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Judicial Exemptions For Minority Institutions Under RTE 2009: Balancing Article 30 Rights With Article 21a Obligations In Post-Pramati Jurisprudence




Sarita Kumari, Christ (Deemed to be University) Lavasa, Pune


ABSTRACT


This paper examines the critical link between India's Right of Children to Free and Compulsory Education Act, 2009 ("RTE Act") and the constitutional rights of minority institutions under Article 30(1). RTE implements Article 21A by mandating free education and a 25% reservation for weaker sections in private schools (Sec. 12(1)(c)), but Article 15(5) (93rd Amendment) explicitly exempts minority schools from such reservations . In Pramati Educ. & Cult. Trust v. Union of India (2014) the Supreme Court upheld RTE's validity but held that its provisions do not apply to aided or unaided minority schools . We survey post-Pramati case law up to 2026 – including Azad Education Society v. Maharashtra (Bombay HC, 2017), M.A. Stephen Sundar Singh v. Tamil Nadu (Madras HC, 2019), Anjuman Isha'at-e-Taleem Trust v. Maharashtra (SC, 2025), and others – that interpret this exemption.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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