Name of the Case : Mohini Jain vs. State of Karnataka
Year of Judgement : 1992
Popular Name : Capitation Fee case
Related Topic/ Issue : Right to education
Related Article/ Schedule : 21 & 41
Supreme Court Judgement:
- Ruled that the right to education is a fundamental right under Article 21, extending to all levels including professional education like engineering and medicine.
- Stated that the right to life and dignity cannot be assured without the right to education, making it concomitant to fundamental rights.
- Declared that the state has a constitutional mandate to provide educational institutions at all levels.
- Deemed charging capitation fees for admission as a patent denial of a citizen's right to education, considering it arbitrary and violative of Article 14.
- Criticized the concept of "teaching shops" as contrary to the constitutional scheme, describing capitation fees as akin to selling education.
Impact of the Judgement:
- Served as the foundation for the Unni Krishnan case (1993) and subsequently the 86th Amendment Act (2002).
- In the Unni Krishnan case, the Supreme Court partially upheld and partially overruled the Mohini Jain judgement.
- The Unni Krishnan case addressed concerns that following the Mohini Jain judgement would necessitate the closure of engineering and medical colleges.
- The subsequent judgement provided further clarification on the implementation of the right to education.