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

Padam Mehtav.The State Of Rajasthan

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 Court. LawLens
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In brief

The question

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.

The court held

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

It also directed

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.

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.

01Facts

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.

¶ 6

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

¶ 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.

¶ 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.

¶ 20-21

02Issues

i.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.

¶ 35 / para. 42

ii.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.

¶ 44 / para. 46

03Law 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.

¶ 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.

¶ 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.

¶ 17

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

¶ 18

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

¶ 38

Provisions in the judgment · 4 · Linked ones open on LawLens

Right of Children to Free and Compulsory Education Act, 2009 Section 3Section 15Section 17Section 29

04Reasoning

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

¶ 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.

¶ 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.

¶ 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.

¶ 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.

¶ 46-47

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

¶ 50-51

05Holding

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

¶ 52

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.

¶ 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.

¶ 49, 50, 54
Supreme Court

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Padam MehtavsThe State Of Rajasthan

Supreme Court · May 12, 2026

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