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Letter to the HRD minister

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राम भक्त Also a pathologist and scientist

Dear readers, appended below is my letter to the HRD minister based on review of the draft NEP.

Sharing it here for everyone to use and incorporate in their responses.

Thank you

Dear HRD Minister,

Many thanks for inviting comments on the draft National Education Policy (NEP). Please accept my sincere appreciation for compiling the draft, a humongous exercise in itself.

I have reviewed the NEP with two different lenses – first as a father of school-going kids who will be affected by the recommendations, and second as a medical doctor with a reasonable understanding of higher education in India, especially Medicine.

The draft NEP has a lot of positive recommendations and the drafting committee must be commended for their far-sighted approach – both vis a vis school education (freedom to choose curriculum, textbooks in local languages, approach to student evaluation and the general spirit favouring of a student-focused approach) and higher education (flexibility to pursue more than one stream, and proposals pertaining to MOOCs/SWAYAM, Indian languages, online access to journals, online digital repository for ODL content etc).

My comments and suggestions (appended below – separately for school and higher education) pertain to those parts of the draft NEP where I feel the recommendations may negatively impact the stated objectives of the NEP.

Best regards,


School Education

Parameter Summary – current draft position Comments / Suggestions
Right to Education (RTE) act The drafting committee has rightly highlighted that the implementation of RTE leaves a lot to be desired and overall the initial intent of providing school education for all has not been fulfilled using the RTE act. The main impediments vis a vis RTE are:

  • Onerous input criteria without taking into account ground realities
  • The financial burden due to RTE has resulted in closure of many ‘public-spirited’ private schools run by non-profit trusts
  • RTE is applicable only to Hindu private schools – thereby depriving Hindus of quality institutions to preserve and protect their culture. Depriving Hindu-schools of their admission autonomy goes against the NEP’s own principle of autonomy of institutions. As a corollary, the education scenario is distorted in favour of minority-run institutions
  • There is potential for misuse of RTE exemption by certain schools claiming minority status, while in reality their school is not primarily serving that minority group
Despite recognizing these flaws, the draft proposes to extend RTE from 3-18 years of age (currently 6-14 years). This comes at a time when Hindu run schools are already under financial pressure that impact their viability. If more schools are shut down due to RTE, it will further restrict the availability of schools – and undermine ‘Education for All’. Therefore, I would urge the ministry to reconsider this proposal.

What I would also like to propose are suggestions that can address the issues plaguing RTE. This should help achieve India’s education goals while concurrently helping public-spirited private schools thrive – something that RTE in its current form does not facilitate.

  • Implement RTE equally across all schools irrespective of religious denomination, i.e., repeal Section 12(1)(c) criteria of 25%
  • If Section 12(1)(c) retained, then consider the following suggestions in descending order of priority
    • Retain RTE exemption to only minority institutions which primarily serve their minority groups
    • Dilute the percentage of RTE quota from the current 25% to a more reasonable figure – e.g. 5% or 10% to ensure financial viability of affected schools
    • Expedite reimbursement to schools and include non-tuition fee related items to the reimbursable amount. School should have the right to be exempted from RTE quota if reimbursement is not received for 3 years
    • Ensure private schools can be approached for admission only if a government school is not available nearby – an approach adopted by the Karnataka government
    • Instead of reimbursing fees to schools – reimburse school fees to the parents via Direct Benefit Transfer (DBT) such that schools are not exposed to the vagaries of volatility in income. The parent should, in turn, pay the full fees to the school
Syllabus, curriculum The draft acknowledges lacunae in current history-teaching, stating that – ‘basic historical facts are not currently taught in India – perhaps a remnant of an earlier colonial time’ Some greats in our history are over-represented, while others are not given commensurate importance. For e.g., there are minimal details on Chhatrapati Shivaji Maharaj, Maharana Pratap, Maharaja Krishna Devaraya and the Vijayanagara Empire, Lachit Barphukan and the Ahoms, Raja Raja Chola and many others. Their description is typically more detailed in respective state curricula, and not in the national curriculum. The destiny of our country has been shaped as much by these great heroes as others – they too need to be given their rightful place in our school textbooks for future generations to know about
The draft recommends revision of the national curriculum framework, and also encourages that the curriculum should be designed with emphasis on local content and flavor Apart from these, the curriculum should change when new knowledge becomes available. For e.g. textbooks needs to be updated with recent archaeological findings in Rakhigarhi, Sanauli etc. that have helped overturn past notions of our history
Teacher Training The draft recommends shutting down existing (substandard) Teacher Education Institutions In lieu of shutting down existing institutes, one could consider selecting better-performing institutes and try to improve the quality of training imparted by these institutes
Appraisal: All heads of school complexes will be appraised by the BEO and DEO Please reconsider this – the BEO / DEO may not be qualified to evaluate the head of school complexes. A peer review system may be better suited for this kind of evaluation
School accreditation The draft recommends that the SMC and two peer schools must endorse the self-accreditation for it to be valid, after adequate due diligence Kindly add that the reviewing peer schools be continuously changed so that the possibility of a bias or malpractice is mitigated
Fees The draft recommends that the percentage fee increase permissible based on inflation, etc. will be decided by SSRA for every three year period To eliminate overbearing bureaucratic controls, the SSRA should not mandate fees. Financial autonomy is an important aspect of school autonomy. Giving government the authority to decide fee increases may eventually make private schools a victim of electoral populism.

