the major chunk of the curriculum for language learning. No specific plans
are recommended for the development and dissemination of local languages. The
document doesn’t give a clear vision about the concepts regarding language learning.
For example, aspects like the learning of letters and grammar are given undue
importance in the document.
25. The core components of the text books will be prepared centrally and the states are
permitted to adapt these areas according to the needs of the states. Private agencies are
also permitted to develop text books in this manner. This, in fact, rejects the state’s right
to develop its own text books taking into account of its specific needs. This is one of the
most objectionable stand. India is a country where the beauty is its diversity. At the
national level NCERT can propose a national frame work for fixing broader contours.
The rest will be the responsibility. On one hand the document argues for local text on
the other hand it also argues for a national centralised material. And also allowing the
private players to play the game as per their norms. This will become a pathway for

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handing over the right of developing the curriculum and related activities to the private
as well as communal elements.
26. A highly contentious recommendation in chapter three proposes school
‘rationalisation or consolidation’ through the set up of ‘school complexes’. This would
be done through mergers and by closing down ‘unsustainable’ small schools,
something which has long since been targeted by corporate NGOs and funding
agencies. Many states under pressure from Niti Ayog have already closed thousands
of schools; this policy’s claims of ensuring access through buses, paid walking escorts
or rickshaws to parents, are not practical or realistic. There social pedagogic reason for
setting up of schools (lower primary) within one kilometre radius to those children
below 10 to 11 years. We have to look different kinds of hazards which prevent children
coming to schools regularly including cultural hazards. The concept of school complex
put forward by Kothari commission and Draft NPE is not the same. Though the word
school complex is the same the intentions are contradictory. The need of the day is a
natural linkage between nearby schools as a collective for enhancing quality education
and equitable sharing all kind of resources including human resources judiciously.
27. Chapter 7.7.3: The responsibility of performance management of Teachers is entrusted to SMC.
Promotion and compensation increases of teachers and principals will be done only upon
endorsement by the SMC based on their adherence to the basic code of conduct. The draft
document doesn’t talk about good quality, equitable public education. The proposal
such as the school management committee and parents to decide and take decisions
are also problematic and objectionable. Can parents regulate schools? ” Instead of
providing adequately resourced schools like the kendriya vidyalayas to every child
and instead of developing a transparent and supportive monitoring system why the
govt trying to make cleavage within the school environment by dividing the parents
and teachers. The basic question is Why does public education have to be so stratified,
with the poor getting a poor school, whereas they deserve more nurturing attention?
The government is actually misleading the society by putting non issues in order to
suppress the systemic failures.

We have to add some more points.

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