Pramati Educational and Cultural Trust v. Union of India
Background
Private educational institutions challenged constitutional amendments permitting admission measures for disadvantaged groups and guaranteeing elementary education. They also disputed the Right to Education Act's obligations, including admission of children from weaker and disadvantaged groups in private unaided schools. Minority schools separately argued that compulsory admissions would undermine their protected character.
Decision Breakdown
The Court upheld Articles 15(5) and 21A against the basic-structure challenge. It also upheld the 2009 Act against the occupational-freedom objection of non-minority private schools, dismissing their petitions. The limited admission requirement, with the statutory reimbursement scheme, served equality and elementary education without destroying their constitutional freedom. However, applying the Act to minority schools, whether aided or unaided, would abrogate their rights under Article 30(1). The minority schools' petition was allowed, and the earlier ruling extending the Act to aided minority schools was disapproved.
Lesson Learnt
The 2014 ruling sustained the educational inclusion obligations of non-minority private schools while exempting constitutionally protected minority schools from this Act. A family's claim under the Act therefore depended in part on the school's legal status.