Way To Ensure Safety Of The Child- In The Light Of School Admissions

"The aim of education in ancient India was not just the acquisition of knowledge as preparation for life in this world, or life beyond schooling, but for the complete realization and liberation of the self"- The National Education Policy, 2020.^[1]

With 36.7% India has one of the largest populations of children in the world.^[2] Children spend a substantial part of their day at school, therefore it is imperative that the atmosphere of schools remain positive and nurturing, and student safety is ensured along with the children feeling safe and secure among their care providers.

In exercise of powers delegated under Rule 43^[3] of the Delhi School Education Rules 1973, all schools including Private Unaided Recognized Schools are directed to get Police Verification done of all the teaching staff & support staff (whether regular, contractual or outsourced from any service providing agency).

The National Commission for Protection of Child Rights recently asked the Delhi government to apprise the Commission for Protection of Children, of whether police verification of the staff engaged in schools for any purpose is being carried out in Delhi in compliance with guidelines.^[4] It has been brought to light that the individuals working with children, be it in Anganwadis, in schools etc. do not undergo police verification. This failure would eventually stall all the education ventures.^[5]

Therefore, in the light of the on-going nursery admissions, parents must cautiously pick the school for the holistic development of their child.

As the government has made it a mandate to provide details, such as name of the school, details of the staff working and so on, the same has to be furnished to the authority under which the school has been registered. Moreover, the details must be displayed on the website of the school. For parents to go through the website to check the safety measures being taken by the school, not only in respect of sexual security of children, but also, physical, psychologically and emotional security.

Parents through RTI (Right to Information) may seek further details related to school. Though private schools are not covered under the RTI Act, as they are not a public authority^[6] per se, the Central Information Commission has said that any information with the government relating to the regulation and management of the private schools are covered under RTI Act. Therefore, a citizen cannot directly file an RTI application to a private school but can file an application for information to the government authority under which it is registered or to the government department which controls it.

The same was held in the case of Khanapuram Gandaiah v. Administrative Officer & Ors^[7] where the Hon'ble Supreme Court stated that as per Section 6 (Request for obtaining information) of the RTI Act, information relating to a private entity could be sought which can be accessed by a Public Authority under any other law.

Therefore, irrespective of a school being covered under the Delhi Education Act, 1973 and the Right to Education Act, 2009 or not; or being a private entity or public entity, any information may be sought through any public authority under which the school has been registered. The same is important to ensure transparency and well-being of children.

As per the Delhi Education Act and section 2 (f) of the RTI Act, any private school under section 4 and section 8 of Delhi Education Act has a duty to follow the regulatory conditions of service, and has a mandate to keep and provide a record on service records, salaries, vacant seats in classes and so on and so forth. However, information on estimated receipt of budget, statement denoting the salary disbursement or payments of the ensuing year, may not be available for the public to seek through RTIs.

However, parents must keep in mind that not all information and activities of the schools are in the records of the public authorities. Schools refrain from displaying or discussing the activities happening in their school premises to ensure the continuance of the goodwill of the school.

Instances relating to bullying, sexual offences go unreported and unaddressed by the school.[8] A 2007 study on child abuse, by the Ministry of Women and Child Development threw up a shocking statistic – of a sample of about 12,500 children, 53.22% reported having faced one or more forms of sexual abuse.^[9]

Under section 19 of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act) teachers and the school must report the instance of sexual abuse that has come to their knowledge. Sadly, the same is not reported in practice. As private teachers are vulnerable, they do not earn much salary and have a fear of losing their job. Moreover, the management of the school fears to communicate the same to police as the image of the school would be stained.

Furthermore, social stigmas and the pressure of interacting with police, restricts reporting of such offences. Often the victim is victimised[10] and despite the prevalence of prevention programs and guidelines, multiple studies have demonstrated that "teachers use programs spasmodically and selectively, omitting the essential concepts relating to children's rights"^[11].

