Introduction:
In a significant judgment emphasizing the constitutional importance of mother-tongue education and linguistic preservation, the Supreme Court of India in Padam Mehta and Another v. State of Rajasthan and Others, SLP (C) No. 1425/2025, directed the State of Rajasthan to formulate a comprehensive policy for the introduction and progressive implementation of Rajasthani language education in schools across the State. The judgment was delivered by a Bench comprising Justice Vikram Nath and Justice Sandeep Mehta.
The case arose from a long-standing demand seeking recognition of Rajasthani as a language of instruction and as a subject in educational institutions within Rajasthan. The petitioners approached the Supreme Court after the Rajasthan High Court refused to grant relief, holding that educational policy matters fall within the domain of the executive and that courts cannot issue directions compelling the State to introduce a particular language in schools.
The controversy centered around the status of the Rajasthani language, which, despite being widely spoken by millions of people in Rajasthan, has not been formally integrated into the school education framework in a meaningful manner. According to the petitioners, nearly 4.36 crore people reported Rajasthani as their mother tongue in the 2011 Census. However, the State continued to rely on the Rajasthan Official Language Act, 1956, under which Hindi is recognized as the official language of the State.
The petitioners argued that the exclusion of Rajasthani from school education directly undermines the constitutional vision of protecting linguistic diversity and ensuring meaningful access to education in a child’s mother tongue. They also contended that the National Education Policy, 2020 strongly endorses mother-tongue-based learning, particularly at the foundational stage, and therefore the State’s continued inaction violated constitutional principles.
The matter acquired constitutional significance because it involved the intersection of language rights, cultural identity, educational policy, and the State’s obligation to facilitate effective education. The Supreme Court was called upon to determine whether executive reluctance in introducing Rajasthani in schools amounted to a failure in implementing constitutional guarantees related to linguistic and educational rights.
The judgment is notable not merely because it concerns a regional language, but because it reinforces the broader constitutional commitment toward multilingualism, cultural preservation, and child-centric education. The Court acknowledged that while policy formulation ordinarily falls within executive discretion, constitutional courts cannot remain passive when constitutionally recognized rights are rendered ineffective through prolonged governmental inaction.
The ruling thus represents a major development in the jurisprudence surrounding language rights in India and could potentially influence similar demands concerning regional and mother-tongue education in other States as well.
Arguments of the Parties:
The petitioners strongly argued that the State of Rajasthan had failed to discharge its constitutional and educational obligations by not recognizing and introducing Rajasthani language in schools despite its widespread usage and cultural significance. Represented by Senior Advocate Dr. Manish Singhvi along with Advocate-on-Record D.K. Devesh, the petitioners contended that the denial of Rajasthani language education effectively deprived children of the benefits associated with mother-tongue learning.
The petitioners relied heavily upon the constitutional framework governing education and linguistic rights. They argued that Articles 29 and 30 of the Constitution recognize the protection of linguistic identity and minority interests, while Article 350A casts a duty upon States to provide facilities for instruction in the mother tongue at the primary stage of education. According to them, the constitutional scheme clearly demonstrates that linguistic preservation is not merely a matter of administrative preference but a constitutional aspiration deserving active implementation.
The petitioners further emphasized that the National Education Policy, 2020 expressly promotes education in the mother tongue and local language, especially during the foundational years of schooling. They argued that modern educational research consistently demonstrates that children learn concepts more effectively when taught in their native language. Therefore, the State’s failure to incorporate Rajasthani into school education not only ignored constitutional values but also contradicted contemporary pedagogical standards endorsed by the Union Government itself.
A central argument advanced by the petitioners was that the State’s insistence on limiting educational recognition only to languages included in the Eighth Schedule of the Constitution was legally unsustainable. They pointed out that inclusion in the Eighth Schedule is not a constitutional prerequisite for educational recognition or instruction. According to them, several languages and dialects not included in the Eighth Schedule continue to receive academic and institutional support in various parts of India.
The petitioners also highlighted the contradiction in the State’s position. They noted that Rajasthani was already being taught in universities and higher educational institutions across Rajasthan. Therefore, the State could not logically claim that the language lacked academic legitimacy or institutional preparedness. If the language was suitable for higher education and scholarly study, denying it a place in foundational education was arbitrary and discriminatory.
Additionally, the petitioners sought directions for the inclusion of Rajasthani in the syllabus of the Rajasthan Eligibility Examination for Teachers. They argued that unless teachers are trained and assessed in the language, the objective of meaningful mother-tongue instruction cannot be achieved.
On the other hand, the State of Rajasthan defended its position by arguing that educational policy matters fall within the exclusive domain of the executive and that courts should exercise judicial restraint in such areas. The State maintained that Hindi is the official language under the Rajasthan Official Language Act, 1956, and educational priorities are determined in accordance with existing administrative frameworks.
The State also argued that the introduction of a language as a medium of instruction or as a compulsory subject involves complex policy considerations including curriculum development, teacher recruitment, financial allocation, infrastructure creation, and textbook preparation. According to the State, such matters require expert evaluation and phased implementation, which cannot be directed through judicial intervention.
Another important contention raised by the State was that only languages recognized under the Eighth Schedule are presently taught as additional languages in government primary and upper primary schools. Therefore, according to the State, the absence of Rajasthani from the Eighth Schedule justified its exclusion from formal school curricula.
