The Legality of "Coaching Culture" and the Regulation of Private Coaching Centers in India

References

[1] Krishna Kumar, What is Education? 42-45 (2d ed. 2009) See Mark Bray, The Shadow Education System: Private Tutoring and Its Implications for Planners 18-22 (UNESCO-IIEP, 2007)

[2] Ministry of Human Resource Development, Report of the Committee on National Policy on Education 89-94 (Draft, 2019)

[3] Pramod Kumar, Shadow Education and Educational Inequality in India, 14 J. Pub. L. & Pol'y 112, 115-117 (2021) Id. at 120

[4] Amartya Sen, Development as Freedom 290-293 (1999) See Avinash Soni, Regulating the Unregulated: The Legal Dilemma of Private Coaching Classes in India, 7 Student L. Rev. 45, 48-52 (2018) Id. at 55

[5] India Const. art. 19, § 1, cl. g

[6] T.M.A. Pai Foundation v. State of Karnataka, (2002) 8 S.C.C. 481, ¶ 54 India Const. art. 19, § 6

[7] Islamic Academy of Education v. State of Karnataka, (2003) 6 S.C.C. 697, ¶ 7

[8] P.A. Inamdar v. State of Maharashtra, (2005) 6 S.C.C. 537, ¶ 112 See Modern Dental College and Research Centre v. State of Madhya Pradesh, (2016) 7 S.C.C. 353, ¶ 65 M.P. Jain, Indian Constitutional Law 432-435 (8th ed. 2018)

[9] India Const. sent. sched., list III, entry 25 (amended by the Constitution (Forty-second Amendment) Act, 1976) India Const. art. 254 India Const. sent. sched., list II, entries 26, 60 See H.M. Seervai, Constitutional Law of India 2210-2215 (4th ed. 2006)

[10] The Goa Coaching Classes (Regulation) Act, 2001 (Goa Act 27 of 2001)

[11] The Bihar Coaching Institutes (Control & Regulation) Act, 2010 (Bihar Act 14 of 2010)

[12] The Uttar Pradesh Regulation of Coaching Act, 2002 (U.P. Act No. 5 of 2002)

[13] Rajeev Dhawan, The Law of Education in India 304-309 (2012) Ministry of Education, National Education Policy 2020, ¶ 4.36 (2020) Id. ¶ 4.37 Ministry of Education, Government of India, Guidelines for Registration and Regulation of Coaching Centers 2024, § 3 (Jan. 16, 2024) Id. § 4

[14] Central Consumer Protection Authority, Guidelines for Prevention of Misleading Advertisement in Coaching Sector 2024, § 2 (Nov. 13, 2024) Id. § 5 See The Rajasthan Coaching Centres (Control and Regulation) Bill, 2025; The Bihar Coaching Centres (Control and Regulation) Bill, 2026

[15] Sanjay Srivastava, The De-institutionalization of Indian Schooling, 54 Econ. & Pol. Weekly 33, 35-37 (2019) Id. at 38

[16] Anuradha De & Jean Drèze, Public Report on Basic Education in India 110-115 (1999)

[17] The Right of Children to Free and Compulsory Education Act, 2009, No. 35 of 2009

[18] See Shanti Bhushan, The Commercialization of School Education and the Law, 12 Sup. Ct. Cas. (Jour.) 14, 16-19 (2015) Id. at 22

[19] Consumer Online Foundation v. National Coaching Institutes Corp., 2018 N.C.D.R.C. 412, ¶ 14 Id. ¶ 16

[20] The Consumer Protection Act, 2019, No. 35 of 2019, § 2(46) See Buddhist Mission Dental College v. Bhupesh Dixit, (2010) 4 S.C.C. 386; Sehgal School of Competition v. Khushboo Sharda, (2009) 2 C.P.J. 33 (Del.)

