No Technicalities: Rajasthan High Court Rules in Favor of Child’s Fundamental Right to Education

Introduction

In a significant ruling, the Rajasthan High Court, Jaipur Bench, has reiterated the constitutional significance of the Right to Education as an inseparable facet of Article 21-A. The Court directed Vardhman International School, Jaipur, to admit Master Daivik Rangwani, a minor aged three years, under the Economically Weaker Section (EWS) quota, in strict compliance with the mandate of the Right of Children to Free and Compulsory Education Act, 2009 (RTE Act).

Background of the Case

The present writ petition Master Daivik Rangwani (Minor) through Father Tarun Rangwani v. State of Rajasthan & Ors.[1] was instituted by Master Daivik Rangwani, a minor of three years, through his natural guardian and father, seeking enforcement of his fundamental right to free and compulsory education under Article 21-A of the Constitution of India and the provisions of the Right of Children to Free and Compulsory Education Act, 2009.

The petitioner had applied for admission to Vardhman International School, Jaipur, under the Economically Weaker Section (EWS) quota provided in Section 12(1)(c) of the Act of 2009. However, his application was rejected by the authorities on the ground that the Aadhaar Card submitted with the form did not mention the ward number of his residence. Although the State extended the deadline for verification and submission of documents up to 08.05.2025, the petitioner’s subsequently furnished certificate, duly attested by a Gazetted Officer and clearly indicating residence in Ward No. 70, was overlooked.

Despite compliance within the extended time frame, the respondents failed to consider the corrected document and consequently denied the petitioner admission under the RTE quota. Aggrieved, the petitioner approached the High Court, assailing the rejection as arbitrary, hyper-technical and violative of his fundamental right to education.

Petitioner’s Contentions

The petitioner contended that his application for admission under the RTE Act, 2009 was wrongly rejected on the ground that his Aadhaar Card did not mention the ward number. Although the deadline for document verification was extended to 08.05.2025, and a duly attested residence certificate confirming residence in Ward No. 70 was submitted on the same date, the respondents failed to consider it. Such refusal, despite timely compliance, was argued to be arbitrary and violative of the petitioner’s fundamental right to education under Article 21-A.

Respondent’s Stand

The respondents argued that the petitioner’s application was rightly rejected as the Aadhaar Card did not specify the ward number of residence. They further contended that the admission process was governed by strict timelines under the RTE guidelines, and no relaxation beyond the prescribed cut-off date was permissible.

Court’s Observations

Justice Anoop Kumar Dhand held that the Right to Education, being a constitutional guarantee under Article 21-A and reinforced by the RTE Act, cannot be defeated on technical or procedural grounds. Once the petitioner furnished valid proof of residence within the extended deadline, the authorities were obliged to consider it.

Relying on precedents such as Sudheer Kumar v. State of U.P. (Allahabad High Court)[2] and Jiya v. Maharaja Agarsen Model School (Delhi High Court)[3], the Court reiterated that schools cannot arbitrarily refuse admission under the 25% EWS quota. It further observed that rejecting admission on the sole ground of an Aadhaar discrepancy, despite availability of an authentic residence certificate, was unjustified and contrary to the spirit of the RTE Act, which aims to ensure inclusivity and equal access to education.

Judgment and Directions

The Court allowed the writ petition and directed Vardhman International School to admit Master Daivik Rangwani under the EWS quota within 15 days from receipt of the certified copy of the order. The ruling serves as a stern reminder to schools and authorities that procedural lapses or technical defects cannot be invoked to defeat a child’s constitutional right to education guaranteed under Article 21-A and the RTE Act.

Conclusion

This ruling by the Rajasthan High Court is a significant reaffirmation of the judiciary’s commitment to a child’s fundamental right to education. The case of Master Daivik Rangwani demonstrates that this right, enshrined in Article 21-A of the Constitution and the Right of Children to Free and Compulsory Education (RTE) Act, 2009, is a substantive entitlement that cannot be defeated by procedural or technical grounds. The court’s directive to Vardhman International School to admit the child under the Economically Weaker Section (EWS) quota, despite an initial documentation issue, sends a clear message to educational institutions and administrative authorities. The judgment reinforces the principle that education is not merely a statutory right but a fundamental one, intrinsically linked to human dignity. By prioritizing a child’s right over administrative rigidity, the court has ensured that children from disadvantaged sections of society are not deprived of educational opportunities due to “administrative lapses or rigid technicalities”. This decision ultimately upholds the constitutional vision of a more “inclusive and equitable education system for all”.

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[1] S.B. Civil Writ Petition No. 8802/2025

[2] 2017: AHC:108425

[3] 2024: DHC:2312