NATIONAL LAW UNIVERSITY, JODHPUR

RIGHT TO EDUCATION – A BRIEF ANALYSIS

(Project submitted as part of Mid-Term in the subject of Constitutional Governance-I)

SUMMER SESSION
(JULY-NOVEMBER 2018)

SUBMITTED TO: SUBMITTED BY:

MS.VINI SINGH DISHA LOHIYA (1665)
(FACULTY OF CG-I) AND

ANURAG SINGH (1656)

BA.LL.B. SEMESTER-I
 ACKNOWLEDGEMENT
On the completion of this project, we take the opportunity of thanking the people who
contributed in the completion of it, without whose aid, contribution and help this project
wouldn’t have seen practicability.
First we extend my heartfelt gratitude to, my mentor and Constitution Teacher, Ms.Vini Singh,
Faculty of CG-I whose continuous guidance and support provided me with the much needed
impetus and gave me a better insight into the topic. We are grateful to the IT Staff for providing
all necessary facilities for carrying out this work. We thank all members of the Library Staff
for providing me the assistance anytime needed.
We also thank our friends and batch mates for providing us the much needed aid whenever
needed. Most importantly, we would like to thank our parents for providing me the much
needed force for accomplishing this project.

2
 TABLE OF CONTENTS

Introduction ................................................................................................................................ 4
historical perspective ................................................................................................................. 5
Provisions under rte act .............................................................................................................. 6
STEPS AND EFFORTS TOWARDS EDUCATION ............................................................... 8
Limitations of this Act ............................................................................................................. 10
CRITICAL ANALYSIS .......................................................................................................... 12
Conclusion ............................................................................................................................... 15
Suggestions .............................................................................................................................. 15
Bibliography ............................................................................................................................ 17

3
 INTRODUCTION
Illiteracy is our sin and shame and must be liquidated.
By Mahatma Gandhi
A number of recent efforts have been initiated in India to make elementary education a
fundamental right of every child. The Lok Sabha passed the 93rd Constitutional Amendment
Bill on 27th November 2001, and then by the Rajya Sabha on 14thMay 2002. A major step was
witnessed in the evolution of the 93rd Constitution Amendment Bill into the 86th Constitution
Amendment Act. This was for the first time since the framing of the constitution, that a
Fundamental Right was added to the constitution of India. Befittingly, for India, with the largest
illiteracy rate in the world, Right to Education was inserted as a fundamental right. Now the
Indian Constitution guarantees eight years of elementary education to each and every child in
the country.
How this shall be implemented and by whom, and in what manner, shall be decided by the
legislation that is to be drafted as a follow up to the Constitutional Amendment. Consequent to
the amendment Article 21(A) shall be inserted after article 21 of the constitution, namely:
“21A. The state shall provide free and compulsory education to all children of the
age of six to fourteen years in such manner as the State may, by law, determine”
Article 45 will not be deleted. Instead, the content of the article 45 of the constitution is being
substituted by:
“45. The State shall endeavour to provide early childhood care and education for all
children until the complete the age of six years.”
In article 51 A of the Constitution, after clause (j), the following clause is being added:
“(k) who is a parent and guardian to provide opportunities for education to his child
or the case may be, ward between the age of six and fourteen years”.
Therefore, it is to be concluded that the provisions of article 21-A itself state that they are to be
implemented in such manner as the state may by law determine. As such the legislation that
would give effects to the provisions to this clause would play a determining role in the favour
of Indian Education .Today we just don’t need the legislation but we require a legislation that
will enforce the rights of every child to quality education.

