Right to Education Includes the Right to Learn in One’s Mother Tongue, and States Cannot Ignore Constitutional Duty to Promote Regional Languages
Case Name: Padam Mehta and Another v. State of Rajasthan and Others
Citation: 2026 INSC 476
Date of Judgment/Order: 12 May 2026
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Held: The Supreme Court held that the right to receive education in one’s mother tongue or regional language is intrinsically connected with the constitutional guarantees under Articles 19(1)(a), 21A, 41, 45, 51A(k) and 350A of the Constitution. The Court held that meaningful education necessarily requires comprehension through a language intelligible to the child and that instruction in the mother tongue substantially enhances conceptual clarity and cognitive development. While the Court declined to issue directions regarding the already-concluded REET-2021 recruitment examination, it held that the State of Rajasthan could not justify its inaction merely because Rajasthani is not included in the Eighth Schedule to the Constitution. The Court observed that constitutional rights and policy commitments relating to language and education cannot be allowed to remain merely on paper due to executive inertia.
Summary: The appellants had filed a Public Interest Litigation before the Rajasthan High Court seeking inclusion of the Rajasthani language in the syllabus for Rajasthan Eligibility Examination for Teachers (REET)-2021 and also sought directions for imparting education in Rajasthani or the relevant local language. The High Court dismissed the petition holding that no enforceable legal right or statutory duty had been established. Before the Supreme Court, the appellants argued that Rajasthani speakers constitute a linguistic minority in Rajasthan and that the right to education in one’s mother tongue is protected under Articles 19(1)(a) and 21A of the Constitution. The State contended that only languages included in the Eighth Schedule are presently taught in schools and that Article 350A is merely directory in nature. The Supreme Court undertook an extensive examination of the constitutional framework governing language rights, the Constituent Assembly debates, Article 350A, the Right of Children to Free and Compulsory Education Act, 2009, the National Education Policy, 2020, and prior precedents recognising the importance of mother tongue instruction. The Court strongly criticised the State’s “pedantic” and “lackadaisical” approach in failing to operationalise constitutional and policy mandates relating to regional language education.
Decision: The Supreme Court allowed the appeal and set aside the Rajasthan High Court’s judgment dated 27 November 2024. The Court directed the State of Rajasthan to formulate a comprehensive policy for effective implementation of mother tongue-based education in line with the constitutional framework and the National Education Policy, 2020. The State was directed to recognise and accord due status to the Rajasthani language as a local/regional language for educational purposes and to progressively facilitate its adoption as a medium of instruction at foundational and preparatory stages and thereafter at higher levels. The Court further directed the State to take affirmative and time-bound steps for introducing Rajasthani as a subject in all government and private schools in a phased manner. The State of Rajasthan was directed to file a compliance affidavit by 25 September 2026, and the matter was directed to be listed on 30 September 2026 for consideration of compliance.