Landmark Cases on Right to Education in India
🎓 Right to Education in India
📜 1. Mohini Jain v. State of Karnataka (1992)
Background:
Mohini Jain, a student, was denied admission to a private medical college because she couldn’t afford the high capitation fee.
Legal Issue:
Can education be treated as a commodity? Is charging exorbitant fees constitutional?
Judgment:
The Supreme Court held that Right to Education is a fundamental right under Article 21 (Right to Life).
It said:
"The right to life and dignity cannot be assured unless accompanied by the right to education."
Education cannot be denied to any citizen due to economic inequality.
Significance:
This case was the first major recognition that education is essential to the dignity and life of a person under Article 21.
📜 2. Unni Krishnan, J.P. v. State of Andhra Pradesh (1993)
Background:
This case dealt with the validity of capitation fees and the extent of the right to education.
Key Question:
Is the right to education a fundamental right? If yes, to what extent?
Judgment:
The Court held that Right to Education is a part of Article 21, but with reasonable limits:
State must provide free and compulsory education to all children up to the age of 14 years.
Beyond that, it is subject to the economic capacity of the state.
5-point Scheme:
The Court created a scheme:
Education up to 14 years = Fundamental Right.
Beyond 14 years = Not fundamental, but still important.
Private institutions can exist, but cannot charge capitation fees.
Government has the duty to regulate private education.
Professional education is not a fundamental right but is part of the directive principles.
Significance:
This case clarified and limited the right first expressed in Mohini Jain.
Set the groundwork for a constitutional amendment.
📜 3. 86th Constitutional Amendment (2002)
Not a case, but a result of court judgments.
Inserted Article 21A:
“The State shall provide free and compulsory education to all children of the age of six to fourteen years in such manner as the State may, by law, determine.”
It made Right to Education a fundamental right in a separate article.
It also modified Article 45 and Article 51A(k) to reflect the state's and parents’ duties.
📜 4. Society for Unaided Private Schools of Rajasthan v. Union of India (2012)
Background:
Private schools challenged the constitutionality of the Right to Education Act, 2009 (RTE Act), especially the 25% reservation for economically weaker sections.
Judgment:
The Supreme Court upheld the constitutionality of the RTE Act.
Held that even private unaided schools must admit 25% students from disadvantaged groups.
The provision is reasonable and in line with constitutional values of equity and social justice.
Significance:
Balanced right to establish institutions (Article 19(1)(g)) with right to education (Article 21A).
Ensured inclusive education for all children.
📜 5. Pramati Educational and Cultural Trust v. Union of India (2014)
Background:
Minority institutions challenged the applicability of the RTE Act to them.
Judgment:
The Supreme Court held that RTE Act does not apply to minority institutions, protected under Article 30(1).
Minority rights cannot be overridden by Article 21A.
Significance:
Clarified the limits of state interference in minority education institutions.
Protected cultural and educational autonomy while maintaining general implementation of the RTE Act.
📚 Summary Table
| Case Name | Year | Key Principle Established |
|---|---|---|
| Mohini Jain | 1992 | First recognition of Right to Education under Article 21 |
| Unni Krishnan | 1993 | Right to free education up to 14 years is fundamental |
| 86th Amendment | 2002 | Article 21A inserted: Right to free education for ages 6–14 |
| Society for Unaided Private Schools | 2012 | RTE Act upheld; 25% quota in private schools is valid |
| Pramati Educational Trust | 2014 | RTE Act not applicable to minority-run institutions |
🧠 Final Takeaway
The Right to Education in India evolved through judicial interpretation before becoming a constitutional guarantee under Article 21A. The courts have emphasized that:
Education is vital to dignity and equality.
The State has a duty to make education accessible to all, especially the poor and marginalized.
But at the same time, the autonomy of minority institutions must also be respected.
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