The themes of Governance, Regulation & Quality constitute the core of the superstructure of a national policy framework on education. Nonetheless, the National Education Policy fails to impress when it comes to this triad. One gets literally cowed down to witness that a policy document of immense national importance retorts to the simplistic methodology of passing the buck to posterity by being abridged in treatment or selective in response.

Governance

The original consultation brief was more nuanced as it expected to talk about Governance Reforms for Quality which the Policy Draft chose to rechristen as Governance Reforms in Higher Education whereby a wide array of unconnected subject matters have been straddled, the purpose and logic of it is difficult to decipher. The must-have commentary on the structural definition of the vast array of India's Higher Education has been left out in its entirely which alone could have created a framework for handling the unprecedented expansion accompanied by diversification of the sector and to make the unplanned expansion of the sector assume an organic evolutionary nature. 

The policy draft talks about contextualizing the statutory position for any perspective on governance and regulatory issues in the sub-sector. The reader gets appalled as as to what are the various contexts and which are the agencies to undergo this top-line exercise? If a highly empowered National Education Policy draft document can't lay the context of country's education or even suggest the various possible scenarios to deliberate upon, the entire hue and cry over the NEP formulation would certainly end up in vain.

Education Commission: Panacea for all Unimaginative Governance

Establishment of an Education Commission to assist MHRD is being suggested as the foremost policy initiative for effective educational governance. It sounds strange and suggests as if the ministry has not been privy to a horde of academic councils and commissions already to steer through the direction of India's forward looking education. This bland bureaucratic response of constituting yet another commission rather than setting the accountability and functions of the already existing ones, doesn't impress at all. It certainly emboldens the concerns of the perpetual shackling of education amidst bureaucratic homilies. What new would be in the structure and composition of this Commission, which shall catapult the national aspirations all of a sudden to a different trajectory of innovation & imagination? The policy draft has chosen to keep those mantras gupt (hidden).

Bureaucratizing Academic Administration: Perpetuating the Yes Minister Syndrome

Bureaucratization of the domain of education would probably be the last nail in the coffin of our educational enterprise which is reeling under unprecedented variegated challenges of governance. Instead of envisaging for a process driven educational governance duly empowered by Information Technology, the National Education Policy calls for a license raj resolution of raising another cadre of self-serving bureaucrats as if the existing spectrum of administrators are hurting the inception of a linear "yes minister" regime. At a time when the country is being nurtured on daily dosages of "Maximum Governance, Minimum Government" and a slew of campaigns conforming to "My Gov", "Digital Gov" et al, this seems to be one of the most regressive policy prescription, interestingly coming from 1968s when the Indian polity started getting fossilized into a dynasty and the Indian Education became the first victim of a committed institution to the diktats of the executive. 

Dichotomies in Model of Governance at the Policy Pedestal Itself 

The Policy Draft speaks of creating multi-stakeholder Governing Bodies encompassing members from Industry & Alumni. Then it dictates the role and importance of students’ unions on academic campuses. Shouldn't it be left to individual campuses to decide upon the nature and constitution of such bodies rather than a national Policy Draft surmising at greater length on the actual nature and role of students' unions? Interestingly the policy assertions have been made out of singular incidents without the outcome of an objective empirical study on the role & importance & impact of students' politics on the gross academic output of the institutions of higher learning. Is MHRD being mandated to out-step the protocol or to follow a regimented regime of a duly laid out process of governance?

Entangling into Operational Use Cases: Treating Educators at par with Cadre Officials

The Policy Draft seems to be laying inordinate emphasis on disjointed Operational Use Cases. When you have an empowered Governing Body, the optimal utilization of the faculty base and its staggered deployment across various levels of education can be left at their best discretion. Why to have a stratified bureaucratic distinction of ranks in a seamless learning environment which our educational ecosystems are craving for long? 

The Golden Number of 100: Underlying Inception & Rationale

In a country which had set out NUEPA long back and which has enough empirical data to support its policy formulation deck, the simple mention of the golden number of 100 in a policy draft seems to have originated from an archaic mindset. Why only 100, why not 90 or why not 125? Have the policy formulators taken into account the geo-spatial clustering of higher education institutions, overlaid the sanctioned seats and disciplines of study to come to this sound decree which would need innumerable references to amend and modify? Can the 21st Century India be governed by such regressive policy documents which are in no way either prepared themselves to the challenges of the time or are structured in a modular scalable fashion? 