One possible solution may be to allow both for-profit and not-for profit private schools. The latter may have reasonable financial autonomy for providing quality education

Under-represented groups (URGs) The draft recommends that URGs (e.g. SCs, STs, OBCs, Muslims, migrant communities, urban poor etc.) have SEZs where an increased amount will be spent to enhance infrastructure. The draft also mentions that teachers from URGs be posted mostly in those regions where their group population is higher so that they become role models for students of their community Such segregation along caste and religious lines has the potential to increase divisiveness. A better and non-divisive approach may be to rank areas based solely on their education indicators (rather than demographic parameters).

In principle, role models should be chosen irrespective of their identity (rather than caste or religion). To create a more inclusive society, we need role models who transcend the boundaries of caste and religion

Higher Education

Parameter Summary – current draft position Comments / Suggestions
Scholarships The draft proposes setting up a National scholarship fund for financial support to students In my experience as a medical student, the fund needs to earmark appropriate amounts to stipends also – since many students pursuing higher education either discontinue or are unable to pursue their education further due to the lack of adequate stipends
The draft recommends that 50% of students in each programme be given fee waivers (20% to have 100% waiver, 30% to have 25-100% waiver) Please reconsider – these appear to be highly prescriptive / bureaucratic recommendations. Each HEI should have the freedom to choose the proportion of students to which they provide fee waivers and the degree of waiver – based on their feasibility. The HEI could however, be asked to justify their criteria. Mandating criteria may also cause financial distress to paying students (who partly subsidise scholarship-eligible students)
Faculty The draft proposes utilizing the services of retired/close-to-retirement researchers as mentors Western experience suggests that the role of academia in terms of goal-directed research for meaningful real-world difference, may be overemphasized. Many scientific discoveries come out of the Industry. India needs to leapfrog the western approach – what we need is more research faculty with industrial experience – who would help in goal-directed education.

We should also consider opening faculty positions to NRIs, OCIs and people of Indian origin. Many Indic origin people are involved in cutting edge research outside India and have a good standing among peers internationally. Many also are enthusiastic in wanting to contribute to their home country – and form a ready resource waiting to be tapped into

Role of government / bureaucracy The draft proposes that the government needs to have a perspective to drive the research that will result in innovations that will facilitate economic growth While this is a well-intentioned move, would suggest that this is restricted to ‘development’, rather than ‘research’ – since generally at the stage of basic / applied research, it is difficult to evaluate whether the potential application may facilitate economic growth or not. Also, the review process should be primarily technical (i.e., minimal bureaucratic interference)
Health Education The draft proposes that the first 1-2 years of MBBS will be common for all science graduates, following which students would specialize into their respective stream. The draft also proposes ‘bridging’ across systems and lateral entry into MBBS for students from nursing, dental etc. Inadequate details have been presented. Medical education has one of the most prolonged durations of education before a professional gains proficiency in his/her specialty – more details are required before we effect a change in the way medical education is conducted
The draft proposes an exit examination at the end of 4 years of MBBS, that would also double-up as an entrance examination This should lessen the burden on the students, and reward consistent performers. However, eliminating entrance examination would exclude any possibility of second-chance for the students – instead, I would propose having a (normalized) weightage for MBBS performance, in addition to a weightage for entrance exam marks
Diploma courses such as the one being offered by the College of Physicians and Surgeons, Mumbai, will be promoted produce sufficient numbers of intermediate specialists While diploma-holders can be used to fulfill health requirements – in principle, diploma should be considered an ad-hoc degree, with the opportunity for diploma-holders to increase their training and gain a MD/DNB qualification with experience
Vocational Education Offering majors and minors in vocations to both UG students Well intentioned move. However, there has to be a hierarchy if seats are limited. UG students should get to choose vocational as second preference after filling seats for students who intend to make the vocations as the source of their livelihood.

Given that vocational occupations are a huge employment generator, we should encourage manufacturing firms to set up vocational institutes and offer courses. These institutes should be in relatively close proximity to the manufacturing hubs, for ease of on-the-job training


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राम भक्त Also a pathologist and scientist
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