[21] Vibha Sharma, Consumer Rights in Commercialized Education Ecosystems, 22 Indian Consumer L. Rep. 88, 91-95 (2022)

[22] Sanjeev Jain, The Psychological Cost of Competitive Excellence, 3 Indian J. Psychiatry & L. 74, 76-79 (2020) Id. at 82

[23] National Crime Records Bureau, Accidental Deaths & Suicides in India 2022, Ministry of Home Affairs, 145-148 (2023) See State of Punjab v. Mohinder Singh Chawla, (1997) 2 S.C.C. 83 (holding that the right to health is integral to the right to life under Article 21)

[24] Rohan Malhotra, Urban Planning Regulations and Commercial Coaching Hubs, 9 J. Urban Plan. & L. 201, 204-208 (2017) Id. at 212 In re: Fire Safety Measures in Commercial Coaching Centres, (2019) SCC OnLine SC 845, ¶ 3

[25] Upjendra Malik, Municipal Deficits and Enforcement Failure in Urban Infrastructure, 16 Indian J. Loc. Self-Govt. 44, 47-51 (2021)

[26] Soli Sorabjee, Reforming Shadow Education via Central Enactments, 24 Legal Perspectives 15, 17-19 (2021) Id. at 22 See K.N. Chandrasekharan Pillai, General Principles of Criminal Law 189-194 (3d ed. 2019)

[27] J.N. Pandey, Constitutional Law of India 560-565 (58th ed. 2021) Id. at 568

[28] Administrative Reforms Commission, Twelfth Report: Citizen-Centric Administration 112-116 (2009)

[29] National Council of Educational Research and Training, National Curriculum Framework 2023 45-52 (2023) Id. at 58

[30] Yash Pal Committee, Report of the Committee to Advise on Renovation and Rejuvenation of Higher Education 34-39 (Ministry of Human Resource Development, 2009)

[31] Pratap Bhanu Mehta, The Burden of Democracy: Education and Structural Deficits in Modern India, 18 India Rev. 102, 105-109 (2019) Id. at 114

@article{1719006,
      author = {Dr. Hanumant Dodake},
      title = {The Legality of "Coaching Culture" and the Regulation of Private Coaching Centers in India},
      journal = {Iconic Research And Engineering Journals},
      year = {2026},
      volume = {9},
      number = {12},
      pages = {2020-2026},
      issn = {2456-8880},
      url = {https://www.irejournals.com/formatedpaper/1719006.pdf},
      abstract = {The rapid proliferation of private coaching centers across India has engineered a parallel, hyper-commercialized educational ecosystem, widely characterized as "coaching culture." This paper evaluates the socio-legal, constitutional, and regulatory dimensions governing this unregulated landscape. While the Right to Education is recognized as a fundamental facet of the right to life under Article $21$ of the Constitution of India, the systematic shifts toward a highly competitive, commercialized mechanism of supplementary training raise significant constitutional challenges under Articles $14$, $19(1)(\text{g})$, and $21$. Analyzing the evolution from early piecemeal state legislations to the central Guidelines for Registration and Regulation of Coaching Centers 2024 and the Central Consumer Protection Authority (CCPA) Guidelines 2024, this study identifies ongoing regulatory arbitrage, structural loop-holes, and enforcement deficits. To bridge the gap between theoretical frameworks and ground reality, this paper features an empirical study conducted in Pune, Maharashtra. The empirical data highlights severe systemic issues, including unsafe infrastructural setups, exploitative fee refund regimes, widespread consumer fraud through deceptive advertisements, and a pervasive mental health crisis driven by rigorous academic stress. The paper concludes by presenting actionable, multi-tiered institutional recommendations and statutory reforms aimed at reconciling the commercial liberties of private operators with the state’s paramount obligation to safeguard student welfare and preserve educational equity.},
      keywords = {Shadow Education, Coaching Culture, Article 21, Guidelines for Registration and Regulation of Coaching Centers 2024, CCPA Guidelines 2024, Consumer Protection, Dummy Schools, Pune Empirical Study, Academic Stress, Regulatory Infrastructure.},
      month = {June},
      doi = {https://doi.org/10.64388/IREV9I12-1719006}
  }