Legal Analysis: Padam Mehta and Another vs. State of Rajasthan and Others

Citation: 2026 INSC 476 (Reportable)
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta (Division Bench)
Date of Decision: May 12, 2026
Nature of Judgment: Civil Appeal under Article 136 of the Constitution of India against the judgment of the High Court of Judicature for Rajasthan at Jodhpur dismissing a Public Interest Litigation concerning the inclusion of the Rajasthan language in teacher recruitment examinations and as a medium of instruction.

Synopsis of the Judgment

The appellants filed a Public Interest Litigation before the Rajasthan High Court seeking directions to include the Rajasthan language in the syllabus for the Rajasthan Eligibility Examination for Teachers (REET-2021) and to impart education to children in the Rajasthan language. The High Court dismissed the petition, holding that a writ of mandamus can be issued only when an enforceable legal right is established and the State has failed to discharge a statutory duty. The Supreme Court, while noting that the specific relief pertaining to the concluded REET-2021 examination had become infructuous, proceeded to address the broader constitutional issues concerning mother tongue‑based education. The Court held that the right to receive education in one’s mother tongue is protected under Article 19(1)(a) of the Constitution and is reinforced by Section 29(2)(f) of the Right to Education Act, 2009 and the National Education Policy, 2020. The Court directed the State of Rajasthan to formulate a comprehensive policy to recognise and accord due status to the Rajasthan language as a local/regional language for educational purposes, to adopt it as a medium of instruction at foundational stages, and to introduce it as a subject in all schools in a phased manner. The appeal was allowed, and the State was directed to file a compliance affidavit.

1. Basic Information of the Judgment

• Case Title: Padam Mehta and Another vs. State of Rajasthan and Others

• Civil Appeal No.: Arising out of Special Leave Petition (C) No. 1425 of 2025

• Bench: Justice Vikram Nath and Justice Sandeep Mehta (Division Bench)

• Date of Decision: May 12, 2026

• Citation: 2026 INSC 476 (Reportable)

• Appeal From: Final order dated 27.11.2024 of the High Court of Judicature for Rajasthan at Jodhpur in D.B. Civil Writ Petition No. 5294 of 2021

2. Legal Framework

Laws and Provisions Involved

• Constitution of India, 1950: Articles 14 (equality), 19(1)(a) (freedom of speech and expression, including right to receive information/education in a language of choice), 21 (right to life), 21A (right to education), 41 (right to work, education and public assistance), 45 (provision for early childhood care and education), 51A(k) (fundamental duty of parent/guardian to provide opportunities for education), 350A (facilities for instruction in mother tongue at primary stage), Part XVII (Official Language), Eighth Schedule (recognised languages)

• Right of Children to Free and Compulsory Education Act, 2009 (RTE Act): Section 29(2)(f) – mandates that the curriculum and evaluation procedure shall take into consideration that the medium of instruction shall, as far as practicable, be in the child’s mother tongue.

• National Education

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