Therefore, it is pertinent to mention that parents must be updated on the system being devised by the school and government to ensure safety and education of children. Parents must familiarise themselves with the Protection of Children from Sexual Offences (POCSO) e-Box^[12] which is an online complaint box for reporting child sexual abuse initiated by the National Commission for Protection of Child Rights (NCPCR). The said online complaint management system has twin goals, first, to help the child to report^[13] crimes coming under the purview of the POCSO Act directly to the Commission and second, to enable timely action against the offenders under the POCSO Act, 2012. Child victims of cybercrimes can also lodge their complaints on the same portal.

Further, parents must know their rights. All parents are by default, members of the Parent Teacher Association (PTA). An Executive Committee of the PTA, having a term for one year, must be formulated in every school through a General Body Meeting. However, according to Swapna Sundar, CEO, IP DOME, Member-Legal, Institutional Human Ethics Committee, NIE – ICMR, the PTA seems to be primarily focusing only on school infrastructure, fees, academics etc., and issues of child sexual abuse in school, bullying etc., are not taken up actively.

Parents must habituate themselves with digital applications such as Saahas developed by Kirthi Jayakumar, a human rights campaigner from Chennai in India, to help survivors of gender-based violence. The application enables victims to report crimes, locate medical services and find lawyers specialising in domestic and sexual violence cases. She has further set up the Red Elephant Foundation, which works in schools and colleges, training thousands of children and teachers on how to recognise and report child abuse, as she believes:

"We are living in a society where young survivors are being blamed and shamed to the extent that schools will not accept them if they have been a victim of assault."^[14]

Therefore, every day, new policies, programs and laws are being laid down that directly or indirectly impact children and young people. Parents being a stakeholder must participate in formulation of them by providing their opinion under 'public opinion and comments'. Moreover, at the global front, the Convention on the Rights of the Child under Article 12 expresses that "Children have the right to say what they think should happen when adults are making decisions that affect them and to have their opinions taken into account".^[15]

The Central Board of Secondary Education (CBSE) has laid down briefs on fire safety management, structural safety, how to deal with violence and ragging in schools, how to protect children from sexual abuse, and how to ensure safety of children in school buses, among others. Any violation or lapses with regard to student safety and well-being of children in school campuses may result in disaffiliation of the school.

The Juvenile Justice (Care and Protection of Children) Act, 2015 states that any school, institution or individuals engaged in imparting education or training that requires proximity to children needs to be accountable and be responsible to ensure their safety.

Therefore, a five-fold approach has to be followed by the schools to ensure student safety.

First being physical safety, which includes safe and secure infrastructure. The school premises must be well equipped with fire safety safeguards. The school must have resources in place to prevent and control disasters (both man-made and natural). The buildings must be earthquake resilient.

Second, is psychosocial safety, which includes appointment of counsellors in school. Teachers must be sensitised on issues such as depression. Further, school staff must be educated on physical and behavioural indicators of child sexual abuse.^[16] Closed-circuit televisions (CCTVs) must be installed at all vulnerable areas including all classrooms, stairways, galleries and other open spaces in the school. Effective measures should be taken against bullying, and sexual offences.

Third, safety during travel and transportation. School bus drivers and conductors must be hired from a reputed and authorised agency. Buses must have GPS trackers to keep a check on the performance of the driver, and parents must be provided with a live vehicle tracking app that assures the parents of their child's safety at all times.

Fourth, verification of staff and background check is a must. Verification should include place of residence, past employment, and checking for any past or on-going criminal cases. Proper records of teaching as well as non-teaching staff such as peons, administrators, receptionists, medical assistants must be maintained.

Fifth, maintenance of the visitor management system and restrictions on the entry of outsiders within its premises. If possible, schools must install fingerprint and facial recognition systems at the gate of the school.

