In support of the campaign launched by BETTER UNIVERSITIES.

The Government of India has finally unveiled the much-awaited draft of the National Educational Policy (NEP) 2019, and with that, has come a host of new issues to address and engage with.

To access a copy of the draft, please click here.

Here is the full point by point critique made of the Draft NEP by Better Universities, that anybody concerned about education in India should read very carefully.

At the end you will find the link that will take you the campaign for mass feedback on the NEP.

Response to the Draft National Education Policy 2019

Most significant point in my opinion:

What is even more damning is that the appointments to all statutory bodies in the higher education sector will have to be made by the RSA – and must, by default, await the nod of the Prime Minister. It is unambiguously stated that appointees to the NHERA, HEGC, NRF, NAAC and all other standard-setting bodies must report to the RSA and thus be beholden to the infirmities of political will and favour. Needless to say, this amounts to the NEP’s unashamed surrender to ruling party intervention and an effective imagining of higher education as subservient to political interests. Autonomy is shown the door, both structurally and ideologically – despite the Draft making a shrill pitch for it through the previous chapters.

Introduction

While the former HRD minister’s message (included in the Draft policy) congratulates the exercise as evolving “path breaking reforms” based on the “foundational pillars of Access, Equity, Quality, Affordability and Accountability”, the higher education sector is instead coming under greater political control and contributing to wider inequities with respect to institutional inputs and outcomes. Even the employment goals envisioned by the curricular reforms proposed in the Draft policy might produce greater job insecurities among students coming into higher education from across different social and economic backgrounds.

Though the Ministry claims to have followed an “unprecedented collaborative, multi-stakeholder, multi-pronged, bottom-up people-centric, inclusive, participatory consultation process” in the framing of a National Education Policy, it is surprising that the list of consultations carried out by the Committee entrusted with its drafting (in Appendix VII) does not mention any teachers’ or students’ association in the country – barring a lone Akhil Bharatiya Vidyarthi Parishad, the student-wing of the RSS backed by the ruling-party at the Centre.

Given the signals that this ‘unprecedented’ consultatory process sends out, it is hoped that a wider process of conversations will be initiated with the student and teaching communities/organisations in the cause of a new National Education Policy.

Fourth Industrial Revolution?

The draft NEP spends considerable time dwelling on the need for a more liberal education, citing India’s ancient universities and the 64 kalas, and is indiscriminate in its usage of jargon such as STEAM (Science, Technology, Engineering, Arts, and Medicine) and the ‘fourth industrial revolution’ throughout. It is particularly alarming that the draft NEP treats the ‘fourth industrial revolution’ — a term coined by Klaus Schwab, the founder the World Economic Forum (WEF) in his 2016 volume and subsequently popularized in industry jargon — as a given, uncritically echoing the language of the WEF.

For instance, in the beginning of Chapter 11, the draft remarks,

With the coming fourth industrial revolution, and the rapidly changing employment landscape, a liberal arts education is more important and useful for one’s employment than ever before.” (223-224)

That the so-called ‘fourth industrial revolution’ in fact promotes the interests of the forces driving the WEF is hardly remarked upon, and is instead treated as a self-fulfilling prophecy.

Secondly, the ‘rapidly changing employment landscape’ — glossed over in a previous sentence in a light-hearted tone,

As remarked by journalist Fareed Zakaria, the purpose of a liberal arts education is not simply to prepare for one’s first job, but also for one’s second job, third job, and beyond” (223)

does not address the problem of structural unemployment, decreasing job security, and the ‘gig economy’ that is part and parcel of the so-called fourth industrial revolution and its ‘disruptions’. In the context of India’s own troubles with rising unemployment — as per figures released by the Ministry of Statistics and Program Implementation on May 31, 2019, unemployment stands at a staggering 6.1% — the uncritical acceptance of the ‘gig economy’ as a given appears particularly dangerous.

That the national education policy of a sovereign nation might reproduce, in a policy document, the language and interests of a forum of global multi-billion-dollar corporations (WEF) is unprecedented, since states are alert to and aware of the dangerous ways this undermines the sovereign interests of a nation and its people.

