The Right to Education (RTE) is a fundamental right under Article 21-A of the Constitution of India, which ensures that every child has access to education as a basic necessity of life. It is not merely about classroom instruction but also about enabling holistic development, fostering equality, and nurturing human dignity. However, in practice, this right often collides with rigid administrative rules and policies, especially concerning the age criteria for admission to different classes.
The recent judgment of the Madhya Pradesh High Court in Aarav Singh v. Union of India & Ors. (W.P. No. 13186 of 2025, decided on 19 August 2025) has reignited the debate: Can the Right to Education be curtailed by imposing strict age limits? The Court addressed the issue of a meritorious student being denied admission in Class IX solely because he did not meet the prescribed age requirement under the National Education Policy (NEP), 2020 and CBSE Examination Bye-laws.
This article critically examines the legal, constitutional, and policy dimensions of this question, exploring how courts in India have reconciled the conflict between rigid age norms and the broader mandate of the Right to Education.
Case Background: Aarav Singh v. Union of India
The petitioner, Aarav Singh, a minor represented by his mother, was born on 19 March 2014. He had an exceptional academic record, consistently performing at the top of his class and demonstrating extraordinary learning abilities. Having completed Class VIII in 2023–2024 with excellent grades, he sought admission to Class IX in the same institution.
However, his admission was denied based on Clause 4.1 of the NEP, 2020, which prescribes the age group for different stages of education. According to this framework, Class IX falls under the secondary stage (ages 14–18). Since Aarav was younger than 14, the school and CBSE refused to register him for Class IX.
Despite representations made by his mother, the authorities insisted that the rules were binding and left no scope for exceptions. This led to the filing of the writ petition before the Madhya Pradesh High Court, where the primary issue was whether imposing an age limit in such circumstances violated the petitioner’s fundamental right to education under Article 21 of the Constitution.
Issues
The case presented several intertwined legal questions:
- Whether Clause 4.1 of the NEP, 2020 prescribing age brackets is mandatory or directory in nature.
- Whether an exceptionally meritorious student can be denied admission solely on the ground of age.
- Whether the Right to Education under Article 21 can be curtailed by rigid administrative rules.
- What role do educational boards and institutions play in balancing policy compliance with individual rights?
The Court’s Analysis
1. Nature of Clause 4.1 of NEP, 2020
The Court examined Clause 4.1 of the NEP, which restructures school education into a 5+3+3+4 model with specific age ranges:
- Foundational Stage: 3–8 years (Anganwadi + Grades 1–2)
- Preparatory Stage: 8–11 years (Grades 3–5)
- Middle Stage: 11–14 years (Grades 6–8)
- Secondary Stage: 14–18 years (Grades 9–12)
The Court clarified that this provision is not mandatory but directory, designed to align the developmental needs of students with academic stages. It does not expressly prohibit extraordinary students from advancing earlier. Thus, treating the age limit as absolute would amount to a mechanical interpretation, defeating the purpose of education itself.
2. Recognition of Exceptional Merit
The Court relied on IQ and aptitude assessment reports submitted by experts, which revealed Aarav’s extraordinary intelligence, analytical capacity, and creative quotient. A blanket refusal to admit him solely on the ground of age, despite his proven capability, would amount to suppression of talent.
The Court emphasised that education policies must be flexible enough to accommodate outliers—students who are far ahead of their age peers. To deny them progression is to deny their right to grow.
3. Precedents from Other High Courts
The Madhya Pradesh High Court referred to rulings from various courts across India:
- Patna High Court (2024, Sameer Raj v. Union of India) – Allowed an underage but meritorious student to file a representation before CBSE for relaxation, recognising exceptional talent as grounds for deviation from rigid norms.
- Himachal Pradesh High Court (2022, Kashvi v. State of H.P.) – Dealt with a genius child of tender age. While initially cautious about emotional strain, the Court provisionally admitted her to a higher class and monitored progress, balancing development with caution.
- Madras High Court (2021, NTA v. Minor SP. Shree Harini) – Considered a student who cleared Class XII before turning 16. Though ultimately bound by NEET regulations, the Court criticised the rigidity and suggested the Medical Council of India consider reforms to avoid injustice in such cases.
