Skill India Mission

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Facts:

  • Nearly 90% of employable people did not receive any vocational training, posing a challenge for the government’s Skill India Campaign.
  • Among persons in the 15-59 age group, about 2.2% received formal vocation training — NSSO 2011-12
  • While 75% in Germany and 80% in Japan. 50% in China are skilled.
  • Govt target to impart skills training to 40 crore people by 2022, and the new govt has a dedicated Ministry of Skill Development and Entrepreneurship.
  • Proportion of young adults who had received vocational training was virtually unchanged between 2004-05 and 2011-2012.
  • There remain multiple decision-making authorities on skills and little clarity about who exactly will do the work. Promise of corporate and foreign partnerships on skilling are pouring in, but how these mass skilling programme will take off is unclear.
  • Need to design curricula as per changing job requirements.

Indian Skill Development Service

The Union cabinet gave its nod for the formations of Indian Skill Development Service (ISDS).

Details:

  • Indian Skill Development Service (ISDS) will be a Group ‘A’ service of the technical cadre of the Ministry of Skill Development & Entrepreneurship (MSD&E).
  • ISDS was earlier called the Directorate General of Employment & Training which was under the aegis of Ministry of Labour Employment.

Why was it created?

  • To improve skill development administration in the country.
  • To enhance the capacity and efficiency of the organization.

Selection:

The cadre will be selected through the Union Public Service Commission (UPSC) and have the same ranks and profile as other Group A services such as the Indian Revenue Service, Indian Audit and Accounts Service and Indian Railway Service.

Their roles:

  • The new cadre of officers will run the skill development and entrepreneurship ministry, help implement various skill and apprenticeship schemes conducted by the ministry as well as those by the Directorate General of Training (DGT).
  • The new officers will help formulate skill policies, devise a road map for improving the apprenticeship system, revamping ITIs and also help revamp course work for various schemes.

Was it necessary?

India aims to skill some 500 million people by 2022 in both organized and unorganized sectors to improve the efficiency of the work force, provide job-ready human resources to industries and ultimately improve the competitiveness of a young demography considered crucial for the economic growth of India. To achieve these objectives, it is necessary to have such a dedicated service.

Initiatives under Skill India Mission

  • Skill India Mission is an initiative of the Government of India, launched by the Prime Minister on the 16th of July 2015 with an aim to train over 40 crore people in India in different skills by 2022.
  • It includes various initiatives of the government like
    • National Skill Development Mission,
    • National Policy for Skill Development and Entrepreneurship, 2015,
    • Pradhan Mantri Kaushal Vikas Yojana (PMKVY) and
    • Skill Loan scheme.

National Skill Development Mission

  • The mission was launched for creating convergence across various sectors and different States in terms of activities relating to skill training.
  • The mission would, along with consolidating & coordinating skilling efforts, expedite decision making across sectors to achieve quality skilling on a large scale.
  • The scheme would be implemented through a streamlined institutional mechanism driven by Ministry of Skill Development and Entrepreneurship (MSDE).

National Policy for Skill Development and Entrepreneurship 2015

  • The policy intends to create a skilling ecosystem on a large scale.
  • The objective of the policy is to meet the challenges of skilling at a large scale with quality and speed, enabling the individuals to realize their full potential through the life-long learning process where the competencies are garnered via instruments such as credit accumulations, credible certifications etc.
  • This policy will link skills development to improved employability and productivity.

Pradhan Mantri Kaushal Vikas Yojana (PMKVY)

  • PMKVY is a flagship scheme of the Ministry of Skill Development and Entrepreneurship (MSDE). It was launched with an objective of enabling a large number of youth in India to take up skill training that is relevant to specific industry, which would help them in securing a better livelihood.
  • The individuals with prior skills and learning experiences would also be certified under Recognition of Prior Learning (RPL) component. The scheme caters monetary rewards to those individuals who have successfully completed the sanctioned training programmes.
  • Sector specific skill councils such as Agriculture Sector Skill Council, Food Industry Capacity and Skill Initiative (FICSI), Health Sector Skill Council etc are established under the scheme.