A Liberal Arts Education

The draft NEP’s promotion of liberal arts education is conducted in this light of uncritical acceptance of the jargon of the fourth industrial revolution,

A holistic and liberal education as described so beautifully in India’s past is indeed what is needed for the education of India in the future to truly lead the country into the 21st century and the fourth industrial revolution.” (225)

It promises to ‘bring back’ quality liberal arts education, in the process, devaluing the achievements of humanities and social sciences scholarship in India despite three decades of policy neglect and a concerted deprival of funding. The fact that the humanities and social sciences have been brought back to policy conversation in the light of producing ideal workers for the so-called fourth industrial revolution suggests considerable contempt for the said disciplines, and runs the risk of streamlining funding/curriculum solely at the service of corporate industrial interests as opposed to public interest.

The draft speaks of ‘breaking silos’ and ‘multidisciplinary’ training, without acknowledging the multidisciplinary elements in India’s existing undergraduate programmes wherein a student is already required to undertake a compulsory language component as well as courses from three different disciplines. This is particularly ironic in the light of the recent policy decisions that have placed the survival of interdisciplinary programmes such as Women’s Studies, Centres for Studies in Social Exclusion, and so on, under a dark shadow.

Furthermore, in its promise to ‘integrate’ the arts with the sciences and applied disciplines, the draft fails to recognize that academic disciplines offer a pedagogically useful and effective way of organizing knowledge, which might then be relayed to the student in a comprehensible fashion. By demanding that an undergraduate student combine, say, rural sociology with quantum physics in order to ‘innovate’, such a model of ‘integration’ effectively expects the student to integrate knowledge they do not possess, or to simply integrate what rudimentary understanding they have developed.

The Failed FYUP model

The proposed model of this idealized liberal education, as the draft claims, is a

a four-year Bachelor of Liberal Arts (BLA) or Bachelor of Liberal Education (BLE) degree (or BLA / BLE with Research)…offered by those institutions which are ready to run such programmes consisting of a broad-based liberal education together with rigorous specialisation in a field or fields. The three-year traditional B.A., B.Sc., as well as B.Voc. degrees will continue as well for those institutions that wish to continue such programmes, but all Bachelor’s degrees will move towards taking a more comprehensive liberal education approach.

In other words, it is but a rehashing of the failed Four Year Undergraduate Programme (FYUP) that was introduced at the University of Delhi (DU) in 2013, and subsequently rolled back by Smt. Smriti Irani — the then HRD minister — after protracted protests from all sections of the university community across ideological platforms.

The utter failure on the part of the draft to acknowledge the problems of the erstwhile FYUP — now rehashed as four-year BLA/BLE — is troubling, since such problems had been articulated by stakeholders in considerable volume at the time. It is almost as though the draft has been composed on a blank slate, where no such records exist. For instance, the glaring inequality of the design of the erstwhile FYUP, wherein the ‘flexible exit points’ would effectively produce lesser graduates that would affect marginalized students the most, has been enthusiastically replicated in the draft which speaks of ‘exit points’ multiple times, such as,

The design of these programmes could also offer an exit option for the student after three years with a B.A., B.Sc., B.Voc., or other relevant undergraduate degree if a student so desires.

There is little doubt that such provisions will force women and students from underprivileged and marginalized sections out of the university with a degree that cannot possibly match up to the hallowed BLA/BLE degree in ‘market value’.

It is equally troubling that the draft recognizes no merits in the existing three year degree programmes, and effectively demotes the same as Section 11.1 clearly states,

The three-year undergraduate programmes currently running will also be redesigned with the same objectives and principles, recognising the fact that the shorter duration of the programme will result in somewhat lesser possibilities for broad exposure or in-depth research. The existing three-year programmes will also continue, and it will be left to individual educational institutions to decide the duration (3 or 4 years) of the undergraduate programmes that they offer in different disciplines. The four-year programme will certainly allow for deeper possibilities for multidisciplinary exposure, research, internships, and dual majors or minors.

There is little ambiguity in the statement that the ‘four-year programme will certainly allow for deeper possibilities’, and serves to clearly disincentivize running the existing three-year programmes, despite making it sound like a matter of institutional choice. This lack of regard for some of the most successful flagship programmes run by India’s premier institutions in the present day appears to be a prime instance of ‘fixing something that isn’t broken’.

Furthermore, the promise of further redesigning of the three-year programme that has already undergone considerable redesigning and restructuring with the forced introduction of the semester system and the Choice Based Credit System (CBCS), with no acknowledgment of the labour, human cost, pedagogical damage or the infrastructural impediments of such restructuring, appears deeply callous.