These precedents collectively show judicial willingness to intervene when rigid age criteria unjustly obstruct a child’s educational progression.
4. Constitutional Dimension: Article 21 and RTE
The Court reiterated that the Right to Education is an integral part of Article 21, which ensures dignity, development, and equality. It was observed that inflexibly applying age criteria, especially when it hinders the progress of an exceptionally gifted student, would amount to a breach of this constitutional protection. While acknowledging that the age norms under the NEP 2020 are designed to match the developmental stages of most students, the Court clarified that such norms cannot become absolute barriers. When a student displays remarkable intelligence, strong academic performance, and the ability to handle advanced studies, those qualities must be acknowledged and supported rather than curtailed by rigid age restrictions.
5. Directions Issued
The Court directed CBSE and the concerned school to:
- Grant provisional admission to Class IX.
- Monitor the student’s daily progress.
- Require submission of a fresh representation to CBSE along with IQ and medical board reports.
- Ensure the CBSE Chairman makes a final decision considering the child’s overall performance and expert evaluation.
This pragmatic order balanced the need for compliance with policy and the child’s individual rights.
Key Highlights of the Decision
Justice Vishal Mishra stated:
“Article 21 of the Constitution of India provides Right to Education. Right to Education cannot be curtailed by imposing a condition regarding age limit. There are several instances which point out that if an underage child can perform exceptionally well and his understanding level is on a higher side, then the exceptional qualities of such student/candidates cannot be suppressed or overlooked merely on the ground of he being underage.”
Broader Implications
1. Age Norms v. Child Rights
The judgment highlights the tension between administrative efficiency (uniform age-based classifications) and individual justice (accommodating exceptional talent). While age criteria ensure developmental readiness for most children, they may unjustly penalise the gifted minority.
2. NEP, 2020’s Flexibility
The NEP was designed to be progressive and child-centric. The Court’s interpretation that its provisions are directory rather than mandatory restores flexibility and aligns the policy with constitutional values.
3. Avoiding a “One Size Fits All” Approach
Rigid application of age norms risks creating a “tyranny of averages”, where exceptional students are held back, potentially leading to demotivation and talent suppression. Courts have now clarified that educational authorities must adopt a case-by-case approach, especially where expert assessments demonstrate unusual merit.
4. Safeguards Against Abuse
At the same time, courts have been cautious, ensuring that accelerated promotions are subject to monitoring (as in the Himachal Pradesh case). This prevents undue pressure or exploitation of children while recognising their right to excel.
Critical Analysis
In Favour of Relaxing Age Limits
- Constitutional Mandate: Article 21 read with Article 21-A obligates the State to promote, not restrict, education.
- International Standards: The UN Convention on the Rights of the Child (UNCRC) emphasises a child’s right to education according to their capacity and interest, not just age.
- Promoting Meritocracy: Recognising exceptional students prevents brain drain and fosters innovation.
Against Relaxing Age Limits
- Psychosocial Concerns: Early progression may expose young children to peer pressure, emotional challenges, and maturity gaps.
- Administrative Chaos: If every student sought relaxation, it could disrupt uniformity and planning in school systems.
- Risk of Misuse: Parents might push children prematurely, leading to stress and burnout.
The Court’s solution—provisional admission with monitoring—strikes a balance between these competing concerns.
Conclusion
Madhya Pradesh High Court’s judgment in Aarav Singh v. Union of India makes it clear that the Right to Education cannot be restricted by rigid age limits when dealing with extraordinary students. Age criteria under the NEP, 2020, and CBSE bye-laws are directory, not mandatory, and must yield in exceptional circumstances to the constitutional mandate of Article 21.
While uniform rules are necessary for the general student population, exceptions must exist for the gifted few, subject to safeguards. Ultimately, education policies must serve the child’s best interests, not bureaucratic convenience.
This case not only protects the rights of one meritorious student but also sets a precedent that Indian education law must be flexible, compassionate, and child-centric.
Important Link
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