Disarrayed Thought Process at the Vision & Commissioning Level 

The very fact that the internal Governance of the Higher Education Institutions has been referred to in points 2, 5 and 7 suggests an entirely disarrayed way of thinking, which makes our governance incredibly complex. The existence of multi-stakeholder Governing Bodies is entirely in conjunction with the setting up of Education Tribunals which in turn relates directly to Grievance Redressal Mechanisms. Couldn't all three be clustered together for effective commentary? 

Regulation

Nothing could have been a mockery of the entire exercise of National Policy Making when the Policy Draft reads the following "The major national institutions in the system were set up at different times, with individual mandates as envisioned at the time of their formation. With the passage of time and new developments in the higher education sector, there is a need to review the regulatory framework and make it more relevant to current and future needs of the higher education system." 

Such generalized commentary could have been authored by any layman having even the superficial and surficial access to the Indian Educational Ecosystem. Shouldn't the policy draft be referred to the major regulatory clusters which are existing in the country and be given a double click treatment rather than passing the buck? 

Out of the Context Infiltration of Concepts: National Higher Education Fellowship Programme

It is difficult to understand the incorporation of National Higher Education Fellowship Programme in this section. It should’ve have been inserted into the one pertaining to Financing Higher Education. What it has to with Regulation of Higher Education? Without any further commentary on this item, it emerges to be an alien component. 

Multiplicity of Agencies, to what end: Central Educational Statistics Agency (CESA) 

The existence of NUEPA and its vast establishment has been entirely set aside and a new agency has been envisaged as a part of the New Education Policy. This has somewhere become the hallmark of an unaccountable bureaucracy, which probably is ignorant of its very own establishment, which its compatriots had got funded at one point of time, writing down a similar policy brief. This ignorance of facts is a criminal wastage of public faith & resources. 

Higher Education Institutions to have Websites or ERPs

At a time when different agents of State are being monitored through real time data dashboards, limiting the policy envisioning to a mere website which remains at the mercy of manual updates, doesn't look futuristic. Governance & Regulations are a part of the same continuum which have not found expression due to a myopic thought process which throws its weight towards raising a cadre of bureaucrats rather than setting up impersonal systems adjudicating transparency & probity by its very design and structure. The maiden NIRF ranking exercise posited the biggest challenge of dependable data, which could be made accessible in real time to regulators if a more progressive stance is taken by our policy formulators.

Quality

The policy commentary under this strand has again been deferred to yet another expert committee as if NBA & NAAC had had been operating in oblivion and disjointed from global realities. This seems to be a national ailment whereby a senior bureaucrat would cast aside the accomplishments or experiments of an agency at once, just because it’s the rank and not the rigor of intellect which matters. Did the vast consultation process of NEP miss the prescriptions from these bodies which do have people of substantial credence at its helm?

Citing that the Evaluation/Accreditation details of each institution will be available to the general public through a dedicated website, to enable students and other stakeholders to make informed choices, seems to be a naive and undue assertion as the NBA & NAAC portal do maintain the details.

If the policy drafters would have known about the knowyourcampus portal, launched with so much fanfare, and would have referred to out there citing the national realities, the observers of education would have been relieved to an extent. 


Conclusion 

Governance is a seamless function and this very section on Governance Reforms in Higher Education dejects the serious observers of National Education who have had been anticipating a first principles approach to National Education Policy, considering the hullabaloo enveloping the same. The aforesaid analysis showcases the incompleteness and lack of coherence across policy diktats. There is an absolute ignorance about IT driven systems and process across the entire policy deck spanning governance, regulation and quality. The sheer emphasis is on raising yet another bureaucratic cadre, commissions, agencies and all the conventional cocktail of policy prescriptions which have been ailing and retarding the country for over half a century now. The contextualization of the narrative is entirely lacking altogether across. An analysis of the questions evaded or skipped contained in the original consultative theme would blow apart the policy draft altogether.