Supreme Court to Review Maharashtra’s Pupil–Teacher Ratio Policy Under the Right to Education Act

Introduction

The Supreme Court of India has agreed to examine whether the pupil–teacher ratio (PTR) prescribed by the State of Maharashtra through a 2024 Government Resolution (GR) is inconsistent with the statutory framework of the Right of Children to Free and Compulsory Education Act, 2009 (RTE Act). The case raises crucial questions about state powers, statutory interpretation, and the future of neighbourhood schools, particularly in rural and low-enrolment areas.

By issuing notice in the matter, the Supreme Court has opened a significant debate on whether state-level administrative decisions can dilute minimum educational standards fixed by Parliament.

Background of the Dispute

The challenge arises from a Government Resolution dated March 15, 2024, issued by the Government of Maharashtra. The resolution modifies the criteria for sanctioning teaching posts in schools by linking the number of teachers to the total number of students across broader school sections, rather than class-wise requirements.

The petitioner, an association of private educational institutions, contends that this policy undermines the core objectives of the RTE Act and violates the Schedule appended to the Act, which clearly lays down norms regarding pupil–teacher ratios.

Supreme Court Proceedings

A Bench comprising Justice P.S. Narasimha and Justice Alok Aradhe issued notice to:

• The State of Maharashtra
• The Commissioner of Education

The Supreme Court has also tagged the matter with a pending case from 2016, where similar questions regarding interpretation of the RTE Schedule and pupil–teacher ratio norms were raised. The next date of hearing has been fixed for March 13.

What the RTE Act Prescribes

The Schedule to the RTE Act, 2009 sets out minimum norms and standards for schools, including pupil–teacher ratios:

• Classes I to V:
  Pupil–teacher ratio of 30–40:1
• Classes VI to VIII:
  Pupil–teacher ratio of 35:1

Crucially, the Schedule measures PTR per class/division, not by aggregating students across multiple classes or school sections.

The petitioner argues that the Maharashtra GR misinterprets this statutory scheme by treating primary, upper primary, and secondary levels as single units for PTR calculation.

Petitioner’s Key Arguments

1. Misinterpretation of the RTE Schedule

According to the petitioner:

• The RTE Act calculates teacher requirements for each class, not for entire school sections.
• The State Government has erroneously treated sections (primary/upper primary) as the unit of measurement, contrary to the statute.

This interpretation, it is argued, directly defeats the legislative intent of ensuring adequate teacher availability in every classroom.

2. Lack of Legislative Competence

The petitioner relies on Section 20 of the RTE Act, which vests the power to amend the Schedule exclusively with the Central Government.

It is contended that:

• A State Government cannot indirectly amend or dilute statutory norms through an executive resolution.
• The Maharashtra GR effectively alters the pupil–teacher ratio prescribed in the Schedule without legislative authority.

3. Risk of School Closures

One of the most serious concerns raised is the practical consequence of the GR:

• Schools with lower student strength may be sanctioned only one teacher for several classes.
• This could make it administratively unviable for such schools to function.
• As a result, neighbourhood schools—especially in rural and tribal areas—may be forced to shut down.

Such an outcome, the petitioner argues, runs contrary to the core objective of universal access to education under the RTE Act.

4. Ignoring Recognition Norms

The petitioner also submitted that while sanctioning teacher posts, the GR ignores:

• Infrastructure requirements
• Distance norms
• Accessibility criteria

These factors are mandated under both central and state education laws, including the RTE Act, for granting and continuing school recognition.

High Court Proceedings and Appeal

The Special Leave Petition before the Supreme Court challenges a December 1, 2025 order of the Circuit Bench of the Bombay High Court at Kolhapur.

The High Court dismissed the plea on the ground that:

• A coordinate bench had already upheld the validity of the GR.
• Therefore, the issue was considered settled at the High Court level.

However, the Supreme Court has now agreed to re-examine the matter, particularly in light of the statutory interpretation involved and the earlier pending case.

Issues Likely to Be Examined by the Supreme Court

The case presents several important legal questions:

1. Can a State Government modify pupil–teacher ratio norms through executive action?
2. Does the Maharashtra GR conflict with the Schedule to the RTE Act?
3. Whether PTR should be calculated class-wise or section-wise?
4. Can administrative efficiency override statutory minimum standards?
5. What is the impact of such policies on the right to access neighbourhood schools?

Broader Implications of the Case

Impact on Education Policy

If the Supreme Court finds the GR to be inconsistent with the RTE Act, it could:

• Reinforce uniform national standards for pupil–teacher ratios
• Limit the scope of state discretion in educational norms
• Protect smaller schools from closure due to staffing policies

Federal Balance in Education

Education is a subject under the Concurrent List, requiring balance between central legislation and state implementation. This case tests:

• The extent to which states can adapt national laws to local conditions
• The limits of executive power when faced with explicit statutory mandates

Case Details

• Case Title: Sindhudurg Zilla Shikshan Sanstha Chalak Mandal, Pandur v. State of Maharashtra & Ors.
• Case Number: SLP (Civil) No. 2479 of 2026
• Bench: Justice P.S. Narasimha and Justice Alok Aradhe
• Next Hearing: March 13

Conclusion

The Supreme Court’s decision to examine Maharashtra’s pupil–teacher ratio policy under the RTE Act highlights the continuing tension between administrative efficiency and statutory guarantees. At stake is not merely a numerical formula, but the quality, accessibility, and inclusiveness of elementary education.

The outcome of this case will have far-reaching consequences—not only for Maharashtra, but for education policy across India—by clarifying whether minimum educational standards fixed by law can be diluted through executive action.

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