Supreme Court Holds That Meaningful Education Requires Learning In One’s Mother Tongue
A Division Bench of the Supreme Court comprising Justice Vikram Nath and Justice Sandeep Mehta has emphatically held that the right to receive education in one’s mother tongue forms an integral facet of the constitutional guarantees flowing from Articles 19(1)(a), 21, and 21A of the Constitution of India. Stressing that meaningful education is impossible without meaningful comprehension, the Court observed that language is not merely a tool of communication but the very medium through which identity, cognition, participation, and constitutional empowerment are realized.
The Bench was dealing with an appeal arising from a Rajasthan High Court judgment which had dismissed a Public Interest Litigation seeking inclusion of the Rajasthani language in the Rajasthan Eligibility Examination for Teachers (REET-2021) syllabus and seeking directions to impart education in the Rajasthani language or other relevant local languages.
Setting aside the High Court’s order, the Supreme Court strongly criticized the State of Rajasthan for adopting what it described as a “pedantic” and “lackadaisical” approach towards implementation of constitutional and policy commitments relating to mother tongue-based education. The Court observed that constitutional rights and policy declarations cannot remain dormant merely because the executive has failed to formulate an appropriate administrative framework.
At the outset, the Court undertook an extensive constitutional and historical examination of the role of language in India’s educational and constitutional structure. The Bench noted that the framers of the Constitution consciously devoted an entire part of the Constitution to language-related issues, recognizing language as a vital instrument for national integration, cultural continuity, and meaningful access to justice and education.
The Court traced the evolution of constitutional and statutory protections for mother tongue education, including Article 350A of the Constitution, the recommendations of the Kothari Commission, the National Policies on Education, the Right of Children to Free and Compulsory Education Act, 2009, and the National Education Policy, 2020. The judgment emphasized that these frameworks collectively recognize that children learn and internalize concepts far more effectively when taught in their mother tongue or regional language.
Significantly, the Court held that the right to receive education in a language understood by the child is constitutionally protected under Article 19(1)(a), which guarantees freedom of speech and expression. According to the Bench, the freedom to receive information necessarily includes the right to receive education in a manner that is intelligible and meaningful.
The Court observed:
“The true value of this freedom lies not merely in the ability to communicate, but in the ability to understand, internalize, and process information so as to make informed choices.”
The Bench further held that education imparted in an unfamiliar language risks impairing conceptual understanding, creating fear and alienation among children, and ultimately defeating the very purpose of elementary education. Referring to prior precedents including State of Karnataka v. Associated Management of English Medium Primary & Secondary Schools and English Medium Students Parents Association v. State of Karnataka, the Court reiterated that the choice of medium of instruction is closely linked with constitutional freedoms and meaningful educational access.
The Supreme Court also gave considerable importance to Section 29(2)(f) of the Right to Education Act, 2009, which mandates that curriculum formulation should, as far as practicable, ensure instruction in the child’s mother tongue. The Court interpreted this provision as a substantive guarantee intended to secure quality and inclusive education rather than a mere symbolic or directory requirement.
The Bench expressed serious concern that despite repeated constitutional directives and policy pronouncements, very little had been done by the State to operationalize mother tongue education at the ground level. The Court observed that rights which remain confined to policy documents without actual implementation become “illusory” and undermine constitutional governance itself.
Criticizing the State’s stand that only languages included in the Eighth Schedule are presently taught in Government schools, the Court held that such reasoning was untenable, particularly when Rajasthani is already being taught as a subject in various universities across Rajasthan. According to the Court, the academic recognition of Rajasthani at the university level itself demolishes the State’s argument that the language lacks institutional or pedagogical acceptance.
While the Court noted that no effective relief could now be granted regarding REET-2021 because the recruitment process had already concluded, it nevertheless held that the larger constitutional issues raised by the petitioners survive and warrant judicial intervention.
Accordingly, the Court directed the State of Rajasthan to formulate a comprehensive policy for implementation of mother tongue-based education in line with the constitutional framework and the National Education Policy, 2020. The State was directed to recognize and accord due status to Rajasthani as a local/regional language for educational purposes and progressively facilitate its adoption as a medium of instruction at foundational and preparatory stages of schooling.
The Court further directed the State to take affirmative and time-bound steps towards introducing Rajasthani as a subject in all schools, both government and private, in a phased manner consistent with constitutional principles and pedagogical requirements.
Emphasizing the constitutional importance of linguistic inclusion, the Bench concluded that courts cannot remain “silent spectators” when constitutionally recognized rights are diluted by executive inaction.
Case Details
Case Title: Padam Mehta & Anr. v. State of Rajasthan & Ors.
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Case Number: Civil Appeal arising out of SLP (C) No. 1425 of 2025
Citation: 2026 INSC 476
Date of Judgment: 12 May 2026