Skill Loan Scheme

  • The skill loan scheme was launched with an intent to support the youth willing to take up skill training programmes in the country. This Skill Loan Scheme replaced the earlier Indian Banks Association (IBA) Model Loan Scheme for Vocational Education and Training.
  • Any Indian National taking admission in a course offered by Industrial Training Institutes (ITIs), Polytechnics , school recognized by Central or State education Boards, college affiliated to recognized university, training partners affiliated to National Skill Development Corporation (NSDC) Sector Skill Councils, State Skill Mission, State Skill Corporation can avail loan under the scheme. The repayment period under the scheme is 3 to 7 years.
  • This scheme does not discriminate against women.

PISA Test Issue

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Context:

  • Union Ministry of Human Resource Development (HRD has officially decided to participate in Programme for International Student Assessment (PISA) after gap of nine years.
  • It will send team of officers to Paris to negotiate India’s terms of participation in PISA 2021.

 ias4sure.com - PISA Test Issue

Programme for International Student Assessment (PISA)

  • PISA is assessment test for 15-year-olds, organised every three years by Organisation for Economic Cooperation Development (OECD), Paris, France.
  • It was started in 2000 with about 43 states participating, and its latest edition in 2015 saw participation from 73 countries including China and Vietnam.
  • PISA measures student performance in mathematics, reading, and science and even innovative subjects like collaborative problem-solving and money literacy.
  • The test is designed by education experts around the world.
  • It assess how students apply what they have learnt to real-world problems.
  • PISA test results give insight into education systems around the world.
  • The results are shown as a national mean score and not shown individually.
  • Its objective is not to rank countries, but to see how education system can be improved.
  • Countries willing to participate in PISA choose kids from different regions to represent sample of 15-year-olds in their country.
  • In 2012 PISA test, schools of Shanghai in China topped reading, mathematics and science test, followed closely by Singapore.
  • In 2015, Singapore, Japan and Estonia were ranked as top three countries, in that order.

 

India’s boycott of PISA

  • India had made its debut in PISA in 2009 with 16000 students from 400 schools across Tamil Nadu and Himachal Pradesh.
  • However, students had performed miserably in 2009 test and India was placed at 72nd among 74 participating countries.
  • Government had blamed “out of context” questions for the poor results in 2009 and decided it won’t participate in 2012 and 2015.

 

Revision of Boycott decision

  • In 2016, HRD Ministry had revisited this decision and Kendriya Vidyalaya Sangathan (KVS) had set up committee to review matter and submitted its report in December 2016.
  • The report recommended for participation in test in 2018.
  • Similar recommendation was made in 2017 by group of secretaries on education constituted by Prime Minister Narendra Modi.
  • However, India had missed the application deadline for 2018 cycle of PISA test.

National Council for Teacher Education (NCTE)

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  • It is statutory body of Central Government set up under NCTE Act, 1993
  • Set up in 1995
  • It was set up to formally oversee standards, procedures and processes in Indian education system.
  • NCTE plans and co-ordinates the development of teacher education system throughout the country (for both central as well as state governments).
  • It also ensures the maintenance of norms and standards in the teacher education system.
  • Its headquarter is in New Delhi.

Institution of Eminence : Analysis

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Context
  • The Ministry of Human Resource Development has taken the decision to give Institution of Eminence (IoE) status to six institutes
 
The three pillars for growth (Make a diagram of these)
  1. Expansion
  2. Inclusion and
  3. Excellence
 
Research output of India among other countries
  • The growth of these and other national institutions will also depend on policies to raise the expenditure on R&D as a percentage of GDP.
  • Among countries with a comparable research output, India with 0.8% R&D spending trails Russia, Brazil, South Korea and even Singapore, according to UNESCO data.

 

ias4sure.com - Institution of Eminence Analysis

 

 
Issues at hand
  • It should be ensured that this conditional recognition is fulfilled transparently, and that it meets the requirements on governance structure, infrastructure and faculty within three years.
  • That there is need for urgent reform became clear during the selection process: the empowered committee found that State universities had a low output because some of them had several faculty members recruited on contract basis, with no incentive to do research.
  • Such ad hocism must end, and public universities should be insulated from political pressures.
  • Vice-chancellors should be appointed on merit, free of ideological biases.
  • With good governance structures and significant new financial grants, the selected public institutions will be able to innovate on courses and encourage research.
  • The quality is uneven, and at the bottom levels, abysmal.
  • At the same time, initiatives by charitable trusts — which have declined due to political support for commercialisation and aid cuts — must be welcomed, as this would help open more affordable colleges and universities.
 
