Draft National Education Policy 2019: comments by George Nedumattom SJ

National Education Policy 2019: Comments

The salient features of the Draft Policy certainly requires appreciation and acceptance. Let us acknowledge that education must result in the “full development of human personality” and also the four pillars of education viz. learning to know, learning to do, learning to live together and learning to be. Education based on these pillars can surely ensure total development of the human person. The draft policy in its brief mention of our heritage broadly mentions the acceptance of various cultures and absorption of many influences down the centuries.

“It is essential that children and youth in the country are equipped with the knowledge, skills, attitudes and values as well as employable skills that would enable them to contribute to India’s social, economic, and political transformation.” This acceptance can bring in a revolution in the field of education if it is properly addressed to. The division of the education up to senior secondary level (Class XII) into four stages (5+3+3+4) appears to be very positive but the challenge will be to provide the required infrastructure, trained personnel and to ensure that quality training is provided to these students in these stages. “None of this will be possible without passionate and committed school teachers and faculty in higher education institutions who will take charge of transforming the education system as envisioned in this Policy.” This is the real scenario today and our country lacks the facilities for training these teachers.

“With regard to regulation, we have made our recommendations based on a key principle namely, that regulation, provision of education, accreditation, funding, and standard setting, will all be done by separate entities, and that regulation will be kept to a minimum.” This should be kept to the minimum and should only be broad guidelines. These regulations should not lead to interference in the administration and management of schools. The Draft Policy suggests ways of doing this efficiently when it says, “the approach should be to ensure that both political initiatives and administrative systems serve the goal of transforming the education system, and eliminating the power of vested interests, improving the transparency and efficiency of regulation, and investing public resources in areas that build the capital for effecting change.” The regulations or the regulatory body should not be a method of any interference in the administration of the school.


The vision of the draft education policy emphasizes an India cantered education policy. It is important to have this foundation for our education policy, but it should not be construed and misunderstood as imposing one or the other particular ways of thoughts on all students. Further, while we base ourselves on our culture and heritage, the vision misses the very important aspect of a global dimension which is required and necessary in today’s globalised world.

Early Childhood Care and Education: The Foundation of Learning

The objective of the early childhood education is very noble and important. The question is whether we will be able to achieve this objective by the year 2025 when there is so much lack of infrastructure, personnel and inequality in the education that is being provided. It maybe fruitful to view the “three years of pre-school (ages 3-6) to the end of Grade 2 (age 8), as a single pedagogical unit called the “Foundational Stage”.” The draft policy envisages “therefore, to develop and establish such an integrated foundational curricular and pedagogical framework, and corresponding teacher preparation, for this critical Foundational Stage of a child’s development.” The political and administrative will to accomplish this will be crucial to success of this programme.  The draft policy suggests to “employ workers/teachers specially trained in the curriculum and pedagogy of ECCE.” Will this lead to another educational qualification required for teachers who will be engaged in this stage or will the existing teachers be professionally updated with the new developments to achieve this goal? The “Oversight of Early Childhood Education by the Ministry of Human Resource Development” is coming under various ministries and departments. It will only lead to lack of accountability and responsibility. It may be advisable to bring this under one unified body which will oversee every aspect of this stage of education.

Foundational Literacy and Numeracy

The goal for children up to grade 5 appears to be good. The draft policy suggests that “the school and classroom curriculum and schedules for Grades 1-5 will be redesigned to focus on foundational literacy and numeracy, and to build a love for reading and mathematics among students.” (Page 59). We already have a well-defined curriculum and schedules for classes up to 5 and so it does not require any further redesigning but what is required is the ensuring of providing the atmosphere and facilities for the children to achieve what is already designed. Further, it recommends that “every child in Grades 1-5 will have a workbook for languages and mathematics in addition to the school textbook.” (page 59). Instead of adding more books to the load of the bags, what is required is to ensure that the children are provided sufficient practice in these areas in the school itself.

The draft policy suggests that  “starting in 2019, all Grade 1 students will begin with a three-months long “school preparation module”, which will help ensure that students have the required learning readiness and prerequisite learning levels prior to starting the usual Grade 1 syllabus.” (page 62). Why this repetition when the children are already being prepared from the age 3 and are following a curriculum which they have already begun?

The Pupil Teacher Ratio which is suggested in the draft policy is too ambitious considering the education scenario in our country and the population of our country. “All the measures for strong foundational literacy and numeracy will require that the PTR be less than 30 : 1.” (page 63). This will not be viable for the self-financed schools as well. It will be ideal to have the PTR as 45:1 considering the situation in our country.