HECI, by Another Name

Chapter 18 of the Draft proposes a complete overhaul of the “design and architecture of the regulatory system” for higher education. Arguing in favour of what the Report calls a “light but tight” regulation regime, the proposal for a common regulator overseeing all fields of liberal/professional/vocational education is not new. The Draft Higher Education Commission of India (HECI) Bill 2018 – placed for public review just about a year ago – had made out a similar case for a single regulatory body.

The NEP draft merely effects a change of name for the body – from HECI to National Higher Education Regulatory Authority (NHERA) – without altering its structure or spirit. But, it requires being pointed out that the 2018 draft legislation was severely criticised and unanimously rejected by educationists and huge numbers of the general public.

The Draft NEP complains about the Indian university sector mandating “some of the toughest requirements for setting up higher education institutions across the world”, and effectively hopes to simplify these strictures such that “setting up new HEIs will be made easier”. What is missing in this policy-sentiment against stringent regulation is a necessary appreciation of the rationale behind it: to prevent a slipping away of the higher education sector to private profiteering interests. It is true that the UGC has only successively loosened its clasp to allow the entry of dubious private investors over the past two decades, but the answer to this cannot be a further de-regulation of the field. The latter, as indicated by the Draft NEP and almost in line with the WTO’s demand of eliminating legal-legislative hurdles to the establishment of new institutions, will only aggravate the large-scale privatisation and divestment of public funds from higher education in the years to come.

Following on the publicly discredited model of the HECI, the Draft NEP also suggests that the regulatory function will primarily consist in accreditation and an evaluation of the “quality of outcomes”, irrespective of “input, resources, processes, conditions, etc.”. This overemphasis on accreditation as the sole significant prerogative of the NHERA will feed into the mad rush for NAAC ratings/rankings that we have witnessed playing out across the nation’s educational institutions since 2010. The redundancy of such accreditation processes does not call for more than a basic understanding of how ‘quality’ standards presume uniformity, and are hollowed of references to the diverse material contexts of institutional functioning. The NEP’s reinforced blindness to disparities in or uneven distribution of “input” parameters is bound to produce fictions of ‘grading’, with little attentiveness to ground reality.

Delinking Regulation and Financing

While imbibing the spirit of the HECI Bill, the Draft NEP recommends a complete separation of regulatory functions from powers of grant-disbursal. The UGC Act 1956 imagined an autonomous body as entrusted with the task of regulating higher education institutions as well as funding them. In an inversion of this policy-template, the HECI Bill dangerously sought to hand over the authority to grant funds to the MHRD itself – thus paving way for a political control of knowledge-institutions by the government of the day. The current policy draft tries to steer clear of this controversial transfer, by empowering a separate body (named Higher Education Grants Council) with the responsibility of releasing finances. Not only does this hint at a complete delinking of regulation and funding, but it also goes on to delink infrastructural funding for institutions from research funding – by passing on the latter to yet another statutory body called the National Research Foundation (NRF).

This heightened separation of statutory functions – and their effective decentralisation – conjures a claim of independence and autonomy at all levels. But, soon afterwards, the Draft proves that this structural independence is nothing but an illusion.

A Total Political Takeover

Chapter 23 of the Draft destroys this myth of autonomy, by announcing the creation of an apex body in all matters related to education. This body, titled as the Rashtriya Shiksha Aayog (RSA), will have as its chairman the Prime Minister of India. The placement of the Prime Minister in a position of such absolute authority regarding education undermines the very question of academic autonomy.

Section 23.5 states that

The RSA will consist of approximately 20-30 members. Membership will include some of the Union Ministers, in rotation, whose ministries impact education directly (e.g. health, woman and child development, finance), as well as a few Chief Ministers of States, in rotation, the Principal Secretary to the Prime Minister, the Cabinet Secretary, Vice-Chairperson of the Niti Aayog, the senior-most Secretary in the Ministry of Education, and other such senior bureaucrats/administrators as the government may deem appropriate.

The direct interference of ministers, bureaucrats and administrators — ‘deemed appropriate’ by the government of the day — speaks of an academic policy-making that undermines the potential for academic autonomy, and makes it further vulnerable to the political-ideological interests of whosoever might be in power at a given time.

Section 23.5 further states that

at least 50% of the members will be eminent educationists, researchers and leading professionals from various fields such as arts, business, health, agriculture and social work

but does not qualify the representation percentages of the fields in question or even the objective criteria for determining the ‘eminence’ of incumbents. It also remains silent on the representation of women and other marginalized groups (religious minorities and SC/ST/OBC) in the aforementioned body.