Conclusion
  • The idea of developing centres of higher learning advances the Nehruvian vision of building ‘temples of modern India’.
  • Islands of eminence can inspire, but the long-term goal should be to raise the quality of higher education in all institutions through academic reform.
  • The Institution of Eminence (IoEs) can become models of autonomy, academic innovation and equity of access, and lead to a transformation of higher education.
 
Source:

Higher Education Commission of India Act 2018 (Draft)

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Context:

  • The government is set to replace the apex higher education regulator, University Grants Commission (UGC), with a higher education commission by repealing the UGC Act, 1951, for better administration of the HE sector.
  • Centre has placed in the public domain a draft Bill for eliciting suggestions from educationists.

The Draft Bill

  • The draft Higher Education Commission of India (Repeal of University Grants Commission Act) Act, 2018, takes away funding powers from the proposed regulator and gives it powers to ensure academic quality.
  • The new regime separates the academic and funding aspects of higher education.
  • While HECI will be in charge of ensuring academic quality in universities and colleges, the Ministry of Human Resource Development (MHRD) – or another mechanism that will be put in place later – will be responsible for funding universities and colleges.
  • Another key feature of the draft legislation is that the Regulator will have powers to enforce compliance to the academic quality standards and will have the power to order closure of sub-standard and bogus institutions.
  • Moreover, non-compliance could result in fines or even a jail sentence (Till now, the UGC had no such powers. All it could do was to release a list of bogus institutions and not recognise their degrees).
  • All institutions approved by the UGC will have to comply with the academic standards laid down by HECI within three years after the new law is passed by Parliament and notified by the union government. If an institution fails to do so, its approval will be revoked.

Composition

  • The HECI will have a Chairperson, a Vice-Chairperson and 12 other members to be appointed by the central government, including ex officio members, eminent academics and a doyen of industry.
  • Of the 12 members, three members will represent union government namely: secretary of higher education, secretary of ministry of skill development and entrepreneurship and secretary, department of science and technology.
  • The secretary of the commission will act as the member-secretary.

Functions

  • HECI is tasked with the mandate of improving academic standards with specific focus on learning outcomes, evaluation of academic performance by institutions, mentoring of institutions, training of teachers, promote use of educational technology, etc.
  • It will develop norms for setting standards for opening and closure of institutions, provide for greater flexibility and autonomy to institutions, lay standards for appointments to critical leadership positions at the institutional level irrespective of university started under any law.

Significance

  • The transformation of the regulatory set-up is based on the principles of minimum government and maximum governance, separation of grant functions, end of inspection raj and focus on the academic quality.
  • The draft Act is in accordance with commitment of the government for reforming the regulatory systems that provide more autonomy to higher education institutes to promote excellence and facilitate holistic growth of the education system.
  • UGC staff would be retrained to adapt to the HECI regime, which would be fully digital and do away with file work.

Other plans to reform Higher Education sector

  • Over the last four years, the HRD ministry has deliberated on several models like a single regulator for higher education by merging UGC, National Council of Teacher Education (NCTE) and All India Council for Technical Education (AICTE); however, the plans were not taken forward.
  • Once the HECI Bill is passed by Parliament, the technical education regulator AICTE and the teachers’ education regulator NCTE will also be reformed on similar lines.

Opposition to HECI:

  • All India University Employees Federation strongly opposed HECI.
  • The University Grants Commission (UGC) has served India’s higher education system for over six decades.
  • Named as the Higher Education Commission (HEC), this new institution will cover a considerable part of the UGC’s mandate, minus the latter’s financial role. This function will go to the Ministry of Human Resource Development (MHRD).
  • Not surprisingly, the academic world is apprehensive that the move will increase the power of the ministry to curb what little autonomy is left in the system of higher education.
  • The Yash Pal Committee never suggested that the UGC should be “scrapped.” The term it used was “subsumed,” pointing towards the need to let the UGC look after the crucial task of equitable distribution of funds, while a larger, essentially deliberative body looks after and encourages the long neglected task of building curricular and research bridges between different disciplines and disparate areas of higher professional learning.
  • What is now being contemplated is the transfer of the UGC’s financial role to the MHRD. This is contrary to the Yash Pal Committee’s recommendations, even though the idea of bringing certain areas of professional education under the proposed HEC partially echoes the committee’s report.