4
 HISTORICAL PERSPECTIVE

During pre-independence days, educational rights were not known. In fact, education was
considered a privilege rather than a right. The State’s obligation to provide education was
recognized with the inclusion of a directive principle to be in force under Article 45 in the
Indian Constitution (directive principles, unlike fundamental Rights, are not legally
enforceable). Butin 2002, the Right to Education was converted into a Fundamental Right1.
The leaders of the independence movement, intellectuals and people that comprised the masses
stood in unanimity on providing free education to every child up to the age of 14. This concept
was adapted from the British law of Free and Compulsory Education (FCE) and incorporated
into Article 45 of the Constitution. Thus, FCE became a Constitutional commitment in India
from 26th January 1950, when Article 45 mandated the State to universalize education within
10 years, i.e. by 1960.
The Kothari Commission summarized-
“the recommendation of the commission regarding the common school system is the integral
part of the programme to promote the education of the poor, reduce its dual character in
which ‘haves’ receive one type of education and ‘have-nots’ another, and to create a socially
cohesive and egalitarian society”.
In 1992the Indian Supreme Court declared the right to education to be a fundamental right2. It
observed that ‘Right to Life’ is the basic right for the dignified enjoyment of life. The Right to
Education flows directly from Right to Life. The Right to Life under Article 21 and the dignity
of an individual cannot be assured unless it is accompanied by the Right to Education. The
State Government was under an obligation to make an effort to provide educational facility at
all levels to its citizens”. This was again reiterated by the Supreme Court in 19933.
The Parliament of India enacted the Eighty-Sixth Amendment in 2002 to make education a
fundamental right for children in the age group 6 to 14 years. Due to the delay in drafting a
central legislation the right remained on paper for eight years owing tothat would lay down the
practical framework for its implementation.
Aftermath of Unni Krishnan decision
The decision in Unni Krishnan gave rise to the debate over the limits of the judicial review.
The fact of this debate was that the children were not provided with primary education could
go to court and file a writ against the authorities. As a result member of civil society and NGO’s
began pushing the executives and legislatures toward the serious action on primary education.
This issue gave rise to the movements for Constitutional Amendments guar anting the Right to
Education. This movement resulted in the formation of National Alliance for the Fundamental

1
86th Amendment 2002, Constitution of India.
2
Mohini Jain v. State of Karnataka, AIR 1992 SC 1858: (1992) 3 SCC 666.
3
Unni Krishnan, J.P. v. State of Andhra Pradesh AIR 1993 SC 2178: (1993) 1 SCC 645.
5
Right to Education (NAFRE) which represented a coalition of almost 2400 grassroots NGO’s
from 15 states across India. Also the groups committed to the abolition of child labour such as
SACCS and CACL joined forces with groups such as NAFRE. In 1997 the Central Government
introduced the 83rd Amendment Bill which sought to make the Right to Education a
Fundamental Right. The bill was reintroduced by the current NDA Government as the
Constitutional (93rd Amendment) Act, 2001.

PROVISIONS UNDER RTE ACT

1. Right of Child to free and compulsory education: Every child of the age of six to
fourteen years shall have a right to free and compulsory education in a neighbourhood
school till completion of elementary education without any kind of fee or charges or
expenses.
2. Special Provisions for children not admitted to, or who have not completed elementary
education: The Act provides a right to receive special training, if the child is directly
admitted in a class appropriate to his or her age.
3. Right of transfer to other school: Under this act a child can transfer to any other school
and pursue further completion of elementary education by obtaining transfer certificate.
4. Duty of appropriate government or local authority to establish school: The Act Provides
the appropriate Government and the local authority have to establish a school, where it
is not so established, within a period of three years from the commencement of this Act.
5. Sharing of financial and other responsibilities: The Central Government and the State
Governments shall have concurrent responsibility for providing funds for carrying out
the provisions of this Act. The Central Government shall develop a framework of
national curriculum with the help of academic authority, develop and enforce standards
for training of teachers, provide technical support and resources to the State
Government for promoting innovations, researchers, planning and capacity building.
6. Duty of parents and guardian: All the parents and guardian are bound to admit their
child for elementary education in neighbourhood school.
7. Appropriate Government to provide for pre-school education: Children above the age
of three years will be provided early childhood care and education for all children until
they complete the age of six years by the government. The Act also mentions the
responsibilities of teachers and schools.
8. No capitation fee and screening procedure for admission: No capitation fee will be
collected from parents while admitting their children in the school.
9. Prohibition of physical and mental harassmentto child: The Act prohibits any private
tuition by teacher in the concerned established school.

10. Monitoring of child’s right to education: The National Commission or the State
Commission for Protection of Child Rights, the Commissions for Protection of Child
Rights Act, 2005, shall, in addition to the functions assigned to them under that Act,
also perform the following functions, namely-
a. examine and review the safeguards for rights provided by or under this Act and suggest
measures for their effective implementation;
b. inquire into complaints relating to child’s right to free and compulsory education and
6
c. take necessary steps as provided under sections 15 and 24 of the said Commissions
for Protection of Child Rights Act.
11. Constitution of National and State Advisory Council: National and State Advisory
Council of not more than fifteen members will be formed by Central and State
Government. The appointed members should possess knowledge and practical
experience in the field of elementary education and child development.