Section 23.6 states that an

RSA Appointment Committee (RSAAC), consisting of the PM, the Chief Justice of India, the Speaker of the Lok Sabha, the leader of the opposition in Parliament, and the UME, will be constituted to enable the appointments to the RSA and to other key related roles and structures,

a structure that is directly in contravention of any principle of autonomy for Indian higher education. It is unfathomable why the appointments to the highest decision-making body on education policy in India will be made by politicians and the Chief Justice, as opposed to stakeholders within academia itself.

Furthermore, the absence of any possibility of electing the members of this body — as opposed to nominated by Members of the Parliament and the Chief Justice, who have not necessarily been appointed to their positions on the basis of their contribution to the field of education — makes it undemocratic, and fundamentally opposed to the principle of academic autonomy celebrated earlier in the draft.

What is even more damning is that the appointments to all statutory bodies in the higher education sector will have to be made by the RSA – and must, by default, await the nod of the Prime Minister. It is unambiguously stated that appointees to the NHERA, HEGC, NRF, NAAC and all other standard-setting bodies must report to the RSA and thus be beholden to the infirmities of political will and favour. Needless to say, this amounts to the NEP’s unashamed surrender to ruling party intervention and an effective imagining of higher education as subservient to political interests. Autonomy is shown the door, both structurally and ideologically – despite the Draft making a shrill pitch for it through the previous chapters.

Section 23.11 states that “over a period of time, as the roles and functions stabilise, the RSA will be given Constitutional status through an Act of the Parliament.” The creation of an extra-Constitutional, politically appointed and unelected body that imposes its ‘vision’ upon universities undermines the ethics of institutional governance. Furthermore, such a body undermines the autonomy of the present MHRD (or the Ministry of Education) and creates dual centres of power, adding to the existing bureaucratic stranglehold on academics. The lack of provision of accountability for the RSA is also deeply troubling. Overall, the RSA seems to be an academic equivalent of the erstwhile National Advisory Council (NAC), with a potential to exert undue and extra-constitutional power over the present MHRD, the bureaucracy, and the universities of this country.

Section 23.18 makes it very clear that the allocation/channelization of budget will be reviewed/approved by the extra-Constitutional remote control body that is the RSA. Such empowerment of a body of this nature has the potential for massive misuse of public money depending on the interests of the political order of the day.

Section 23.19 speaks of the constitution of State Education Commissions (SEC), where

the respective SECs can have as its members the ministers of education, ministers of other stakeholder ministries related to education, eminent educationists and professionals, and a senior representative from the RSA. The creation of the SECs in the States will facilitate better coordination with the Centre.

The constitution of such a body to ‘co-ordinate’ with the RSA cannot but undermine the respective education ministries of the states, given the tight budgetary control the RSA holds (as noted in Section 23.18). It is important to remember that education is in the concurrent list and therefore while state and central coordination and cooperation is part and parcel of the overall welfare of education in India, any attempt on the part of the GoI to exert greater control over the states’ handling of state-funded educational institutions is absolutely unwarranted, damaging to the federal structure of India and its diverse requirements.

Furthermore, the addition of yet another body of ministers and their ‘nominees’ cannot possibly be a positive step in the empowerment and autonomy of educational institutions, despite the draft claiming to celebrate the same. It is to be noted that once again, the draft fails to make clear the composition of such diversity in terms of its representation of women and SC/ST/OBCs/religious minorities.

While the HECI Bill 2018 was critiqued for directly involving the MHRD (and bypassing the need for autonomy) in matters of educational funding and in setting up an Advisory Council headed by the HRD minister, the Draft NEP envisions the Prime Minister as the sovereign figurehead of higher education in the country, and unilaterally invests in him the power to nominate members and appoint functionaries in every single statutory body. This is in clear contravention of the foundational vision of the UGC Act 1956 which clearly maintained that the Chairman of the Commission “shall be chosen from among persons who are not officers of the Government or any State Government”, precisely with a purpose to maintaining the autonomy of the Commission from any form of direct interference by governments. Unfortunate as this move is, this makes the Draft NEP’s tall proclamations about the need for institutional autonomy sound utterly dishonest and hollow.