 

cna117

Private School Fees Issue

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What is the issue?
  • Regulating school fees is one of the most significant legal and political challenges policymakers in India face.
  • The issue of fee regulation finds itself at the intersection of constitutionally protected freedoms enjoyed by private schools and the need for making quality education affordable and accessible.
  • Over the years, the issue of skyrocketing tuition fees has confronted parents. Adding to their burden is the annual and steep hike in tuition fees along with additional costs such as fees for transport, extra-curricular activities and sports.
  • The managements of such schools claim that these hikes are reasonable and justified as the costs of maintaining a fully functional private school with quality teaching and world-class infrastructure are quite steep. In this context, balancing the autonomy of private schools and their public welfare function becomes a contentious issue.
 Facts:
  • There are around 3,50,000 private unaided schools (24% of all schools) where 75 million children or 38% of all students, study.
  • Such schools do not receive any grant from government and have to generate their own revenue for sustenance.
  • In Mumbai and Delhi, for instance, arbitrary fee hike in such schools in last year varied between 10 % and 40 %.

 

 

ias4sure.com - Private School Fees Issue
So can private schools arbitrarily hike fees?
  • In M.A. Pai Foundation v. State of Karnataka(2002), the Supreme Court held that regulatory measures imposed on unaided private educational institutions must, in general, ensure the maintenance of proper academic standards, atmosphere and infrastructure and the prevention of mal-administration by the school management.
  • Subsequently, in Islamic Academy of Education and Anr. v. State of Karnataka and Ors(2003), a Constitution Bench of the Supreme Court held that these institutions have the autonomy to generate surplus which must be used for their betterment and growth.
  • While private schools are ‘entitled to a reasonable surplus for development of education and expansion of the institution, there has to be a balance between autonomy of such institutions and the measures taken to prevent commercialisation of education’.
  • However, there is not much clarity on what the terms “surplus”, “reasonable surplus” or “commercialisation of education” entail.
 
Weak laws
  • In order to prevent private schools from charging unreasonably high fees and to prevent misuse of funds, several State governments have either enacted fee regulation laws or are in the process of framing them.
  • States such as Tamil Nadu follow the fee fixation model whereby a government committee is empowered to verify and approve fee structures proposed by private schools.
  • Karnataka is for a formula that caps fees for schools by way of framing rules under its school education legislation.
  • Maharashtra has a weakly enforced legislation to regulate fees and has multiple government bodies to approve school fees. Recently, the Maharashtra government’s decision to cap proposed fee hikes at 15% was widely criticised by schools.
  • A recent order of the Gujarat High Court upholding the validity of the Gujarat Self Financed Schools (Regulation of Fees) Act, 2017 is now being reconsidered by the Supreme Court. The court has directed the government to not take any coercive steps against schools in the interim period.
  • As of now, these models are affected by the challenges of weak implementation, a lack of capacity and constant legal challenges posed by private school associations.
  • There is a larger irritant which is entrenched in the way private schools operate. In 2010, the Comptroller and Auditor General slammed 25 well-known private schools in Delhi for arbitrary fee hikes.
  • According to the report, money was being collected from parents under false heads, while at the same time, teachers were being underpaid, and accounts misrepresented.
  • Existing legislative efforts have made an incomplete assessment of the deeper problems with financial management and accounting practices adopted by private schools.
 
Accounting standards
  • The new wave of fee regulation laws being debated and enforced in States has the potential to address the problems Indian parents face.
  • However, there is still a lack of jurisprudential clarity on what private schools can or cannot do, how much “surplus” they can make, or what “commercialisation” actually means.
  • In order to make these laws more effective, the solution would be to address the disease of financial mismanagement and misreporting, and not the symptoms. In Modern School v. Union of India(2004), the Supreme Court recommended accounting standards for private schools.
  • Further, measures such as regular government supervised audits, generating capacity in State-level Departments of Education, regular inspections, and stricter sanctions for fraudulent reporting could be considered.
 
