INTRODUCTION
Language serves as far more than an instrument for expressing information since it represents cultural customs as well as personal and societal connections. The language strategy within India plays a pivotal role in constitutional and educational discussions of this linguistically rich nation. The Three-Language Formula (TLF) stands at the core of the National Education Policy (NEP) 2020 to advance multilingualism through regional identity preservation and national unity. The NEP 2020 provides states and learners with flexible and autonomous frameworks by ensuring that no language requirements will be enforced on any specific region. Educational justice perspectives in this blog encompass an analysis of India’s language policy constitutionality, alongside its historical development and implementation challenges, and the legal standing of the Three-Language Formula.
HISTORICAL BACKGROUND
The Kothari Commission introduced the TLF concept during 1964-66, which became official through the National Education Policy, 1968.[1] Students in Hindi-speaking regions were required to study Hindi as well as English and one modern Indian language from Southern India, and those in non-Hindi-speaking states were required to study their regional language and Hindi along with English. The primary goal of the policy was to create cultural unity across different linguistic groups. The implementation process demonstrated several differences depending on the state. Tamil Nadu chose to abandon the formula and enforced a new two-language policy.[2]
The National Education Policy of 1986 upheld the three-language formula, yet remained uneven and partially effective.[3] The Kasturirangan Committee’s 2019 draft NEP caused discord through its perceived requirement for Hindi usage until public resistance led to its revision to “Modern Indian Language.”[4] NEP 2020 advances educational practices by introducing educational autonomy and removing language enforcement protocols.[5] The new rule specifies that students need to learn two Indian languages and be taught in their home language during the initial five years before extending it to Grade 8.
CONSTITUTIONAL FRAMEWORK
The Indian Constitution establishes a comprehensive language system that enables the development of a common national language while also protecting regional dialects. The Three-Language Formula (TLF) under NEP 2020 draws its constitutional backing from provisions in Part XVII (Articles 343–351) and Articles 350A and 350B, which establish the goal of protecting and developing India’s diverse language system.[6]
- Official Language of the Union and States
Article 343 declares that Hindi written in Devanagari script stands as the sanctioned language of the Union and permits the continued functional use of English through perpetual legislative extension.[7]
The legislature of a state holds the authority, through Article 345, to establish any combination of one or more state languages or Hindi as the official language of that state.[8] States have the authority to implement their regional languages in governance and education while preserving their right to self-governance.
These constitutional provisions establish Hindi as a key language element while preserving state autonomy, which makes it constitutionally inappropriate to implement a uniform language regulation for all states.
- Directive for Promotion of Hindi
Article 351 directs the Union to promote the spread of Hindi while advancing its development into a unifying expression of Indian cultural rudiments.[9] There is a requirement for careful management because it must coincide with protecting and preserving the various languages spoken across different Indian regions.
While Article 351 encourages the use of Hindi, it is a Directive Principle, not an enforceable mandate, and must coexist with other fundamental rights and constitutional provisions.
- Educational and Linguistic Rights of Minorities and Citizens
All states under Article 350A must establish proper educational facilities for minority language instruction during the initial educational period for students from linguistic minority backgrounds.[10] This rule directly aligns with the educational goals of NEP 2020, which stipulate that students should learn in their native language as a medium until at least Grade 5 and preferably until Grade 8.
The president appoints a Special Officer for Linguistic Minorities through Article 350B to perform investigations and produce reports regarding protective measures for minority languages.[11] The constitution explicitly supports equal linguistic equity through this provision.
Article 29(1) safeguards the right of any section of citizens to conserve their distinct language and cultural practices.[12] The constitutional provision bars any homogenizing language policy that could damage regional identities that are protected by law.
- Eighth Schedule – Recognised Languages
The Eighth Schedule to the Indian Constitution incorporates 22 languages as the “Scheduled Languages” of India.[13] The enumeration includes both classical languages and regional languages that have been given official recognition by the Constitution. The NEP 2020’s mention of “Modern Indian Languages” corresponds to these 22 languages, thus providing a neutral basis for choosing languages under the TLF, without necessitating the use of any language.
IMPLEMENTATION CHALLENGES
Despite progressive intent, the implementation of the TLF remains uneven and fraught with challenges:
- Lack of Trained Teachers: Especially in tribal and rural areas, a shortage of multilingual teachers has hindered effective instruction in mother tongues.[14]
- Textbook Deficiency: In several dialects and minority languages, quality educational materials are either unavailable or delayed in development.