Setting Minimum Standards

The Draft policy also recommends a transformation of the multiple existing regulatory bodies for professional disciplines (like Bar Council of India, Medical Council of India, All India Council of Technical Education, National Council of Teacher Education, etc.) into standard-setting bodies (SSBs). These professional SSBs are then required to specify a “curriculum framework” or “expectations in a particular field of learning and practice”. However, by robbing these standard setting bodies of any “regulatory role” (Section 18.1.1), the original task of ascertaining the ‘minimum’ requisites for any course or programme is left to the institution itself. This will only encourage a proliferation of sub-minimal teaching programmes, mostly at private universities with little care or concern for basic curricular standards. The PSSBs, stripped of their regulatory role and punitive powers, will be reduced to toothless advisory bodies with little relevance to the academic quality-maintenance of HEIs.

Expanding Higher Education

The entire section on ‘Higher Education’ (Chapters 9 to 18) is driven by a policy concern about its expansion – as borne out by the Gross Enrolment Ratio (GER). It seeks to lay out a road-map for doubling the GER in tertiary education from the current 25.8 to at least 50 percent by the year 2035. This would mean an exponential increase in access and institutional enrolment, from the “present base of 35 million students” (Chapter 9).

However, the means suggested by the Draft in achieving this vision seem grossly out of sync with established models of policy-thinking. For example, a Report published by the UGC in 2008 – titled ‘Higher Education: Issues related to Expansion, Inclusiveness, Quality and Finance’ – coherently debated the challenge of increasing enrolments, and argued that there are two distinct methods of going about it. The first consists in a proportionate increase in the number of HEIs, and the second advocates for a higher student-‘intake’ within each HEI.

The Draft NEP contests this time-tested method – by insisting on lesser number of HEIs and absurdly higher enrolments in each. It pushes through a wholesale merger of smaller institutions, effectively bringing down a current total of nearly 50,000 HEIs to a maximum of 12,300 over the next two decades. Section 10.3 maintains:

In the long term (by 2040), the Indian higher education system will consolidate into a far smaller number of institutions, across the three Types of HEIs, but the average size of these institutions will be much larger than the average size today; this will help increase resource efficiency, multidisciplinary capacity and quality, as well as GER.

In plainer terms, the NEP draft calls for a slashing of the number of institutions to a quarter of its current spread, and yet hopes to achieve a doubling of overall enrolments. This not only seems impossible in terms of statistical permutation, but also voids the context of an institution’s functioning of the real indices of geographical access, social disprivilege and local-material demand. To assume that a massive concentration of colleges will achieve the goal of expansion – through a neat principle of population-based distribution – is to imagine policy as a matter of mere numbers. Even if the NEP’s arithmetic is to be trusted, the ‘less-colleges-more-students’ model will realistically only lead to half the expansion that it presumes.

While paying lip-service to a democratizing agenda for higher education – through “increased opportunities and access for students from socio-economically disadvantaged backgrounds and areas” (204) – the Draft NEP is actually clueless about how this is to be achieved. The plan for merging institutions, in the cause of greater enrolments and a more diversified curriculum, has every potential of aggravating structures of social discrimination.

By physically and intellectually alienating students from marginalised communities from their immediate life-world, such a plan ignores the complex interplay of social-psychological factors that affect campus experience and demography. Also, insofar as the policy Draft is surprisingly silent on forms of caste, class, gender and religious discrimination within higher education institutions, it does not have any viable template for substantive agendas of inclusion. The obsession with GER (or enrolments) as the sole yardstick of access shows how the question of alarmingly high drop-out rates among SCs/STs/minorities and women is left unattended.

Public Funding

All through the policy draft – and especially in its Addendum A1 – there is a refreshing insistence on increasing public finances for education. This is of course a welcome demand, particularly in the context of the Draft’s resistance to imagining education as a ‘for-profit’ good. This pitch for increased public funding is however far from being articulated for the first time, and has governed the tenor of policy thinking since the Kothari Commission report of 1966. But, the resolute negligence of this policy-prescription by successive governments and all political parties for decades proves that the mere pitching of the demand does not merit congratulation. It is important for us to note the extent of the increase proposed by the Draft, and its identification of possible sources for this additional expenditure.

