The Case of Mohini Jain vs State of Karnataka (1992)

July 19, 2024

To tackle the urgent problem of financial accessibility and to encourage educational inclusivity for all societal segments, the Indian government implemented the “government seats” reservation system. By allocating a portion of seats to students from a particular social class who have historically faced discrimination on a number of grounds, this creative initiative aims to uplift and provide inclusive education for children from those communities.

mohini jain vs state of Karnataka Case Facts

  • The Karnataka Legislature passed the karnataka educational institutions prohibition of capitation fee act in 1984 with the intention of ending the practice of charging admissions fees to applicants.
  • To restrict tuition costs at private medical schools, the Karnataka Legislature issued a notification on June 5, 1989 (referred to as the “challenged notification”) in compliance with Section 5(1) of this Act. Tuition and other fees were stated in this notification.
  • According to the contested notification, Karnataka residents (apart from the ones with government seat admissions) would pay a maximum yearly fee of Rs. 25,000, while students enrolled through “government seats” would pay Rs. 2,000. The highest annual cost for students from outside Karnataka is Rs. 60,000.
  • An offer to enroll in the MBBS program at Sri Siddharatha Medical College in Agalokote, Tumkur, Karnataka, with a session beginning in early 1991 and a cost of Rs. 60,000 was sent to Ms. Mohini Jain, a resident of Meerut, via mail. But the father of Ms. Jain got in touch with the college and said he couldn’t afford it.
  • The respondents refuted her allegations of an additional capitation charge of around Rs. 4.5 lakhs. Ms. Jain brought a complaint under Article 32(1) of the Indian Constitution, arguing that the notification infringed upon the right to education by charging unjustified fees in violation of Articles 12(2), 14(3), 211, and 41(4).

mohini jain vs state of Karnataka Issues

  • Does the Indian Constitution recognize the right to education as a fundamental right?
  • Does the imposition of a capitation charge adhere to the principles described in article 14 of the indian constitution?
  • Does the government’s notification permit capitation fees to be collected in the guise of regulation?

Contentions by Parties

Petitioner:

  • The petitioner argued that there is no rational relationship between capitation fee collection and the caliber of education offered by private schools. The policy is arbitrary and unjust due to the lack of a reasonable link, which violates Article 14 of the Constitution’s guarantee of the right to equality.
  • The petitioner claims that students from economically disadvantaged backgrounds who are unable to pay the exorbitant fees required by private colleges are subjected to discrimination by the capitation fee scheme. According to Article 14 of the Constitution, this kind of discrimination is against the equality principle.
  • The petitioner said that the Articles 38 and 39 of the Constitution’s Directive Principles of State Policy are in conflict with the capitation fee policy. The policy fails to uphold these ideals, which emphasize the state’s role to offer equal opportunities for all individuals and promote their welfare.

Respondent:

  • The State of Karnataka was the respondent in Mohini Jain v. State of Karnataka. They maintained that maintaining the caliber of education and the standards of the medical profession depended on admitting students to medical and dentistry universities on the basis of merit.
  • The State of Karnataka argued that since female candidates could not be as qualified as their male counterparts, giving seats to women could lower standards in medical education and the medical profession.
  • They further argued that allocating seats exclusively to women could be discriminatory towards male candidates, who may be more meritorious than female candidates and may not be able to enter because of the reservation policy.

mohini jain vs state of Karnataka Judgment

  • The Supreme Court of India ruled that the capitation fees collected by private educational institutions were illegal and supported the fundamental right to education. The right to education is upheld as a fundamental right that is safeguarded by article 21 of the indian constitution, which also safeguards the rights to life and personal liberty.
  • Furthermore, the court determined that the capitation fees levied by for-profit educational establishments violated article 14 of the indian constitution’s guarantee of equality.
  • The court noted that these fees had little to do with the quality of education provided by for-profit educational institutions and were instead essentially money-making demands. The court emphasized how economically disadvantaged sections in society were discriminated against as a result of these capitation payments, as they were unable to afford the exorbitant tuition costs.
  • The court also mandated that the government take steps to ensure that capitation fees are prohibited by regulating the prices that for-profit educational institutions charge. The court’s decision mandates that the government make sure that education is a right that is available to everyone and isn’t only reserved for the powerful and wealthy.

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