Mohini Jain vs State of Karnataka (1992) – Right to Education & Capitation Fee
In this landmark decision, the Supreme Court of India treated education as part of the Right to Life under Article 21 and struck down the practice of charging capitation fees in professional colleges.
mohini-jain-vs-state-of-karnataka-1992
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Quick Summary
CASE TITLE: Mohini Jain vs State of Karnataka, 1992
In this case, a young student, Mohini Jain from Meerut, challenged the demand of a huge capitation fee by a private medical college in Karnataka. She argued that such a fee makes professional education available only to the rich and shuts the door on students from middle-class and poor families.
The Supreme Court of India held that the Right to Education is an integral part of the Right to Life under Article 21. The Court further held that the system of charging capitation fee in professional colleges is unconstitutional as it violates Article 14 (equality) and ignores the spirit of Article 41 and the Karnataka Educational Institutions (Prohibition of Capitation Fee) Act, 1984.
The Government notification that allowed private medical colleges to charge capitation fee was struck down. However, Mohini herself did not get admission because she was not in the merit list and the course had already started.
Issues Before the Court
- Whether the Karnataka Government’s 1989 notification allowing private medical colleges to charge capitation fee was valid or unconstitutional, especially in light of the Karnataka Educational Institutions (Prohibition of Capitation Fee) Act, 1984.
- Whether making admission to professional education dependent on payment of very high capitation fee violates the Right to Equality under Article 14.
- Whether the Right to Education can be read as part of the Right to Life under Article 21.
- How far the Directive Principles, especially Article 41, guide the State in providing access to education.
Rules & Legal Provisions Applied
| Article 21 | Right to Life includes the Right to Live with Dignity. The Court held that dignity is empty without reasonable access to education. |
| Article 14 | Prohibits arbitrary and discriminatory State action. A system that allows only rich students to buy education through capitation fee violates equality. |
| Article 41 | A Directive Principle that expects the State to make effective provision for education, within its economic capacity. It guides the interpretation of Fundamental Rights. |
| Karnataka Act, 1984 | Karnataka Educational Institutions (Prohibition of Capitation Fee) Act, 1984 – Section 3 prohibits capitation fee; Section 4 prescribes penalties. |
| 1989 Notification | Government notification permitted private medical colleges to charge capitation fee for certain seats. The Court examined its validity against the 1984 Act and the Constitution. |
| Capitation Fee | An extra, often very high, amount charged by institutions at the time of admission, over and above regular fees – working like a compulsory donation. |
Facts – Timeline Style
Before 1984 – Growing Commercialisation
Private professional colleges, especially medical colleges, began to demand large sums of money from students in the name of donations or capitation fees. This made admission depend more on money than on merit.
1984 – Karnataka Capitation Fee Act
To control this practice, Karnataka enacted the Karnataka Educational Institutions (Prohibition of Capitation Fee) Act, 1984, which in principle banned capitation fee and provided penalties for violations.
1989 – Government Notification
Despite the 1984 Act, the Karnataka Government issued a 1989 notification allowing private medical colleges to charge high capitation fees for certain categories of seats, especially for non-Karnataka students.
Mohini Jain’s Application
Mohini Jain, a middle-class student from Meerut, Uttar Pradesh, applied for admission to a private medical college in Karnataka. The college asked her to pay regular tuition fees plus around Rs. 60,000 as capitation fee per year.
Inability to Pay & Petition
Mohini could not afford this huge amount. She felt that education was being reserved only for those who could pay. She approached the Supreme Court of India, challenging the notification and the fee structure.
Grounds of Challenge
She argued that the notification conflicted with the 1984 Act, and that making education dependent on money violated Article 14 (equality) and Article 21 (right to life with dignity).
1992 – Supreme Court Decision
The Supreme Court delivered a landmark judgment in 1992. It declared the capitation fee system unconstitutional, recognised Right to Education as part of Article 21, and struck down the 1989 notification.
Arguments – Appellant vs Respondent
Appellant – Mohini Jain
- Capitation fee is an unlawful extra charge that turns education into a saleable commodity instead of a right.
- The 1989 notification goes directly against the 1984 Capitation Fee Act, which bans such fees; therefore the notification is ultra vires (beyond the powers of the State).
- Requiring huge payments for admission creates a class-based barrier – rich students can buy seats, while poor and middle-class students are excluded. This is arbitrary and discriminatory, violating Article 14.
- Without access to education, a citizen cannot live with dignity. So Right to Education must be treated as an essential part of the Right to Life under Article 21.
- The State is constitutionally guided by Article 41 to provide education within its capacity. Allowing capitation fee contradicts this duty and widens the gap between rich and poor.
Respondents – State of Karnataka & Colleges
- Private medical colleges need large funds to run laboratories, hospitals, and other facilities. Capitation fee is a way to raise resources without overburdening the State.
- The 1989 notification was issued to regularise and control the fee structure, not to encourage exploitation. It fixed the amount and categories to make the system more transparent.
- They argued that education, especially professional education, is not fully a fundamental right and can be subject to reasonable regulation, classification, and fee structures.
- It was also contended that since Directive Principles like Article 41 are not enforceable by courts, the State should have flexibility in designing fee policies.
- On facts, they pointed out that Mohini was not in the merit list and the academic session had already started, so she could not claim a personal right to admission.
Judgment of the Supreme Court
The Supreme Court held that the practice of charging capitation fee in educational institutions is unconstitutional. The Court read the Right to Education into Article 21, stating that the Right to Life means more than mere animal existence and includes the right to live with dignity. Education is essential for dignity, self-development, and meaningful participation in society.