National Commission for Protection of Child Rights (NCPCR) Draft  fee regulations:
  • Aim is to put in place uniform fee framework to check frequent and arbitrary increases in school fees by unaided private schools. 
  • It proposes 10% yearly cap on the fee hike permissible by private, unaided schools.
  • It suggests setting up district fee regulatory authority in states to monitor school fee increases.
  • It suggests formula for determining fees, based on school’s location, costs incurred, revenue earned, student strength and other parameters.
  • It proposes fines on schools if they violates uniform fee framework. These schools will be fined 1% of revenue it generates for first instance of violation of these rules and it will increase to 2 % and 5% for second and third violation.
  • For any subsequent violation, it proposes to place school in no admission category and bar it from admitting new students.
  • Note: The regulation of education-related matters is domain of HRD ministry, but NCPCR has stepped in to draft fee regulations for unaided schools, citing Section 13 of Commission for Protection of Child Rights (CPCR) Act, 2005 and Section 32 of Right to Education (RTE) Act, which gives it authority to review safeguards under law to protect of child rights and recommend measures.
 
Source:

Higher Education

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Facts:

  • The Gross Enrolment Ratio (GER) in higher education of Indian has registered an increase from 10% in 2004-05 to 25.8% in 2017-18according to latest All India Higher Education Survey (AIHES) released by HRD Ministry.
  • India is aiming to attain GER of 30% by 2020, but it is still far behind countries like China with GER of 43.39% and US with 85.8%.
  • GIAN – project to rope in eminent scholars from abroad to teach at Centrally-funded institutions (Global Initiative of Academic Network)

The report on the annual status of higher educational universities and colleges in India pointed out that, states that lay more emphasis on the quality and depth of their higher education are economically better placed than those that do not. Analyse the reasons behind this linkage? What initiatives must the states take to improve higher education in the country? (200 Words)

Knowledge based competition within a globalising economy is prompting a fresh consideration of the role of higher education in economic development and growth There is a positive correlation between investment in higher education and economic growth of a state (directly and indirectly)

  1. It helps in rapid industrialization by providing manpower with professional, Technical and managerial skills.
  2. In present context of transformation of nations into knowledge economies and knowledge societies, it provides not just educated workers but knowledge workers to the growth of economy
  3. It creates attitudinal changes necessary for the socialization of individuals and overall transformation of society
  4. Higher education contributes through the ―production of knowledge‖ and that largely takes place within major universities and their research
  5. Helps in creation of new technology which contributes to the economy of the state
  6. Higher education leads to economic growth through both private and public channels. Higher earnings for well-educated individuals raises tax revenues for governments and eases demands on state finances. They also translate into greater consumption, leading to greater production and a demand-driven economy.
  7. In addition, the larger tax base reduces the tax pressure on low-income members
  8. A more educated workforce gives a higher output per worker in 2 ways
    1. Higher education adds more skill to workforce
    2. Increases the capacity to innovate
  9. The growth of science-based industries also means that economic development depends on highly educated and scientifically trained labour
     

Initiatives to improve higher education :

  1. Instead of funding public colleges and universities based on enrollments, states should use a formula that pays institutions for success in key areas like progress toward and completion of degrees and credentials, research
  2. Promoting technical and vocational universities
  3. Promoting private investment in higher education
  4. Establishment of more centers of excellences.
  5. International collaboration and student exchange programmes
  6. Promoting industrial participation in designing different vocational and technical courses so that demand based skills are acquired.
     

Thus along with promoting primary and secondary education, there is also a need for states to promote higher education which brings not only a higher economic growth but also social and other returns.

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“The perverse kind of political interference that routinely takes place in higher education is one of the primary reasons that the best of India’s colleges and universities lag behind.” Examine the causes of political interference, its implications and solutions to the problem. (200 Words)

Political interference is not new to the education system especially higher education. The FYUP of the Delhi University is a clear evidence of this. There are many causes for this problem:

  1. The one-upmanship of the executive, corruption, student’s connection with political groups like ABVP etc.
  2. The lack of transparency, accountability among the hierarchy of the higher education system allowing political interference.
  3. Ideological differences of the parties pushing for changes in discipline like history etc.
  4. Accreditation system, allotting deemed or other status to a college etc. are ridden with lobbying from the University or college authorities pulling political influence into the system.
  5. Issues in appointments, system of functioning of autonomous bodies like IITs, IIMs etc. drawing comments and opinions from politicians.

Implications of the political interference are:

  • lack of competence, collaboration and coordination in the higher education,
  • failure in governance of the universities or colleges leading to reduction in standards,
  • performance of students,
  • No vibrant growth like foreign universities with multiple disciplines and autonomy of subjects/courses,
  • rise in corruption, personal rivalry among  authorities etc.

