In a significant judgment on Tuesday, the Supreme Court upheld the constitutional validity of the Uttar Pradesh Board of Madrasa Education Act, 2004, providing much-needed clarity for over 12 lakh students enrolled in 13,364 madrassas across the state. This decision comes after the Allahabad High Court had struck down the Act in March 2024, declaring it “non-secular” and therefore “unconstitutional.” The High Court ruling had put the future of madrassa education in jeopardy, with students potentially being forced to shift to regular schools under the UP Education Board.
A three-judge bench, led by Chief Justice D.Y. Chandrachud, alongside Justices J.B. Pardiwala and Manoj Misra, disagreed with the High Court’s assessment and ruled in favor of the Act, which regulates the academic standards of madrassas in the state. The judgment makes it clear that minorities do not have an “absolute” right to administer educational institutions, and that the state has a legitimate interest in ensuring that religious minority schools meet secular education standards.
The Court’s ruling emphasized that the state’s regulatory powers over madrassas were designed to maintain academic excellence without interfering with the institutions’ minority character. Chief Justice Chandrachud, who authored the 70-page verdict, explained, “The right of minorities to manage educational institutions is not unqualified. The state has a constitutional obligation to ensure that these institutions impart education of an acceptable standard.”
The judgment clarified that while religious minority institutions, like madrassas, have the right to manage their affairs, the state can impose regulations to ensure the quality of education. These regulations, the Court said, could include guidelines on course curricula, teacher qualifications, student welfare, and other aspects of institutional management.
The Supreme Court also ruled that the UP Madrassa Act’s provisions related to higher education—specifically, the conferment of degrees like Fazil (postgraduate) and Kamil (undergraduate)—were beyond the state legislature’s competence, as they conflicted with the University Grants Commission (UGC) Act, which governs higher education in India. However, the Court maintained that the Act could continue to regulate madrassa education up to the 12th grade.
On the issue of religious instruction, the Court referred to Article 28(3) of the Constitution, which prohibits compelling students to receive religious education in state-recognized or state-funded institutions. “Religious instruction may be imparted in such institutions, but no student can be forced to take part in it,” the Chief Justice stated.
The judgment is expected to bring relief to thousands of students attending madrassas in Uttar Pradesh, ensuring that their education continues under a structured regulatory framework. It also reaffirms the state’s role in ensuring the academic and secular standards of all recognized educational institutions, including those managed by minority communities.