Reintegrating Dropouts and Ensuring Universal Access to Education

The suggestion to “Allowing multiple models for schools, and loosening the input restrictions of the RTE Act:” (Page 71) is a welcome move to encourage private participation in the field of education. This will facilitate many more schools being established and proper monitoring of these schools will make it easier to achieve the goals set for 2025.

Curriculum and Pedagogy in Schools

I would consider this as the most important aspect of the draft education policy. The objective is well defined and the policy makers should stick to it without making any unscientific claims and changes to this vision leading the children to the required 21st century skills.

The suggestion to have a 5+3+3+4 is a welcome move. In fact it is only a restructuring of the existing system with renewed focus on various stages. The final stage in this system requires further thinking and clarification. “The Secondary Stage will comprise four years of multidisciplinary study, and will build on the subject-oriented pedagogical and curricular style of the Middle stage, but with greater depth, greater critical thinking, greater attention to life aspirations, and greater flexibility and student choice. Each year of the Secondary Stage will be divided into 2 semesters, for a total of 8 semesters.” (page 75). The policy suggests that every student will study 6 to 8 subjects during each of these semesters with some core subjects being common. This needs further study and clarification, otherwise it may dilute the rigour and in depth study required of various subjects at this stage as a preparation to higher education.

The draft policy also suggests to “reduce curriculum load in each subject to its essential core content, in order to make space for more holistic, experiential, discussion-based, and analysis-based learning” (page 77). This may be advisable at the first three stages of the suggested school structure, it may not be ideal at the fourth stage which needs to be very focused in depth study of various subjects which will lead the student to higher learning for the future. This should not dilute the required deep knowledge of the subject at this stage.

The four suggestions of Increased flexibility in choice of subjects, No hard separation of content in terms of curricular, extra-curricular, or co-curricular areas, No hard separation of arts and sciences, No hard separation of “vocational” and “academic” streams is very confusing and not well thought out. The secondary stage (grades 9-12) is time to prepare oneself for the higher studies in the future. At this stage to have such large variations and flexibility will defeat the purpose of achieving the 21st century skills. There should clearly defined framework of studies of various subjects which are essential rather than leaving it so flexible at this stage of education.

Education in the local language/ mother tongue; multilingualism and the power of language

The suggested language policy appears to be not well thought out.  “When possible, the medium of instruction - at least until Grade 5 but preferably till at least Grade 8 - will be the home language/mother tongue/local language.” (page 80). This needs to be further discussed and studied. It appears that this policy is going contrary to the global needs of today. While it is necessary to be efficient in the mother language, it is also required today that every person is well versed in English language for further professional growth of the person. Even if the beginning stages of education is provided in one’s own mother language, the option to have English medium education should be available to parents and students. The choice should be theirs rather than being imposed.

The suggestion to “to leverage the enhanced language-learning abilities of young children, all students from pre-school and Grade 1 onwards will be exposed to three or more languages with the aim of developing speaking proficiency and interaction, and the ability to recognise scripts and read basic text, in all three languages by Grade 3.” (Page 81) should be done away with and the existing policy regarding languages in schools should be continued without any tampering with it.

“We further observe that English has not become the international language that it was expected to become back in the 1960s.” (page 82). It is to be noted that this assumption may not be correct. There shouldn’t be any tampering with the language policy, neither in the name of “Course on the Languages of India” nor in the name of “Classical languages and literatures of India.” The language that is currently followed is sufficient and proper for the current global situation.

There is a special emphasis being placed on Sanskrit in school education in the draft education policy. “Sanskrit will be offered at all levels of school and higher education as one of the optional languages on par with all Schedule 8 languages.” (page 87) While we acknowledge the contribution of Sanskrit language and Sanskrit literature in India, it need not be over emphasised or imposed on the students. It should be left to the individuals to pursue the study of Sanskrit according to their interest.

 National Curriculum Framework

There is a suggestion to revisit and redesign the national curriculum framework 2005. The purpose of such activity should be to make the NCF relevant and future oriented which will lead the learner to acquiring 21st century skills. “Textbooks will aim to contain only correct, relevant material; when unproven hypotheses or guesses are included, this will be explicitly stated.” (page 102). This is a very contentious suggestion. Textbooks which will form the foundation of learning for the children, should not contain any unproven hypothesis, guesses or arguments. This should be totally avoided in textbooks.

