Supreme Court

State must provide mother tongue-based instruction and recognise regional languages to ensure meaningful education and constitutional rights.

Padam Mehta vs The State Of Rajasthan

Supreme CourtJUDGMENT: May 12, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellants filed a Public Interest Litigation (PIL) in the Rajasthan High Court seeking directions for the State to include the Rajasthani language in the syllabus for the Rajasthan Eligibility Examination for Teachers (REET), 2021, for Grade-III Teacher recruitment.

Source reference: para. 6

They further sought a mandate for the State to impart education to children in Rajasthani or relevant local languages.

Source reference: para. 6

The High Court dismissed the petition, holding that the appellants failed to establish an enforceable legal right or a failure of statutory duty by the State.

Source reference: para. 7

The appellants challenged this dismissal before the Supreme Court, contending that Rajasthani speakers constitute a "linguistic minority" under Article 350A and that the right to mother-tongue instruction is implicit in Articles 19(1)(a) and 21A.

Source reference: paras. 20-21
02

Issues

1. Whether the State is constitutionally and ligislatively obligated to provide facilities for instruction in the mother tongue/regional language at the primary level of education.

Source reference: para. 35 / para. 42

2. Whether the exclusion of a widely spoken regional language (Rajasthani) from the educational curriculum and recruitment syllabus violates constitutional mandates despite the existence of the National Education Policy (NEP) 2020 and the RTE Act, 2009.

Source reference: para. 44 / para. 46
03

Law Applied

Article 350A of the Constitution, which mandates that States endeavour to provide adequate facilities for instruction in the mother tongue at the primary stage.

Source reference: para. 15

Article 19(1)(a), interpreting the freedom of speech to include the right of a child to receive education in a language of their choice, as established in State of Karnataka v. Associated Management of English Medium Primary & Secondary Schools.

Source reference: para. 43

Section 29(2)(f) of the Right of Children to Free and Compulsory Education (RTE) Act, 2009, which mandates that the medium of instruction shall, as far as practicable, be in the child’s mother tongue.

Source reference: para. 17

National Education Policy (NEP) 2020, which emphasizes the primacy of regional languages in early education.

Source reference: para. 18

Principle of "Quality Education" under Article 21A as discussed in Devesh Sharma v. Union of India.

Source reference: para. 38
04

Reasoning

The Court reasoned that language is a matter of "existential rights" and essential for meaningful participation in society.

Source reference: para. 3

While the specific relief regarding REET-2021 was infructuous due to the conclusion of the recruitment, the Court addressed the broader failure of the State to implement mother-tongue instruction.

Source reference: para. 30

It rejected the State’s defense that Rajasthani is not in the Eighth Schedule, noting that academic recognition of the language in various State Universities (offering B.A. and M.A. courses) contradicts the claim that it lacks pedagogical standing.

Source reference: para. 50

The Court observed that under Article 19(1)(a), the "freedom to receive information" is hollow if the medium of instruction is unintelligible to the child.

Source reference: para. 42

It criticized the State for justifying inertia through a lack of policy, holding that once the Union has acknowledged the necessity of mother-tongue education via the RTE Act and NEP 2020, the State has a corresponding obligation to operationalize those rights.

Source reference: paras. 46-47

The Court concluded that the current "pedantic approach" of the State resulted in a "palpable vacuum" in a significant constitutional area.

Source reference: paras. 50-51
05

Holding

The Supreme Court allowed the appeal and set aside the High Court’s order.

The Court held that the right to primary education in one’s mother tongue is an intrinsic facet of the rights guaranteed under Articles 19(1)(a) and 21A.

Source reference: paras. 42-43

The Court directed the State of Rajasthan to: Formulate a comprehensive policy to implement mother-tongue-based education in line with NEP 2020; Recognize Rajasthani as a local/regional language for educational purposes and facilitate its adoption as a medium of instruction at foundational/preparatory stages; Take time-bound steps to introduce Rajasthani as a subject in all government and private schools in a phased manner; File a compliance affidavit by September 25, 2026.

Source reference: paras. 49, 50, 54
Supreme Court

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Padam MehtavsThe State Of Rajasthan

Supreme Court · May 12, 2026

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