Section A1.4.1 details the quantum of additional finances required by the education sector. While the allocations for the entire sector are expected to rise from the current 10 percent of total public expenditure (including Centre and the states) to an estimated 20.9 percent over the next 10 years, the claim for higher education is even more ambitious. The government’s investment in higher education is pitched at thrice the current spending – that is, an extra 5 percent over and above the present 2.77 percent of total revenue expenditure. While all these policy-demands are salutary, the Draft’s listing of sources for this possible revenue increase is where the miscalculation lies. There are three indications in the Draft of the means to garner the extra resources over the next 10 years: the growth of the national economy, a substantially higher tax-to-GDP ratio and targeted cess levies.

With India’s current GDP slumping to a five-year low and showing no signs of a miraculous recovery, employment rates touching the lowest in 45 years, tax-to-GDP ratios increasing at a slow average of 5.67 percent over the past decade as opposed to the imagined 10 percent, as well as a complete non-utilisation and non-allocation of cesses worth INR 94,036 crores in secondary and higher education for 11 years – it does not take much intelligence to predict the outcome of the Draft NEP’s elaborate financial recommendations.

Autonomy

The suspicion regarding the government’s commitment to public funding and rigorous regulation is strengthened by the Draft NEP’s repeated insistence on autonomy. Autonomy seems to involve the freedom to decide on a range of issues, while the exact import of such freedoms is largely left to be worked out in course of their operationalization. It is clarified, in Section 17.1.20, that there shall be three elements to autonomy – academic autonomy, administrative autonomy and financial autonomy. While the operationalization of each kind of autonomy is left vague, the most worrying are the pronouncements on financial autonomy.

The Draft’s discussion on higher education begins by contesting the interpretation of ‘autonomy’ as ‘reduction in public funding’, and it goes on to specify in Section 9.3: “financial autonomy will not mean a cut in funding, but rather the freedom to decide how best to spend funds to maximise educational attainments.” But, this assurance is soon belied in the very next Chapter – where the announcement, in Section 10.1.c, that “all HEIs will gradually move towards full autonomy – academic, administrative and eventually financial” is immediately followed by a call to treating private institutions on par with public HEIs. It is clear that the vision of financial autonomy championed by the Draft – despite caveats to the contrary – applies uniformly and impartially to both public and private institutions. In the same breath, the Section argues in favour of “gradually phasing out the system of ‘affiliated colleges’ in order to enable and encourage local innovation”. The implications of de-affiliating colleges in the name of ‘autonomy’ are not unknown, and their ‘eventual’ push towards privatization looms large on the horizon of the Draft NEP.

The policy draft states that “financial autonomy will be achieved by adequate public funds being committed and given to the public HEIs, with stability and certainty” (Section 17.1.20.c). What is misleadingly omitted from this Section that later elaborates on the meaning of autonomy (after the entire report waxes eloquent about it), is the fact that commitment to public funding is temporary, till such time when the institutions attain full financial autonomy.

The Draft makes no reference to the ways in which an institution may manage its finances once fully autonomous. In the light of recent debates about the demerits of self-financed courses and periodic fee-hikes one wonders how such mechanisms will play out in the operation of financial autonomy. No clear references are made to such possibilities, let alone a discussion on the problems that they are likely to pose.

The push towards financial autonomy – celebrated in the policy statement as local management of resources (Section 10.6) and therefore contributing to institutional freedom – dovetails with the lack of clear and convincing ideas regarding possible sources of public funding under the current financial constraints that the economy is functioning within.

The report celebrates what it calls “teachers’ autonomy”: the freedom to choose “their own innovative and personalised styles…to take into account their own expertise as well as their knowledge of their students’ needs.” (Section 13.1) In effect, besides creating further hype about autonomy, the policy has little to say about how such “teacher autonomy” will be operationalized. After all, “administrative” and “academic” autonomy, given how it has been defined, need not necessarily translate into teacher autonomy and could very well be manipulated to serve the interests of the administrators.

Graded Autonomy

To the extent that the Draft NEP does talk about how autonomy is to be operationalized, it largely falls back upon the much-criticised model of ‘graded autonomy’, wherein top-grade institutions would be the first to become autonomous. ‘Graded autonomy’ – as spelt out by a set of UGC Regulations in February 2018 – provided that the ‘high performance’ of institutions, decided through a flawed accreditation process, is to be “rewarded” with autonomy, slackening of regulatory regimes and withdrawal of financial support from the government. Section 18.2.2 of the Draft NEP picks up that same model and states that a “phased transition plan for existing colleges to get accredited and become autonomous over a period of a decade shall be put in place. Colleges that have already been accredited shall be given appropriate graded autonomy within the next 3 years.”

