1. The proposed amendment regulating admission at nursery level is vague and open to abuse. The Govt. simply needs to lift the provisions of Section 13 and Section 2(o) of RTE Act, 2009 and incorporate the same in Delhi School Education Act, 1973 making it applicable to the Nursery admissions. Such amendment would also be in consonance with the observations of Hon’ble Delhi High Court in WP(C) No. 8533/2010 titles Social Jurist Vs GNCTD and Ors.
2. The proposed provisions regarding regulating fee in unaided private schools fail to cater to the mischief of exorbitant and unjustified fee-hike. The provisions ought to be even better than that of Tamil Nadu (Regulation of collection of fee) Act 2009 but the proposed amendments fall way short of even what Tamil Nadu has already achieved. The unaided schools may be allowed to increase any kind of fee only with the prior approval of the fee committee.
3. The fee committee must be headed by a retired High Court Judge and not by Additional Director of Education.
4. There must be minimum 50% representation of parents in the Managing Committee of an unaided private school. This would not only check commercialization in education but also enhance the overall quality of education in private schools.
5. It is a well known fact that once a school charges fee from the parents, it becomes next to impossible to get it refunded.
6. It would be a better option to enact an independent legislation on fee regulation on the lines of Tamil Nadu, even more robust and effective than Tamil Nadu.