Additionally, schools must constitute separate committees for redressal of grievances of the staff, parents and students, and form an internal committee for complaints regarding sexual harassment under Protection of Children from Sexual Offence Act, 2012 as directed in ''Handbook on Implementation of POCSO Act, 2012, for School Management and Staff"^[17] by the National Institute of Public Cooperation and Child Development (NIPCCD).

Complaint boxes should be created and records of the complaints made along with the action taken thereof must be maintained. Schools should prominently display information and disseminate details of Childline and organisations working on child rights issues.

Furthermore, students must be taught that they are the "bosses of their bodies" and that "any touch that makes you feel confused and uncomfortable is a bad touch". Being able to differentiate between the two would help them not only to protect themselves within the premises of school but also outside the school, where they often feel unsafe.

School is an institution where children develop trust with teachers. Often, children are more open and confident before teachers, especially their favourite teacher. A research paper by Leach et al. (2007) reflects that public discussion of sexual matters, especially relating to children, is largely taboo in India.^[18] Girls sometimes report boys for ragging, usually to a female teacher, the teacher's response is limited to reprimanding the culprit(s) and only if that doesn't have the desired effect the headmaster would be informed. Girls do not want their parents to hear of any incident, as they fear of being withdrawn from school. Thus, teachers would only alert parents as a last resort. Such issues are often resolved within the school, regardless of the severity of the incident, and cases rarely reach the family, and almost never to the Education Department.

A research by Chapman et al. (2013)^[19] suggested that schools should aim to foster school connectedness in children. School connectedness is defined by "the extent to which students feel personally accepted, respected, included and supported by others in the school social environment" and varies widely depending on the school environment. There is also a correlation between high levels of connectedness and a reduced likelihood of engaging in risky behaviour as an adolescent.

An Australian 2015 report, "Taking Us Seriously"^[20], which was part of a study conducted for the Royal Commission into Institutional Responses to Child Sexual Abuse surveyed wherein the children and young people were inquired about their saftey, particularly in organisations such as schools, sports clubs and holiday camps. Children and young people talked about how safe environments made them 'comfortable' and 'relaxed', encouraging them to be 'confident' and 'resilient'.

Therefore, it is the responsibility of the schools to ensure that the students come to school feeling welcomed, and safe; have a trusting relationship with at least one adult in school, understand their academic needs and behavioural expectations; and have access to mental health services in school.

Schools must take note of the fact that the school along with the teacher/staff is responsible in criminal law if they do not report instances of sexual abuse and suppress the same in the name of reputation or any pretext, and may face imprisonment up to six months or may be fined or both.^[21]

However, the need of the hour is to provide the school administration with an easy-to-use system to ensure safety and education of children, and provide parents with constant updates of their children's whereabouts.

The CBSE had issued Circular No. 03/2021 dated 05.03.2021^[22] and Circular No. 09/2021 dated 21.05.2021^[23] for display of "Mandatory Public Disclosure" at home page in school's website under prominent icon labelled as "Mandatory Public Disclosure" for easy access by the stakeholders to ensure transparency.

While the government-run educational institutions struggle with basic infrastructure needs, private schools often fail to comply with the directions issued by CBSE and governmental Educational Departments which provide guidelines for transparency, and safety and educational uniformity of the students across India (please check Annexure-A). One could not only see a vast difference in the quality of education being provided by the different players in the education sector in the days of pandemic but may also trace the path of change.^[24] As per the Unified District Information System for Education Plus (UDISE+) report 2019-20, only 22% of schools had access to the internet and less than 12% of government schools had internet in 2019-20.^[25]

All the schools affiliated with CBSE were directed to update Online Affiliated School Information System (OASIS) data by the end of February, 2022. OASIS is aimed to integrate various documents/data/information uploaded by the school and the same would be the main source of data for scrutiny of various applications and further decision thereon. The affiliated schools should share relevant information regarding infrastructure and its usefulness for safe and secure conduct of various exams, faculty strength for invigilation and evaluation purpose, available facilities for teaching as well as sports and best practices to be highlighted for collective growth.^[26]

The schools applying for affiliation must have No Objection Certificate (NOC); Recognition Certificate; Registration certificate of Society or Trust/Certificate of incorporation of the company running the school; Land Certificate as per appendix X of Affiliation Bye-Laws 2018, along with Fire Safety Certificate and Building Safety Certificate.