Section 10.3 of the policy Draft proposes a “new institutional architecture for higher education” by envisioning a graded classification of HEIs as ‘Type 1’ (research universities), ‘Type 2’ (teaching universities) and ‘Type 3’ (colleges) entities. Though the ‘type’-casting of HEIs is followed by a disclaimer that this is “not in any natural way a sharp, exclusionary categorisation, but is along a continuum”, the nature and scale of operations of each ‘Type’ indicates the differentiated quality-imagination behind each. Furthermore, the fact that it is deemed desirable for HEIs to strive towards moving from a lower ‘Type’ to a higher ‘Type’ proves the logic of ‘grading’ that governs such an architecture. That this ‘grading’ is a marker of institutional quality and will invite differential structures of governance for different ‘Types’ is borne out in the same Section: “The accreditation system will develop and use appropriately different and relevant norms for the three types of HEIs.”

The rule itself confirms the contingent nature of public funding and the government’s insincere commitment to the same. Government funding is meant to push institutions (primarily Type 1 & 2 institutions) towards higher performance, only to be deprived of such funding in the long run. It is clearly stated later, “financial autonomy will be devolved as confidence is established on capacity and probity of the institutions.” (Section 17.1.20.d).

By breaking down the autonomy question into three parts, the policy avoids making further pronouncements on what graded autonomy would imply. For instance, under the head of academic autonomy it is stated that autonomous HEIs shall be allowed to formulate their own rules about faculty recruitment. This is a throwback to the UGC Regulations last year that permitted autonomous institutions (Category I and II universities) to hire foreign faculty as per terms and conditions approved by their own Governing Councils/Statutory Bodies without prior approval of any regulatory body. The move was much criticised as it could potentially disrupt the internal academic and financial parity among the faculty of a university and compromise existing cultures of accountability. There is no assurance that such a measure would not be put in place yet again.

Section 12.4.11 provides for the setting up of ‘select’ foreign universities “i.e. those from among the top 200 universities in the world” to open offshore campuses in India. This goes on to craft out a separate ‘world-class’ grade of foreign institutions with no policy-commitment to questions of equity or justice, and in fact vindicates the WTO’s demand for ease of doing business in the higher education sector. Making a pitch for a “legislative framework facilitating such entry”, the Draft NEP effectively reinstates the terms of the Foreign Education Providers Bill 2013 – which has been vehemently opposed both within the Parliament and outside.

The separation of HEIs into three grades, the hurried accreditation process, the stated intention to adopt a process of facilitating autonomy, the push for a competitive ‘branding’-economy and the lackadaisical statements about the means of procuring enough public funds clearly suggest that ‘graded autonomy’ forms a cornerstone of the policy framework. If that is indeed the case, the loud pronouncements about increased government investment in higher education are substantially misleading.

Scrapping of M.Phil. Programme

Section 11.5.1 of the Draft NEP cursorily asserts that “the MPhil programme shall be discontinued”. There is no attempt made, at any point in the Draft, to delve into the rationale of the M.Phil. programme and the material realities that govern questions of access to research training in the country. The existing M.Phil. programme, with its rigorous coursework requirements, not only serves to transition a student from higher education to research, but it also has a deep social validity. For a large majority of women/SC/ST/OBC/minority students coming with a history of social disprivilege, the possibility of enrolling for and completing a Ph.D. programme (of 4 to 6 years’ duration) without a job to support oneself is very bleak. Most students from such backgrounds have therefore preferred to opt for an M.Phil. degree first, and then pursue Ph.D. while in service. Given that a Masters degree is only a ‘minimum qualification’ for academic appointments in the country (as per UGC-NET norms), the M.Phil. certification serves to benchmark candidates and thus even out differences in social capital for access to a Ph.D programme. The abrupt recommendation for abolishing the M.Phil. programme in toto only points to the Draft NEP’s complete disregard for a social justice agenda within higher education.

In the light of all the above observations about the current framework of the Draft National Education Policy 2019, it is evident that there are serious issues that require addressing and demand a nation-wide debate before the government embarks on any of the proposed structural reforms. Education is an issue that impacts every citizen of the nation, and has effectively determined the future of democracies across the world. It is therefore in the interests of all concerned – citizens and governments alike – that larger consultations be immediately initiated at a national level as well as with teachers’ and students’ associations, before the Draft NEP is taken forward.

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