7
 STEPS AND EFFORTS TOWARDS
EDUCATION
THE RIGHT OF CHILDREN TO FREE AND COMPULSORY EDUCATION ACT,
2009
The present Act has its history in the drafting of the Indian constitution at the time of
Independence but is more specifically to the Constitutional Amendment that included the
Article 21A in the Indian constitution making Education a fundamental Right. This
amendment, however, specified the need for a legislation to describe the mode of
implementation of the same which necessitated the drafting of a separate Education Bill.
The very first step toward the achievement of right to education as fundamental right is
enactment of the Right of Children to Free and Compulsory Education Act, 2009.

The salient features of the Right of Children for Free and Compulsory Education act are-

1. Free and compulsory education to all children of India in the six to 14 age group;
2. No child shall be held back, expelled, or required to pass a board examination until
completion of elementary education;
3. A child above six years of age has not been admitted in any school or though
admitted, could not complete his or her elementary education, then, he or she shall be
admitted in a class appropriate to his or her age.
4. Proof of age for admission: For the purposes of admission to elementary education. The
age of a child shall be determined on the basis of the birth certificate issued in
accordance with the provisions of the Births.
5. A child who completes elementary education shall be awarded a certificate;
6. Calls for a fixed student-teacher ratio;
7. Provides for 25 percent reservation for economically disadvantaged communities in
admission to Class One in all private schools;
8. Mandates improvement in quality of education;

SARVA SHIKSHA ABHIYAN

The SSA programme is an endeavour to provide an opportunity for improving human
capabilities of all children, through the provision of community-owned quality education in a
mission mode. The Sarva Shiksha Abhiyan had been set with specific targets. These are:

 All children in school, Education Guarantee Centre, Alternate School or ‘Back-to-

School’ camp by 2003.
 All children complete five years of primary schooling by 2007.
 Children complete eight years of elementary schooling by 2010.
 Focus on elementary education of satisfactory quality with emphasis on education for
life
 Bridge all gender and social category gaps at the primary stage by 2007 and at the
elementary education level by 2010.
 Universal retention by 2010.
8
 More recently, the Government of India has launched in 2001 Sarva Shiksha Abhiyan (SSA)
a flagship programme in partnership with the state government to cover the entire country and
address the needs of 192 million children in 1.1 million habitations. The SSA is an extensive
scheme to universalize elementary education through district based, decentralized specific
planning and implementation strategy by community ownership of the school system. The
scheme subsumes all other major governmental educational interventions of the entire country.
The SSA is to provide useful and relevant elementary education for children in the 6-14 age
groups by 2010.

RASHTRIYA MADHYAMIK SHIKSHA ABHIYAN

Rashtriya Madhyamik Shiksha Abhiyan (RMSA) is aimed at expanding and improving the
standards of secondary education classes’ eighth to tenth. The RMSA would also take
secondary education to every corner of the country by ensuring a secondary school within a
radius of five km for every neighbourhood. RMSA which is the most recent initiative of
Government of India to achieve the goal of universalization of secondary education. The SSA
program set up by the government to bring elementary education to millions of children has
been successful to a large extent, and has thus created a need for strengthening secondary
education infrastructure across the country. The HRD Ministry has taken note of this, and now
plans to implement a secondary education scheme called RMSA during the 11th plan. “With
the successful implementation of the Sarva Shiksha Abhiyan, a large number of students are
passing out from upper primary classes creating a huge demand for secondary education,” the
HRD Ministry said.

1) To ensure that all secondary schools have physical facilities, staffs and supplies at
leastaccording to the prescribed standards through financial support in case of
Government/Local Body and Government aided schools, and appropriate regulatory
mechanism in thecase of other schools,
2) To ensure that no child is deprived of secondary education of satisfactory quality due
togender, socio-economic, disability and other barriers
3) To improve quality of secondary education resulting in enhanced intellectual, social and
Cultural learning.
4) To ensure that all students pursuing secondary education receive education of goodquality.
5) Achievement of the above objectives would also, inter-alia, signify substantial progressin
the direction of the Common School System.