- Resistance from States: Tamil Nadu and parts of Karnataka have consistently rejected the TLF as an instrument of Hindi imposition, asserting that it threatens their linguistic identity.
- Linguistic Burden on Students: For tribal students, learning three unfamiliar languages (regional, Hindi, and English) creates cognitive overload and increases dropout rates.
- Language and Identity Conflict: Critics argue that despite policy safeguards, the promotion of Hindi under Article 351 can be seen as linguistic centralisation, threatening civil harmony and regional identity.[15]
LEGAL AND POLICY DEBATES
The NEP 2020 attempts to address past criticisms by granting greater autonomy in language selection. However, constitutional concerns persist:
- The directive in Article 351 to promote Hindi must be harmonised with Article 345, which empowers states to decide their official language. This legal tension underlies the federal resistance to centrally proposed language models.
- Language as an identity marker, protected under Article 29, adds another layer. Any policy perceived as threatening regional linguistic heritage may face constitutional challenges.
- The lack of a binding enforcement mechanism for NEP provisions further weakens the TLF’s practical reach, making it more of a guiding principle than a statutory requirement.
JUDICIAL AND ADMINISTRATIVE PERSPECTIVES
While courts have not directly ruled on the constitutionality of the TLF, broader rulings support multilingual inclusivity:
- In the judgement of State of Karnataka & Anr v. Associated Management of (Government Recognised – Unaided – English Medium) Primary & Secondary Schools & Ors (2014),[16] The Supreme Court of India upheld the autonomy of parents and private institutions, reiterating that the State is not entitled to impose the medium of instruction, even if it is shown as part of the educational policy. The Court acknowledged the parental and student choice of the medium of instruction as a fundamental element of their right to freedom of speech and expression provided by Article 19(1)(a) and the right to education under Article 21A, thus restricting the Government’s regulatory powers in this area.[17]
- The Right to Education Act, 2009, although silent on language, implies the need for culturally accessible education.[18]
The absence of binding litigation on the TLF leaves room for states to exercise discretion, albeit within the constitutional bounds of Articles 29, 350A, and 351.
WAY FORWARD
To align constitutional principles with practical implementation, the following measures are proposed:
- Flexibility in Language Choice: Recognise linguistic diversity by allowing region-specific adaptations, including bilingual instead of trilingual models where appropriate.
- Teacher Training & Curriculum Development: Invest in recruiting and training multilingual teachers, especially in tribal and remote regions.
- Technological Integration: Use AI-based translation tools and digital resources to support multilingual content creation.
- Community Participation: Encourage community-led schooling models that respect local linguistic traditions, ensuring better retention and relevance.
- Legal Clarification: Codify the language policy framework via a central model law, respecting state flexibility while guiding implementation.
CONCLUSION
India’s Three-Language Policy under NEP 2020 presents a noble vision—one that aspires to harmonise national unity with linguistic plurality. Its success, however, hinges on nuanced execution, constitutional respect, and collaborative federalism. Rather than being a tool of linguistic imposition, it must evolve into an enabler of cognitive growth, cultural pride, and inclusive education. If implemented with empathy and equity, the TLF can truly become a cornerstone of India’s multilingual democracy.
Author(s) Name: Pritam Sen (CHRIST(Deemed to be University), Delhi NCR)
References:
[1] Kothari Commission Report 1964–66, Education and National Development: Report of the Education Commission 1964–66 (Ministry of Education, Government of India)
[2] Ministry of Human Resource Development, National Policy on Education 1986 (Government of India)
[3] ibid
[4] K Kasturirangan and others, Draft National Education Policy 2019 (Committee for the Draft NEP, Government of India)
[5] Ministry of Education, National Education Policy 2020 (Government of India)
[6] Constitution of India 1950, arts 343–351, 350A, 350B
[7] ibid art 343
[8] ibid art 345
[9] ibid art 351
[10] ibid art 350A
[11] ibid art 350B
[12] ibid art 29(1)
[13] ibid Eighth Schedule
[14] Lumina L, ‘A Critical Analysis on New National Education Policy’ (2024) 9(2) International Journal of Novel Research and Development 37 <https://www.ijnrd.org/viewpaperforall.php?paper=IJNRD2402005> accessed 6 June 2025
[15] Lumina (n 14)
[16] State of Karnataka & Anr v Associated Management of (Government Recognised – Unaided – English Medium) Primary & Secondary Schools & Ors (2014) 9 SCC 485
[17] Constitution of India 1950, arts 19(1)(a), 21A
[18] Right of Children to Free and Compulsory Education Act 2009, s 29