Submission of any fraudulent/ deliberate misrepresentation with intent to obtain affiliation through wrongful means may lead to appropriate action against the Principal, Manager concerned and authorised signatory of the Society.

CBSE has stipulated conditions for the school seeking Affiliation such as the number of students in the class should not be very large. The optimum number in a section of a class to be 40 and availability of one square metre Built-up Floor Area per child in the classrooms is an absolute necessity in the school.[27] The school needs to maintain a student teacher ratio of 30:1 and so on.^[28]

These circulars are to be compiled irrespective of the school being a private entity or a public entity. The "Mandatory Public Disclosure" must be at the home page of the school's website under prominent icon labelled as for easy access by the stakeholders to ensure transparency. However, the same if not followed by the majority of the schools (please refer to Annexure-A) and the stakeholders would have to go through the website of the school to look for the matter which often is a hassle.

In order to improve the educational standards of Indian schools, the Kasturirangan Committee on National Education Policy was formed, which observed that less than 5% of the workforce in the age-group of 19-24 received vocational education in India during 2012-2017. In contrast to 52% in the USA, 75% in Germany, and 96% in South Korea[29].[30] Therefore, NEP recommended that vocational education should be integrated in all school and higher education institutions in a phased manner over the next 10 years. The NEP aims to ensure that at-least 50% of learners in school and higher education should be exposed to vocational education by 2025.

The education system of Finland is considered as one of the best education systems in the world. Their education system is based on trust and responsibility of the schools. The Finnish system of Early Childhood Education and Care (ECEC) policy may be described with the concept of EduCare.^[31] It fulfils both the day-care needs of small children, serving an educational and instructional purpose. Internationally, the concept of EduCare has been used to describe more extensively the ECEC model of a Nordic welfare state, wherein care, education and instruction have been combined to form an integrated whole, where the same acts as a central tool of pedagogical activities.

Further, in Finland, the National Reforms in Early Childhood Education and Care in its 2021 Action plan to prevent bullying, stipulated that a separate programme is needed to support emotional intelligence and social skills in early childhood education and care as a means of preventing bullying and teasing.^[32] The action plan includes 14 measures, including equipping children with necessary tools to develop emotional intelligence and social skills already at early childhood education; providing adequate training for teachers so they can detect and prevent bullying and loneliness among pupils, granting teachers and principals the authority to intervene in disagreements and act against bullies if needed and hiring more psychologists for schools, among others.

There the upper secondary education is split into two- General and Vocational. In general education, students have all the freedom to choose their study schedules and in the end, they need to attend a matriculation exam. The scores are counted for their college applications. The Finnish National Agency for Education promotes self-evaluation for both teachers and schools to help them improve. Vocational education is job focused wherein school learning and apprenticeships go hand in hand. Students achieve competence-based qualifications after this.

Finland's educational system doesn't depend on artificial or arbitrary merit-based systems. There are no lists of top performing schools or teachers. It's not an environment of competition – instead, cooperation is the norm.

Schools in Finland often start from 9:00-9:45 a.m.. Research has shown that early start times are detrimental to students' well-being, health, and maturation, and students are more prone to unhealthy risk behaviours^[33] and drug abuse^[34,35],. Late start times correspond to improved attendance, less tardiness, less falling asleep in class, better grades, and fewer motor vehicle crashes.^[36] They have longer class periods and much longer breaks in between. The overall system isn't there to ram and cram information to their students, but to create an environment of holistic learning.