The State further contended that the Court should not substitute its views for that of policymakers in educational matters. Relying upon the doctrine of separation of powers, it argued that policy formulation is best left to democratically accountable institutions and administrative experts rather than judicial mandates.
The Rajasthan High Court had earlier accepted this broad line of reasoning and declined to issue directions for the inclusion of Rajasthani in schools. The High Court held that courts cannot compel the government to adopt a specific educational policy and therefore refused to interfere.
Before the Supreme Court, however, the petitioners argued that they were not seeking judicial overreach into policymaking but rather enforcement of constitutional obligations already recognized under the Constitution and national educational policy frameworks. According to them, the prolonged failure of the State to act had created a constitutional vacuum warranting judicial intervention.
Court’s Judgment:
The Supreme Court delivered a detailed and constitutionally significant judgment recognizing the importance of mother-tongue education and the State’s obligation to take affirmative measures toward linguistic inclusion in education.
At the outset, the Court acknowledged the limits of judicial power in matters of policy formulation. However, it clarified that judicial restraint cannot become a justification for constitutional indifference. The Bench observed that while courts ordinarily refrain from entering policy domains, they nevertheless possess a constitutional duty to ensure that recognized rights are not reduced to empty promises through executive inaction.
The Court made strong observations regarding the constitutional status of mother-tongue education. It emphasized that the constitutional scheme, particularly when read alongside the National Education Policy, 2020, reflects a clear commitment toward facilitating education in languages intelligible to children. The Bench held that once the Union Government itself has recognized the necessity and value of mother-tongue instruction through legislative and policy frameworks, corresponding obligations arise upon State Governments to meaningfully implement these objectives.
The Court observed that the State’s continued inaction had created a “palpable vacuum” in an area of immense constitutional importance. According to the Bench, constitutional rights cannot be allowed to remain merely symbolic or aspirational; they must translate into practical and tangible outcomes. The judgment stressed that executive inertia cannot dilute rights flowing from constitutional principles and nationally accepted educational policy.
A particularly important aspect of the judgment was the Court’s rejection of the State’s argument that only Eighth Schedule languages deserve educational recognition. The Bench termed the State’s approach “pedantic” and held that such reasoning ignored the realities of linguistic diversity and constitutional pluralism.
The Court specifically noted that Rajasthani is already being taught in universities throughout the State. This, according to the Bench, conclusively disproved the State’s suggestion that the language lacked pedagogical or institutional acceptance. The Court held that if a language is academically recognized at the university level, denying it a place in school education becomes difficult to justify.
The judgment repeatedly emphasized the educational benefits associated with mother-tongue learning. Although the Court did not enter deeply into educational theory, it accepted the broader pedagogical consensus that children learn more effectively when instruction is imparted in a familiar language, particularly during foundational stages of education.
Importantly, the Court did not direct immediate compulsory implementation across all levels of education. Instead, it adopted a balanced and phased approach. The State of Rajasthan was directed to formulate an “appropriate and comprehensive policy” for implementing mother-tongue-based education with respect to Rajasthani language.
The Court directed the State to recognize and accord due status to Rajasthani as a local or regional language for educational purposes. It further instructed the State to progressively facilitate its adoption as a medium of instruction, initially at foundational and preparatory stages and later at higher educational levels in a phased manner consistent with constitutional principles and pedagogical requirements.
The directions extended not only to government schools but also to private schools across the State. This aspect of the judgment demonstrates the Court’s intention to ensure broad-based linguistic inclusion rather than limiting implementation to public institutions alone.
The Bench also made powerful constitutional observations regarding judicial responsibility. It stated that the Court cannot remain a “silent spectator” to the dilution of rights clearly recognized in constitutional provisions, legislative enactments, and binding precedents. According to the Court, constitutional guarantees lose their meaning if governments fail to adopt effective implementation mechanisms.
The Court’s reasoning reflects an evolving constitutional philosophy that recognizes education not merely as formal instruction but as a means of preserving cultural identity, ensuring accessibility, and promoting substantive equality. By linking language rights with educational access, the judgment strengthens the constitutional understanding of inclusive and child-centric education.
At the same time, the Court carefully avoided excessive judicial encroachment into administrative details. It did not prescribe an exact curriculum structure, timeline, or implementation model. Instead, it directed the State to undertake policy formulation while ensuring that constitutional objectives are meaningfully realized.
The matter has been listed for compliance in September, indicating that the Supreme Court intends to monitor the State’s progress and ensure that the directions do not remain confined to paper declarations.
The judgment is likely to have far-reaching implications beyond Rajasthan. Several regional and indigenous language groups across India have long demanded greater educational recognition and inclusion. The Supreme Court’s emphasis on mother-tongue education, constitutional obligations, and linguistic diversity may strengthen future claims seeking similar protections and institutional support.
Ultimately, the ruling represents a significant reaffirmation of India’s multilingual constitutional identity. It recognizes that language is not merely a tool of communication but also a repository of culture, identity, and social belonging. By directing Rajasthan to move toward structured inclusion of Rajasthani in schools, the Supreme Court has reinforced the constitutional vision of educational inclusiveness rooted in linguistic diversity and cultural dignity.