Tuesday, 3 November 2026
Supreme Court of India
Constitutional Law

Mother-Tongue Education a Constitutional Mandate: Supreme Court Directs Rajasthan to Introduce Rajasthani in Schools

Published: · NyayVidhan · 3 min read

In Padam Mehta v. State of Rajasthan, the Supreme Court set aside the Rajasthan High Court's dismissal of a public interest litigation seeking a place for the Rajasthani language in teacher recruitment and school education. The REET, 2021 prayer had become infructuous, but the Court located the right to receive education in one's mother language in Article 19(1)(a) and directed the State to frame a mother tongue-based education policy and introduce Rajasthani as a subject in all schools (paras 30, 42, 49-50).

Mother-Tongue Education a Constitutional Mandate: Supreme Court Directs Rajasthan to Introduce Rajasthani in Schools

Judgment Intelligence

Petition Allowed
Padam Mehta & Anr. v. State of Rajasthan & Ors.
2026 INSC 476
Civil Appeal No. 7458 of 2026 (arising out of SLP (C) No. 1425 of 2025)
Court
Supreme Court of India
Date of Decision
12 May 2026
Bench
Justices Vikram Nath and Sandeep Mehta
Relevant Acts & Sections
Constitution of India - Articles 19(1)(a), 21, 21A, 41, 45, 51A(k) and 350A; Right of Children to Free and Compulsory Education Act, 2009 - Section 29(2)(f); National Education Policy, 2020
Final Outcome

Appeal allowed. The High Court's order of 27 November 2024 was set aside; Rajasthan was directed to frame a mother tongue-based education policy, introduce Rajasthani as a school subject and file a compliance affidavit by 25 September 2026 (paras 49-50, 52, 54).

Source Supreme Court of India, www.sci.gov.in — judgment dated 12 May 2026 · Court's copy

Key holdings

  1. The prayer to add Rajasthani to the REET, 2021 syllabus was held infructuous, as that recruitment had concluded (para 30).
  2. The right to receive education in one's mother language was located in Article 19(1)(a) (paras 42-43).
  3. Rajasthan was directed to frame a policy on mother tongue-based education and to recognise Rajasthani as a local/regional language for educational purposes (para 49).
  4. The State must take time-bound steps to introduce Rajasthani as a subject in all schools, government and private, in a phased manner (para 50).
  5. A compliance affidavit was due by 25 September 2026, with the matter listed on 30 September 2026 (para 54).

Case explainer by NyayVidhan: an account of this judgment and the law it laid down, not the court's text. The judgment itself is the authoritative version.

Brief Facts

The appellants filed a public interest litigation in the Rajasthan High Court at Jodhpur (D.B. Civil Writ Petition No. 5294 of 2021) seeking the inclusion of Rajasthani in the examination syllabus for recruitment to the post of Teacher, Grade-III, Level-I and Level-II, under REET, 2021, and a direction to impart education to children in Rajasthani or the relevant local language (paras 5-6). On 27 November 2024 the High Court dismissed it, holding that mandamus issues only where the petitioners establish an enforceable legal right and a failure to discharge a statutory duty (paras 5, 7). The State's stand was that only Eighth Schedule languages are taught and no policy existed for Rajasthani (para 25).

Court's Findings

The REET, 2021 prayer had become infructuous because that recruitment was over, but the wider questions on language in education could not be brushed aside as wholly academic (paras 30-31). Articles 21, 21A, 41, 45, 51A(k) and 350A make education a constitutional entitlement, and instruction that students cannot grasp because of language barriers is not quality education (paras 34-35). Section 29(2)(f) of the RTE Act, 2009 and NEP, 2020 reinforce mother-tongue instruction (paras 39-40). Relying on English Medium Students Parents Assn. and Associated Management, the Court located the right to receive education in one's mother language in Article 19(1)(a) (paras 41-43). It found a substantial deficit in implementation by the State and described the State's reliance on the Eighth Schedule as a myopic stance (paras 44, 46). Policy formulation is not the Court's province, but it must ensure that Part III guarantees are not rendered illusory by executive inaction (para 47). That Rajasthani is taught at university level belied any suggestion that it lacks pedagogical acceptance (para 50).

Legal Principle

Education in a language the child understands is part of quality education, and the right to receive education in one's mother language rests on Article 19(1)(a), supported by Article 21A and Section 29(2)(f) of the RTE Act, 2009. Where executive inaction leaves this unrealised, the Court may direct the State to frame a policy (paras 35, 39, 42, 47-49).

NyayVidhan's view · Practice note

Why It Matters

The specific REET, 2021 prayer failed as infructuous (para 30), yet the judgment turned a PIL about one examination into continuing duties for the State: a policy on mother tongue-based education, recognition of Rajasthani for educational purposes, and its phased introduction as a subject in government and private schools alike (paras 49-50). Parents, teachers and school managements can rely on para 42 for the Article 19(1)(a) footing of mother-tongue instruction. The judgment sets no outer date for the policy itself; it called for a compliance affidavit by 25 September 2026 (para 54). Compare Varshatai on official languages and linguistic diversity.

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

  1. State of U.P. & Anr. v. Anand Kumar Yadav & Ors. (2018) 13 SCC 560
    Relied Upon Discussed at ¶ 36

    Quoted for the principle that the right to education is the right to quality education, in support of the Court's view that instruction a child cannot grasp because of language is not quality education.

  2. Devesh Sharma v. Union of India & Ors. (2023) 18 SCC 339
    Relied Upon Discussed at ¶ 38

    Quoted on the transformative purpose of the RTE Act, 2009: the Act aims at elementary education of ‘quality’, not merely free and compulsory education.

  3. English Medium Students Parents Assn. v. State of Karnataka & Ors. (1994) 1 SCC 550
    Relied Upon Discussed at ¶ 41

    Relied on for the pivotal role of mother-tongue instruction in a child's development and the State's obligation to promote the regional language.

View all precedents (4)
  1. State of Karnataka & Anr. v. Associated Management of English Medium Primary & Secondary Schools & Ors. (2014) 9 SCC 485
    Relied Upon Discussed at ¶ 43

    Relied on to hold that Article 19(1)(a) encompasses the freedom of a child to receive primary education in a language of his or her choice.

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