Mohini Jain vs State of Karnataka
This is a landmark case on the Right to Education in India and has had a lasting impact on fundamental rights jurisprudence.
1. Case Name:
Mohini Jain v. State of Karnataka, AIR 1992 SC 1858
2. Facts of the Case
Petitioner: Mohini Jain, a student, challenged the Karnataka Education Act 1983 and related fee structures in private educational institutions.
Issue: Private professional colleges (medical and engineering) were charging exorbitant fees, making access to higher education difficult for economically weaker sections.
Legal Action: Mohini Jain filed a petition under Articles 14, 19(1)(g), and 21 of the Constitution.
Key Facts:
She argued that denial of affordable higher education was a violation of right to equality (Article 14).
Claimed it violated Article 21 (Right to Life and Personal Liberty), as the right to life includes right to education.
3. Legal Issues
Whether the right to education is a fundamental right under Article 21.
Whether the state has a duty to regulate private educational institutions to ensure access and affordability.
Whether charging exorbitant fees violates Articles 14 and 21.
4. Supreme Court’s Analysis
Right to Education under Article 21:
Court examined international norms and Indian Constitution provisions.
Held that right to life includes the right to education, because education is essential for meaningful exercise of other fundamental rights.
Equality and Non-Discrimination (Article 14):
Court noted that exorbitant fees effectively deny access to education, creating inequality in educational opportunities.
State Responsibility:
Government must ensure that private institutions operate under regulations to prevent exploitation.
Reasoning:
Education is necessary to participate fully in democratic society.
Denying access to education to those who cannot pay violates right to life and equality.
State can regulate fees and ensure affordable education.
5. Judgment
Supreme Court held:
Right to education is part of the fundamental right to life under Article 21.
State must ensure access to education without unreasonable restriction or economic barrier.
Charging exorbitant fees by private institutions is unconstitutional unless state regulation ensures accessibility.
State has a duty to plan and regulate educational policy to ensure social justice.
Significance: This judgment laid the foundation for Right to Education jurisprudence in India.
6. Significance of the Case
Right to Education:
Recognized as implicit in Article 21 (Right to Life).
State Duty:
Government is responsible for regulating private educational institutions to prevent exploitation.
Equality in Education:
Denial of access due to economic barriers violates Article 14 and Article 21.
Basis for Later Laws:
Paved the way for 84th Constitutional Amendment (2002) and Right of Children to Free and Compulsory Education Act, 2009.
7. Key Principles Established
| Principle | Explanation |
|---|---|
| Right to Education | Part of fundamental right to life (Article 21) |
| State Responsibility | Ensure affordability and accessibility of education |
| Equality | Economic barriers denying education violate Article 14 |
| Private Institutions | Must operate under state regulations to prevent exploitation |
8. Later Developments
Unni Krishnan v. State of Andhra Pradesh (1993) – Expanded Mohini Jain by framing a regulatory framework for private professional colleges.
Right of Children to Free and Compulsory Education Act, 2009 – Made education a justiciable right for children aged 6–14 years.
9. Conclusion
Mohini Jain v. State of Karnataka is a landmark case that recognized:
Right to Education as a fundamental right under Article 21.
State has duty to ensure access, regulate fees, and prevent exploitation by private institutions.
The case forms the foundation of India’s education rights jurisprudence, influencing policy, legislation, and subsequent court decisions.
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