MID-DAY MEAL

The Mid-day Meal Scheme is the popular name for school meal programme in India which
started in the 1960s.It involves provision of lunch free of cost to school-children on all working
days. The key objectives of the programme are: protecting children from classroom hunger,
increasing school enrolment and attendance, improved socialization among children belonging
to all castes, addressing malnutrition, and social empowerment through provision of
employment to women. The scheme has a long history especially in the state of Tamil Nadu
introduced state-wide by the then Chief MinisterK. Kamaraj in 1960s and later expanded by
M. G. Ramachandran government in 1982 has been adopted by most of the states in India after
a landmark direction by the Supreme Court of India on November 28, 2001.

The objectives of the MDM scheme are:

9
  Improving the nutritional status of children in classes I-V in Government, Local Body
and Government aided schools, and EGS and AIE centres.
 Encouraging poor children, belonging to disadvantaged sections, to attend school more
regularly and help them concentrate on classroom activities.
 Providing nutritional support to children of primary stage in drought affected areas
during summer vacation.

LIMITATIONS OF THIS ACT

The Right to Education Act, like any other law, has some inherent limitations imposed by the
thought behind it.

Its benefits are further limited by the ability of the state or the citizen to enforce it. For one,
the constitutional amendment to make free and compulsory education a fundamental right
does not go beyond the age of 14 (eight years of education). This is the first limitation of the
law.

Most states, thanks to work done over the last five years, have opened schools within one km
of almost 98% of rural habitations and teacher recruitments are one.

So, setting a goal to extend the right to education up to at least 16 years of age by 2015 is
possible in large parts of India.

Simultaneously, recognising the critical importance of early childhood education to the

development of a child’s faculties, the government will do well to extend the lower limit of
the law at least to age three.

There are two factors that are helpful in this. First, under orders from the Supreme Court, the
government is obliged to universalise the Integrated Child Development Scheme (ICDS) —
the anganwadi network — to each habitation.

This has largely happened, although not satisfactorily on the quality and efficiency
parameters, in most parts of India. ICDS is expected to deliver education along with other
services but this aspect was never stressed.

So, a structure exists, which can be leveraged. Secondly, it is observed that half of the five-
year-olds in the country are already enrolled in Std I although the new act only talks about
ages six and higher.

So, getting the other 50% of five-year-olds to attend a pre-school in the school premises is
just a short hop.

Another limitation in the law is continuation of the traditional stress on inputs without
adequate attention to outcomes.

If a child goes to school for three, five, or eight years, what should his/her learning
achievement be? If some basic minimum learning is not achieved, should it not be considered
a violation of the child’s right to education?

10
In my opinion, it is not only possible but also necessary to conduct standardised tests after
classes 2, 5, and 8.

These can be text-book independent, stress-free, on-demand examinations conducted by

independent agencies. Unless such independent assessment is conducted, the quality of
learning in government schools will decline.

It is because of the poor quality of learning in government schools that parents with even
limited means choose to put their children in low-cost private schools, which may not be all
that good either.

The new law is designed to make these low-capital, low-cost schools impossible to survive
because for them to be recognised they will need to have a good building and a playground,
while also paying prescribed salaries to trained teachers.

In a city such as Hyderabad, close to 4,000 such schools will face closure.

The numbers are likely to be almost as high in every big city of Uttar Pradesh and some other
states.

Will the government find the space and funds to replace these schools? How will the
population react to these closures given their perception of government schools? Will the
government actually have the moral, political, and financial strength to close them down in
three years?

A social conviction that children of the rich and the poor should study together will be needed
if the law has to be effective. There is no leadership today that can actually provide this
conviction.

In conclusion, the government will have to take drastic and urgent steps to ensure improved
quality of education in government schools that focus on measurable outcomes. A beginning
has been made, but a long and difficult road lies ahead for the Indian child.

11
 CRITICAL ANALYSIS
What happens when a country of the size of India has over 3 million children living on the
streets? Or has over 150 million children working as bonded labourers? Or one out of every six
girl child does not live to see her 15th birthday? What happens when despite having a national
policy for compulsory primary education, only 50% of children have access to education?
The statement "Children are the future of the nation" stops making sense, then! In fact, it sounds
like an ominous prophecy. For how can we explain that even after 63 years of independence,
half of India's children are illiterate? Despite identifying primary education as a key thrust area
and possessing one of the largest networks of schools in the world?

