Mohini Jain v State of Karnataka (1992): Right to Education and Capitation Fees Explained

The Mohini Jain case is one of the most important judgments in Indian constitutional law. It was the first case in which the Supreme Court recognized that the right to education is a fundamental right under Article 21 of the Constitution.

This case also dealt with the issue of capitation fees charged by private medical colleges and their constitutional validity.

Read the full constitutional framework here:

Reservation and Autonomy of Educational Institutions in India: Constitutional Framework

📚 Background of the Case

During the late 1980s and early 1990s, private medical colleges in India charged very high capitation fees from students who were not admitted under government quota.

The Karnataka government allowed private colleges to charge higher fees from students outside the state quota.

This created discrimination between students based on their financial capacity.

👩 Facts of the Case

Mohini Jain, a student from Uttar Pradesh, applied for admission to a private medical college in Karnataka.

The college demanded a capitation fee of approximately ₹60,000 per year, which was extremely high at that time.

She challenged the fee structure in the Supreme Court, arguing that it violated her fundamental rights under Articles 14 and 21.

⚖️ Legal Issues Before the Supreme Court

The Supreme Court examined the following key issues:

• Whether the right to education is a fundamental right under Article 21.
• Whether charging capitation fees violates the right to equality under Article 14.
• Whether the state can permit private institutions to charge arbitrary fees.

🏛️ Arguments Presented

Petitioner’s Arguments

• Capitation fees create inequality based on wealth.
• Education is essential for exercising fundamental rights.
• The fee structure violated Articles 14 and 21.

Respondent’s Arguments

• Private institutions have the right to charge fees.
• The government had authority to regulate admissions.
• Education was not explicitly mentioned as a fundamental right.

👨‍⚖️ Supreme Court Judgment

The Supreme Court ruled in favor of Mohini Jain.

The Court held that the right to education is part of the right to life under Article 21.

The Court also held that charging capitation fees violates the Constitution.

⚖️ Key Observations of the Court

• The right to life includes the right to live with dignity.
• Education is essential for human dignity.
• Without education, other fundamental rights cannot be exercised effectively.
• Charging capitation fees creates unfair discrimination.
• Education cannot be treated as a commodity.

📜 Constitutional Provisions Discussed

• Article 14 – Right to Equality
• Article 21 – Right to Life
• Directive Principles relating to education

📊 Impact of the Judgment

This judgment had far-reaching consequences.

• It recognized education as a fundamental right.
• It restricted arbitrary fee structures.
• It strengthened state responsibility in education.
• It influenced future judgments like Unni Krishnan case.

⚖️ Criticism and Later Developments

Some critics argued that the judgment imposed excessive restrictions on private institutions.

Later, in the Unni Krishnan case (1993), the Supreme Court partially modified this judgment.

However, Mohini Jain remains historically important.

📚 Importance for Law Students and Judiciary Aspirants

This case is frequently asked in constitutional law examinations.

It is important for understanding the evolution of the right to education.

It laid the foundation for Article 21A.

📌 Conclusion

The Mohini Jain case marked a turning point in Indian constitutional law.

It established that education is essential for human dignity and fundamental rights.

This judgment laid the foundation for modern education law in India.

❓ Frequently Asked Questions (FAQs)

1. What was decided in Mohini Jain case?

The Supreme Court held that the right to education is a fundamental right under Article 21.

2. Why was capitation fee declared unconstitutional?

Because it created inequality and violated Articles 14 and 21.

3. How did Mohini Jain case affect education law?

It established education as a fundamental right and influenced future judgments.

4. Which Article provides right to education?

Initially Article 21 through interpretation, later Article 21A was added.

5. Which case modified Mohini Jain judgment?

The Unni Krishnan case (1993) clarified and modified it.

6. Why is Mohini Jain case important for exams?

It is a landmark judgment in constitutional and education law.

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