Transforming assessment for student development

The draft policy suggests sweeping changes in the assessment process of the learning of the students to eradicate rote learning and the coaching culture. Such changes are required and would greatly influence the learning of the students. But the proposed model appears to be burdening the students further and avoiding in depth study and knowledge of any of the subjects.

“As a suggested model, each student over the duration of secondary school would be required to take at least two semester Board Examinations in mathematics, two in science, one in Indian history, one in world history, one in knowledge of contemporary India, one in ethics and philosophy, one in economics, one in business/commerce, one in digital literacy / computational thinking, one in art, one in physical education, and two in vocational subjects. In addition, each student would be required to take three basic language Board Examinations that assess basic proficiency in the three-language formula, and at least one additional Board Examination in a language of India at the literature level.” (page 108). How this is going to be achieved is a herculean task considering the infrastructure deficiency in our country. The model also proposes too many subjects to be learned by the students at this stage and it may only increase the present coaching atmosphere that is harming the learning process.


The draft policy has clearly spelt out the objectives and have aptly identified the issues affecting the teachers which in turn affect the teaching – learning process in the classrooms. The suggestions made in the draft policy regarding the training, recruitment and deployment of teachers is very much needed and welcome. The policy suggests that “the TET will be the first screening for recruitment.” It appears that even with the four-year integrated B. Ed programme, the teachers will have to go through another test to prove their ability to be recruited and deployed. If the B. Ed programme is strengthened, there will be no need for another test for finding their worth to be recruited as teachers.

Besides, the practice of having contract teachers in schools should be totally done away with and all the teachers should be tenured teachers to ensure quality and continuity in the teaching process.

The suggestion that “Aside from the minimal Supreme Court directives related to election duty and conducting surveys, teachers will not be requested nor allowed to participate in any non-teaching activities during school hours that affect their capacities.” (page 126) should be implemented in letter and spirit. Teachers should not be pulled out of school activities and should not engaged in other works.

School Management Committees as a mechanism for community support and supervision

The suggestions made regarding the SMC goes against the constitutional rights provided to the Minority institutions. The independence and rights of minority institutions should not be tampered with. “Functioning of all schools (government/public, privateaided and private-unaided) will be supervised by the SMC, the constitution of which is mandatory since the enactment of the RTE Act.” (page 173).

Regulation and Accreditation of School Education

The draft policy has made elaborate suggestions regarding the regulation and accreditation of all schools through various mechanisms. It is necessary to have regulation and accreditation but the purpose of these should be to encourage and strengthen the public and private schools and not to stifle genuine schools.  “Public and private schools will be regulated on the same criteria, benchmarks, and processes, emphasising public disclosure and transparency rather than mandates, so as to ensure that public spirited private schools are encouraged and not stifled in any way.” (Page 179) This should be put into practice without any dilution of the suggestion.

These suggestions are very welcome and should be put into practice in letter and spirit. “Private philanthropic schools have played and will continue to play an important role in India. These initiatives must be encouraged and not stifled by treating them with suspicion. Such schools too must be empowered and freed of the regulatory overload, and its resulting problems.” (Page 189). This will help the establishment of many more private schools which are truly educational institutions which provide quality education to the children. “The loading of regulatory requirements only against private schools should end with uniform requirements for all schools emphasising public disclosure on basic parameters.” This should be the way forward.

The School Managing Committee for Private Schools

The suggestion regarding the SMC needs to be reviewed in the light of the constitutional rights of the minority institutions. These rights should not be trampled to ensure that they are able to function within the framework provided to these institutions. The public disclosures required under the suggested framework will lead to unnecessary interference and problems from various sections. “They must also transparently report their annual audited financial statements and other reports submitted to the Income Tax Department, the SMC and the public. The SMC must endorse the statement for it to be valid. The financial disclosure standards must be the same as for Section 8 (not-for-profit) companies. The SDP and the Financial Statements shall be freely and publicly available (including online).” (Page 191). This need not be done and it should be disclosed to the mandated government agencies to ensure quality, transparency and genuineness.

Review of the RTE Act

The review of the RTE Act is welcome. There should not be any dilution of the minority rights of the institutions in the name of review of RTE Act. The definition of minority school as provided in the constitution should not changed at all. The definition is any institution that is established and administered by the minority community and it does not depend on the number of students served from the minority community. But the suggestions in the draft policy reflects otherwise. “Judicial exemption, granted by the Supreme Court, may have been misused by certain schools, by claiming minority status, while in reality their school is not serving primarily that minority group, as reflected in the proportion of the schools’ students from that minority group.” This shouldn’t be the criteria for defining any minority institution.

George Nedumattom SJ (PAT)