Case: Unnikrishnan J.P. v State of Andhra Pradesh (1993)
Date of Order / Judgment: 6th August, 2024
The Matter Heard by Bench: Justice K. Ramaswamy, Justice M.N. Venkatachaliah, Justice J.S. Verma, Justice B.L. Hansaria,
Justice S.P. Bharucha
Background
The landmark case of Unnikrishnan J.P. v. State of Andhra Pradesh (1993) addressed the
fundamental right to education in India. The petitioner, Unnikrishnan J.P., challenged the adequacy
and quality of education provided by the government and sought to establish the right to education
as a fundamental right under the Indian Constitution. The case was heard by a Constitution Bench of
the Supreme Court of India.
Issues
- 1. Whether the right to education is a fundamental right under the Indian Constitution.
- 2. The extent and nature of the state's responsibility to provide education.
- 3. Whether the provisions related to education in the Constitution require a certain standard
or level of education.
Observation:
- 1. Constitutional Interpretation: The Supreme Court observed that while the Constitution of
India does not explicitly recognize the right to education as a fundamental right, the
Directive Principles of State Policy (DPSPs) under Article 45 of the Constitution emphasize
the importance of free and compulsory education for children.
- 2. Right to Life and Education: The Court interpreted Article 21, which guarantees the right to
life and personal liberty, as encompassing the right to a meaningful and adequate education.
The judgment highlighted that the right to life under Article 21 should include the right to
education, as education is essential for the development of a person’s dignity and capability.
- 3. State Obligation: The Court emphasized that it is the duty of the State to provide education
to all children, particularly in the context of promoting equality and social justice.
Decision:
The Supreme Court ruled that the right to education is indeed a fundamental right derived from the
right to life under Article 21 of the Constitution. The judgment mandated that the State must
provide free and compulsory education to children up to the age of 14 years. The Court directed that
the State must take necessary steps to ensure that education is accessible to all, and that it should
be of a quality that meets reasonable standards.
This landmark decision significantly influenced subsequent legal and policy developments in India.
Consequently, the 86th Amendment to the Indian Constitution was enacted in 2002, which inserted
Article 21A. This amendment explicitly recognized the right to education as a fundamental right,
guaranteeing free and compulsory education to children aged 6 to 14 years. This constitutional
provision aligned with the Supreme Court’s interpretation in the Unnikrishnan case and reinforced
the State’s obligation to ensure educational opportunities for all children.