It is a popular saying that “Education is both the means as well as the end to a better life”.
means, because it empowers an individual to earn his/her livelihood and the end because it
increases one's awareness on a range of issues. But unfortunately in today’s modern day
scenario the subject of Education is actually used by our political leaders and legislators as the
“means” for achieving the “end” common to them all. Political power. After all it makes an
integral part of their Election manifesto.
The Act suffers from some serious flaws, many of which have been objected upon by the
state governments and the professionals related to the field of education, from teachers to
parents to our very own students.

Section 16 of the Act, provides that No child admitted in a school shall be held back in any
class or expelled from school till the completion of elementary education. While it is true that
failing a child may well cause the child to intensely doubt his or her abilities, the Government
fails to appreciate that failing a child also serves as a protective mechanism. The term “fail”
has always worked as a deterrent for a child to study seriously and perform well. Failing,
actually serves as a blessing in disguise for the students. Also, detaining the child in the same
class ensures that the child learns the particular set of skills required for his/her development
and hence is a more scientific approach. Promoting the child to the next class regardless of
his performance in the previous class would also, in a way, be treating the less meritorious
students at par with the ones who have worked hard and meritoriously achieved a place in the
next level which is unfair to the good students.

The system then provides for special attention (through Section 4 of the Act) for such a child
in the higher class to make up the deficiency in skills and ability. The critical question is –
can a child who is unable to bear the workload of a junior class now deal with the workload
of a senior class in addition to taking special classes? The embarrassment of failing, which
under a system of failing a weak student is corrected at the first stage of inadequacy, now
carries over into senior classes.

Failing also provides a feedback to the teachers as well as students. Both the skills of the
student and the teaching skill of a teacher are put to test. However, the present legislation
dismisses this advantage. A child who does not learn the value of accountability,
performance, and hard work in the initial stages of its schooling will be ill-equipped to meet
these constants of life in later stages. Failure makes the students accustomed to handling
pressure and dealing with stress. The present system simply makes the child ignorant to the

12
realities of life.

Schools which do not have a certificate of recognition from the local authority or government
shall no longer be allowed to function, under Section 18 of the Right to Education Act. If
such a school is already functioning, the Act prescribes that it be shut down within 3 years if
it fails to meet norms. If a new school is set up, it must conform to the norms for a school as
laid out in the Schedule of the Act, or be shut down within three years. This brings before us
two important facts. It is erroneous to conclude that private, unrecognized schools offer a
quality of education that is less than that offered by recognized schools, and banning private
unrecognized schools further aggravates the problem of scarcity of formal education
institutions.

Section 17(1) of the Act prohibits physical punishment or mental harassment of students.
While a ban on physical punishment is laudable, the one on mental harassment is
incompletely defined. What, after all, is ‘mental harassment’? It could be anything from a
light admonition for not completing homework to vile abuses meant to strip the student of all
self-respect. The Act sheds no further light.

Section 28 of the RTE Act mandates that no teacher should engage himself or herself in
private tuition activity. The primary reason why teachers under perform in the classroom and
then require their students to attend private tuitions is the want of additional income,
unfettered by a loose monitoring and punitive system. Banning teachers from taking private
tuitions does not do away with the cause of the problem. Even if private tuitions by teachers
are successfully done away with, it still does not address the prevalence of teacher
underperformance and absenteeism. Section 24 of the Act prescribes punitive measures to be
undertaken in case absenteeism and non-performance of duties is observed. While it
prescribes the minimum duties to be undertaken by each teacher, no specification is made of
what constitutes high performance.

While the intention of the Government (through the RTE Act) in providing free education to
children till the age of 14 years is laudable, there is also a need for measures to ensure that
children (especially poor children) do not drop out of school once they lose the benefit of free
education.

