Mohini Jain v. State of Karnataka

Emblem of the Supreme Court of India

Mohini Jain v. State of Karnataka is a landmark Supreme Court of India case that significantly impacted the right to education in India. The case was decided in 1992 and is often cited in discussions about educational rights and the Right to Education Act, 2009.

Background

The case arose when Mohini Jain, a resident of Uttar Pradesh, was denied admission to a medical college in Karnataka due to her inability to pay the exorbitant capitation fee demanded by the institution. Jain challenged the constitutionality of the capitation fee system, arguing that it violated her fundamental rights under the Constitution of India.

Legal Issues

The primary legal issue in the case was whether the imposition of capitation fees by private educational institutions violated the right to education as implied under the Right to Life guaranteed by Article 21 of the Constitution. The case also examined whether the state had an obligation to ensure access to education for all citizens.

Judgment

The Supreme Court, in a landmark judgment, held that the right to education is a fundamental right under Article 21 of the Constitution. The Court ruled that the capitation fee system was unconstitutional as it created an economic barrier to education, thereby violating the right to equality under Article 14 and the right to education under Article 21.

Significance

The judgment in Mohini Jain v. State of Karnataka had far-reaching implications. It laid the groundwork for subsequent rulings that further expanded the scope of the right to education. The case was instrumental in the enactment of the Right to Education Act, 2009, which mandates free and compulsory education for children between the ages of 6 and 14.

Related Cases

• Unni Krishnan, J.P. v. State of Andhra Pradesh
• T.M.A. Pai Foundation v. State of Karnataka

See Also

• Right to Education Act, 2009
• Supreme Court of India
• Constitution of India
• Article 21 of the Constitution of India
• Article 14 of the Constitution of India