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Writer's pictureAryaman Garg

TMA Pai Foundation vs State of Karnataka (2002) 8 SCC 481

DECIDED ON-: October 31, 2002


BENCH-: B.N.KIRPAL CJI & G.B.PATTANAIK & V.N.KHARE & S.RAJENDRA BABU & S.S.M.QUADRI


FACTS

Dr. T.M.A Pai, founder of 'The Academy of General Education,' established the institution under the Societies Registration Act, 1860, in Manipal, initially within the state of Madras. After state reorganization, the region became part of Karnataka. In response to unethical fee practices, the governor enacted the Karnataka Educational Institutions Ordinance, 1984.

A writ petition challenged the ordinance and a state directive restricting college intake, reserving 40% of seats as government seats. During the petition, the Karnataka Educational Institutions (Prohibition of Capitation Fee) Act, 1984, was enacted, specifying fees for private unaided institutions not receiving government assistance.


ISSUES

1. Legal Authorization for Educational Institutions: Is there a legal framework permitting the establishment and governance of educational institutions?

2. Determining Religious and Linguistic Minorities: How should the identification of religious and linguistic minorities be conducted—based on state boundaries or encompassing the entire country?

3. Government Rules and Article 30: Do government regulations concerning minority-affiliated or unaffiliated institutions violate the rights guaranteed under Article 30 of the Constitution?

4. Government Intervention Limits: To what degree can the government impose restrictions on the management of minority-aided and unassisted institutions?


JUDGMENT

The Supreme Court upheld private educational institutions' right to autonomy under Article 19(1)(g) of the Constitution. While emphasizing the institutions' role in national development, the court stated that autonomy should be subject to reasonable regulations for transparency and fairness. The court's guidelines covered admission processes, fee fixation, staff selection, and institutional administration, aiming to strike a balance between autonomy and accountability.

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