[Marxistindia] Observations of CPI(M) on Draft National Education Policy 2019

[news from the cpi(m)]

July 20, 2019
Press Release
 
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therefore, the constitutional scheme of Federalism and should be withdrawn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,
Sd/-
(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.
 
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