The Court found that the 1989 Karnataka notification permitting capitation fee was inconsistent with the 1984 Capitation Fee Act as well as the Constitution. The notification allowed private colleges to divide students into categories and charge capitation fees from some categories, especially non-Karnataka students. This created an unreasonable classification and violated Article 14.
According to the Court, allowing education to be purchased by money destroys the value of equality and treats education as a purely commercial product. The State cannot permit a scheme where ability to pay becomes more important than merit or need.
Therefore, the Court:
- Declared that the Right to Education flows directly from Article 21.
- Held the capitation fee system unconstitutional and struck down the 1989 notification.
- Clarified that the State must ensure fair and non-exploitative access to education.
However, the Court did not grant personal relief to Mohini Jain. She was not selected on merit, and the academic year had already begun. Disturbing ongoing admissions would have harmed other students, so the Court limited the relief to a declaration of law.
Ratio Decidendi – Core Legal Principle
- Right to Education is a fundamental right because it is necessary for effective enjoyment of the Right to Life under Article 21. Life with dignity is impossible without reasonable access to education.
- Any fee structure which makes education available only to those who can pay large sums of money is arbitrary and discriminatory and therefore violates Article 14.
- The State’s power to regulate education must be exercised in harmony with its constitutional duties under Article 41 and other Directive Principles, which urge the State to provide education within its capacity.
- The 1989 Karnataka notification, allowing capitation fee, was inconsistent with the 1984 Capitation Fee Act and the Constitution, and was therefore liable to be struck down.
Why This Case Matters
Student FocusThe judgment in Mohini Jain is important because it was one of the first times that the Supreme Court strongly and clearly recognised education as a fundamental right. It changed the way we look at education in India. Education was no longer treated as a private luxury; it was seen as a basic requirement for a meaningful life.
The decision also sent a clear message against the commercialisation of education. By declaring capitation fee unconstitutional, the Court warned both the State and private institutions that they cannot treat students as customers and seats as products.
Later, this case became an important stepping stone for:
- Unnikrishnan vs State of Andhra Pradesh (1993), which refined the scope of the Right to Education.
- The Right of Children to Free and Compulsory Education Act, 2009 (RTE Act), which gave statutory shape to the right of children aged 6–14 years to free and compulsory education.
Key Takeaways for Students
- Right to Education = Part of Article 21: The case firmly connects education with the Right to Life and dignity.
- Capitation Fee is Unconstitutional: Any system that sells seats to the highest bidder is against Articles 14 and 21.
- State Cannot Ignore its Duty: Article 41 and other Directive Principles push the State to expand access to education, not restrict it.
- Merit vs Money: Admission based mainly on payment of money is discriminatory and destroys the idea of merit-based education.
- Foundational Case: Mohini Jain laid the base for later cases and the RTE Act, 2009.
Mnemonic + 3-Step Exam Hook
Mnemonic: “MOHINI”
Think of MOHINI as:
- M – Money-based admission banned (capitation fee unconstitutional)
- O – Opportunity for all (education not only for the rich)
- H – Human dignity under Article 21
- I – Inequality rejected (Article 14 violation)
- N – Notification struck down (1989 Karnataka notification)
- I – Inspired later RTE cases and RTE Act, 2009
3-Step Hook for Writing Answers
- Step 1 – Start with Principle: “In Mohini Jain vs State of Karnataka (1992), the Supreme Court held that education is part of the Right to Life under Article 21.”
- Step 2 – Connect with Facts: Briefly mention the medical college, huge capitation fee, and the 1989 Karnataka notification.
- Step 3 – Conclude with Impact: Write that capitation fee is unconstitutional, the notification was struck down, and the case paved the way for later Right to Education developments.
IRAC Outline – Exam-Friendly Structure
I – Issue
- Is the Right to Education a fundamental right under Article 21?
- Is the capitation fee system in private medical colleges constitutional?
- Is the 1989 Karnataka notification consistent with the 1984 Capitation Fee Act and Articles 14 and 21?
R – Rule
- Article 21 – Right to Life includes life with dignity.
- Article 14 – State cannot act arbitrarily or create unreasonable classifications.
- Article 41 – Directive Principle guiding the State to provide education within its resources.
- Karnataka Educational Institutions (Prohibition of Capitation Fee) Act, 1984 – prohibits capitation fee and provides penalties.
A – Application
- High capitation fee made medical education accessible mainly to the rich; this failed the test of equality under Article 14.
- Without education, citizens cannot effectively enjoy their rights or live with dignity; therefore, education is read into Article 21.
- The 1989 notification allowing capitation fee contradicted the 1984 Act that aimed to prohibit such fees, making the notification ultra vires.
C – Conclusion
- Right to Education is a fundamental right derived from Article 21.
- The capitation fee system is unconstitutional as it violates Articles 14 and 21.
- The 1989 Karnataka notification was struck down, and the State was reminded of its duty to make education accessible and non-commercial.
Glossary – Simple Terms from the Case
- Capitation Fee
- An extra and usually very high amount charged by an educational institution at the time of admission, in addition to normal tuition fees. It works like a compulsory donation and often decides who gets admission.
- Right to Education
- The idea that every person should have reasonable access to education. In this case, the Court treated it as part of the Right to Life under Article 21.
- Right to Life (Article 21)
- A Fundamental Right that protects life and personal liberty. The Court has interpreted it to include living with dignity, which requires education, health, and other basic needs.
- Article 14 – Equality
- A constitutional guarantee that the State shall not deny equality before law or equal protection of laws. It forbids arbitrary or unfair discrimination.
- Article 41
- A Directive Principle that encourages the State to provide work, education, and public assistance within its economic capacity. It is not directly enforceable in court but guides policy and interpretation.
- Ultra Vires
- A Latin term meaning “beyond the powers.” When a law or notification goes beyond the authority given by a parent statute or the Constitution, it is called ultra vires.
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