Padam Mehta and Another v. State of Rajasthan and Others
Background
The appellants had filed a Public Interest Litigation before the Rajasthan High Court seeking a direction that Rajasthani language be included in the syllabus for the Rajasthan Eligibility Examination for Teachers (REET), 2021, and that children be taught in Rajasthani or the relevant local language. The High Court dismissed the PIL, holding that a writ of mandamus requires an enforceable legal right coupled with a corresponding statutory duty on the State, neither of which it found established. The appellants then appealed to the Supreme Court under Article 136.
Decision Breakdown
The Supreme Court allowed the appeal and set aside the High Court's order. It held that language is central to identity and meaningful participation in society, and that Part XVII of the Constitution and India's National Education Policy, 2020 recognise the importance of mother-tongue-based education. The Court noted Rajasthani is already taught at the university level in Rajasthan, undercutting the State's stand that only Eighth Schedule languages could be taught in schools. It directed the State of Rajasthan to formulate a comprehensive policy recognising Rajasthani as a regional language for educational purposes, to progressively introduce it as a medium of instruction starting at foundational levels, and to introduce it as a subject in all government and private schools in a phased manner, with a compliance affidavit due by 25 September 2026.
Lesson Learnt
Courts can direct the State to take concrete, time-bound steps to give effect to constitutional and policy commitments (like mother-tongue education) even where no single statute creates an explicit enforceable right: sustained governmental inaction in the face of recognised constitutional values can itself be judicially remedied.