The implementation of the provisions of the RTE Act will be no simple matter either. The
other shortfalls aside, the availability of funds and teachers remain significant roadblocks in
the implementation of the Act. The Act, which has made education a fundamental right of
every child, will require an investment of Rs 1.71 lakh crore for the next five years for
implementation. Recently, Delhi Government violated The RTE Act, 2009 by subjecting
children to screening procedure for admission to Class VI in Rajkiya Pratibha Vikas
Vidyalayas in the academic year 2010-2011.On the other hand The State Governments
demand for cent percent finance from the central government. In reply to them the Centre
regards Education as an essential State subject and hence puts the onus of 35 percent of the
finance on the state. The war of words still continues. The sad reality is that the future and
education of 3 million poor children is juggling between the central government and the state
government and their political motives. The Act has also been criticized for its hasty drafting.
The Question still remains. Should the future of Indian children be dependent on the faulty
drafting of laws in a country which is the largest democracy in the world? Can a country, who

13
is a signatory to many international conventions, who is one of the fastest growing economy
in the world, not provide adequate, good quality education for her children?
The RTE Act will neither help get significantly more number of kids into schools nor will
improve the learning quality of kids drastically. It is time the government started focusing on
output (i.e. the quality of learning) instead of inputs in education. And only then will India
perform better in education surveys and, more importantly, reap the benefits of its demographic
dividend.

14
 SUGGESTIONS
1. The Right to Education act should not be restricted to the age of 14 years. It should be raised
up to the secondary level or vocational level courses. The centre and the state government
should introduce diplomas/degrees with specialization in IT, media, entertainment,
telecommunication, mobile communication etc. with due reservation for the economically
weaker sections of the society.
2. CSS (Common School System) should be replaced with MSS (Model school system) based
on the needs and demands of the society where education should be given free of cost and on
private institute patterns.
3. Parents should be motivated through counselling and made aware about the RTE Act through
media, hoardings, pamphlets campaigns, rallies etc.
4. New state and central schemes like mid-day meal, SSA, RMSA along with world
organization UNICEF should target weaker sections of the society, economically backward,
females and highly populated states of India on top priority to improve efficacy of this act.
5. New born babies should be enrolled in the neighbouring school. So that the school can admit
them.
6. Provision for strict punishment regarding the violation of this Act should be made. It should
be made mandatory for all the government employees to send their children in government or
government aided institutes.

15
 CONCLUSION
Education is a powerful tool which lifts economically and socially marginalized adults and
children out of poverty and participate fully as citizens.
In the context of globalisation, education assumes greater meaning. Greatness of a nation
should not be measured by its ranking in global economic order, but by its ability to provide
quality education. The last two decade have shown enormous improvement in the literacy scene
in the country as reflected by the average literacy figures. Education is perhaps the most vital
requirement for inclusive growth, empowering individual and society, opening up
opportunities and promoting true public participation in the development process. It is an
important factor that fuels both social change and economic growth.
How much education does India need, and for what purpose? We can readily agree that
universal good quality basic education is a requisite and moral requirement of all modern
societies, for the sake of social equity, cultural values, and economic functionality. India is
actively pushing forward with its agenda for revamping and restructuring education in the
country. It is submitted that though the judiciary has made education as a fundamental right yet
it is for the State to secure it for all people. It is beyond any doubt that education is of
fundamental significance to the life of an individual and the nation.
However, realization of the objective of ‘Education to All’ is not going to be very easy- not
when the school system in the country, especially those rural areas continue to be plagued by
problems of poor infrastructure, shortage of teachers, their lack of training motivation besides
poverty and livelihood issues that are responsible for the huge drop out of rates. It is estimated
that there is a shortage of nearly five lakh teachers, while about three lakh of them are untrained
at the elementary school stage. Over 50% of schools have a student teacher ratio much poorer
than the 1:30 prescribed under the RTE Act. About 46% schools do not have toilets for girls,
which is another reason why parents do not send girl children to schools.

16
 BIBLIOGRAPHY
Cases-
Mohini Jain v. State of Karnataka, AIR 1992 SC 1858: (1992) 3 SCC 666
Unni Krishnan, J.P. v. State of Andhra Pradesh AIR 1993 SC 2178: (1993) 1 SCC 645

Books-
 DD Basu, Commentary on the Constitution of India.
 MP Jain, Indian Constitutional Law

Web links-
 http://www.lawyersclubindia.com/articles/Right-to-Education-A-Brief-Analysis-
4776.asp
 http://www.legalservicesindia.com/article/article/right-to-education-1925-1.html
 https://www.nls.ac.in/ccl/cclmedia/ER/miles.pdf
 http://ijepr.org/doc/V1-IS2_Oct12/ij4.pdf
 https://icon.oxfordjournals.org/content/2/1/148.full.pdf
 http://www.nuepa.org/Download/Publications/Occasional%20Paper-33njuneja.pdf

17