It is good governance, transparency, accountability which must be ensured, sufficient autonomy and enforcing discipline among the university authorities coupled with reforms like freedom to choose courses, refrain from making college issues political, better financial autonomy which are needed for efficient functioning of Higher education system in India.

An intense debate is going on the Union government’s proposal to revive the Central Universities Act of 2009 which will require the Central universities to follow a common admission procedure and common syllabus. Analyse the issue and critically comment if following a common syllabus is good for higher education sector in India. (200 Words)

Higher education is going through a difficult phase on various fronts namely both quality as well as quantity along with research and innovation to name a few. As a result no Indian University is in the list of top 200 universities in the world. In this perspective Union government have proposed to revive the Central Universities Act of 2009

This Act has the following objectives:

  1. Mandate a common admission procedure and common syllabus for all universities.
  2. Transfer policy for faculty as in they can be transferred between different universities.
  3. It may mandate all universities to initiate CBCS.
  4. Provide an opportunity to the below average universities to improve upon their quality

Advantages:

  1. They make it feasible to measure and rank universities.
  2. Since, most of the universities in metropolitan cities are better served with distinguished faculty and expertise, it provides a level playing field to all universities due to faculty mobility
  3. Framing syllabus to meet industry requirements, focus on skill development of students
  4. Students have to fill single form instead of plethora of forms and have to prepare for single test with on specified syllabus.
  5. New universities will have greater chance of getting good students and faculty due to provisions of mobility
  6. All universities have to complete their accreditation with NAAC. This is a good step as it will ensure adherence to required specification.
  7. Provisions for a Central university teacher recruitment board that will set standards for assistant professor after qualifying NET. This will ensure quality of teachers as required qualification will be an improvement of minimum being NET qualified which is currently in practice.
  8. Academic and research activities will be subjected to external review. Students will be allowed to participate in this review.

Issues:

  1. The act centralises and homogenises education completely ignoring the specialisation and uniqueness and diversity of each university. Universities in N-E are created to cater to students of that region, JNU was created to promote national values, humanism etc., DU was created to provide education along diverse subjects, common syllabus will take away special character of these universities
  2. Transfer policy is detrimental to academics. Research requires long time presence of the faculty. Secondly, it has potential to silence dissent of faculty. Transfer of faculty will increase the possibility of vindictiveness as it is a punitive measure to silence the dissent and independent voices.
  3. Further this will be impact research and innovation which is already very low in the country. Faculties specializing in different fields and researchers will lose the zeal to practice and promote their field with enthusiasm owing to limited domain as a result of common syllabus. This will further impact and deter the growth of higher education on qualitative aspects.
  4. Common syllabus will do more harm than good. Indian institutions presently are termed as “islands of excellence and oceans of mediocrity” which might turn into “oceans of mediocrity” as a result of common syllabus. This will result in further lowering the qualitative aspects of education and its excellence.
  5. Loss of Autonomy again due to common syllabus.
  6. Due to 35% of vacant teaching posts, universities are already breaching the global teacher-pupil ratio; mobility of students will not be helpful in this case

What are the challenges private universities have posed to higher education in India? Should they be strictly regulated? Critically comment. (200 Words)

Challenges posed by private universities:

  • arbitrary admission criteria, capitation fees and vested interests dominate these universities
  • they spread misinformation among students about recognition, faculty, course structure and quality. These leads to fake degrees and unrecognised qualifications causing problems for students when they pass out and enter job market.
  • Political patronage and nexus promotes setting up of these universities flouting standard norms and criteria.
  • Poor quality of teaching, infrastructure, labs and practical impedes genuine learning at these universities
  • The financial criteria denies the poor and underprivileged students admissions leading to inequity in education

Regulation:

  • NCHER bill needs to be passed to setup a strong assessment, accreditation, rating and regulatory framework in the country. Universities not adhering to prescribed standards should be de-recognised while strong regular monitoring should be done for the rest
  • Grievance redressal, counselling, prior information, strict checking on correctness of online ad contents, quick action on complaints and monitoring of financial irregularities and frauds are some steps which need to be urgently taken.
  • For accreditation: NAAC and NBA (National Board of Accreditation) could be strengthened