Additionally, they believe in giving less homework and outside work. Surprisingly, Finnish culture does not involve tutors, yet students there outperform students of other countries, as there cultures that have toxic school-to-life balances without the unneeded or unnecessary stress.

As per the National Education Policy^[37], the Committee formed in 2017, chaired by Dr. Kasturirangan observed the current nature of secondary school exams and entrance exams as detrimental to student learning. It recommended that the Board examinations should test only core concepts, and cover a range of subjects. Students can choose their subjects, and will have the option to take the exams on up to two occasions during a given year. Further assessment of a student would be based on the student's progress throughout their school experience and examinations will be conducted in grades three, five, and eight.

Moreover, the Committee observed that over 85% of a child's cumulative brain development occurs prior to the age of six. Since safety and learning go hand-in-hand, students should feel adequately supported and safe at school, both physically and psychologically, in order to learn to their fullest potential.

CBSE had reiterated that the onus of keeping students safe within schools would "solely lie upon the school authorities". Therefore, schools must ensure the safety and security of children in schools. The victims of school sexual abuse are often "vulnerable or marginal students".^[38] Coercive sex had been experienced by approximately 6 % of adolescents.[39] Rural boys were more likely to have experienced coercive sexual intercourse than urban boys (10.3 % v. 2.5%), urban girls were more likely to have experienced any form of sexual abuse than rural girls (37.2 % v. 25.4%).^[40]

The government has taken up various steps to protect the interest of vulnerable and marginal students, such as by setting up Kasturba Gandhi Balika Vidyalaya (KGBV) which are residential schools from class VI to XII for girls belonging to disadvantaged groups such as SC, ST, OBC, Minority and Below Poverty Line (BPL).^[41]

Though such initiatives are now in place, the Child Protection Policy in all schools is a necessity, of which students, teachers and parents must be aware of, and which must ensure holistic growth of all including such vulnerable students. This policy must encompass not just safety within the campus but also in school transport as well as cyber safety.

During the on-going nursery admissions (In Delhi, Nursery Admission Schedule for 2022-23 would be completed by 31st March 2022^[42]), especially in the view of COVID-19, parents must do their homework before getting their children enrolled in a school.

Parents must not forget, schools are an ideal place to address children's concerns about these issues. Therefore, a checklist for the parents is, whether:

1. the school monitors the activities of the staff members, visitors and strangers to
2. The school has a Draft on Child Protection Policy in place and practice
3. Proactive Measures taken by the school to Prevent Child Sexual Abuse
4. The school provides a space for reporting and encouraging children to speak up
5. Background check of staff

to ensure that they are in safe hands.

In the absence of violation of the same, parents must bring it to the attention of local authorities. Additionally, parents may avail benefits of various initiatives established by the government in the view of pandemic such as Manodarpan^[43], Vidya Pravesh Module^[44], DIKSHA^[45] (Digital Infrastructure for Knowledge Sharing), and many more.

Annexure - A
The table contains details that are disclosed on the school's official site.

S. No.	School	District	Public or Private school	Mandatory Public Disclosure	Linked to OASIS	Safety measures	Fees Components Displayed
1	Manav Sthali School [46], New Rajinder Nagar.	Central Delhi.	Private	Yes https://manavsthalischool.com/scan_document.pdf	Complied	Names of teachers disclosed	Not disclosed
2	Bal Bharati Public School [47], Ganga Ram Hospital Marg.	Central Delhi	Private	Yes, under 'About' https://bbpsgr.balbharati.org/mandatory-public-disclosure/	Complied	List of School Managing Committee, Faculty, and PTA members disclosed	Full fee structure of year 2021-22 disclosed
3	Bharti Public School [48], Swasthya Vihar.	East Delhi	Private	No	Details not available on the website	Names and photographs of teachers and staff displayed Counsellor available	Annual Charges; Tuition Fee; Development Fee; Digital Learning Fee; Online ERP Digital Learning; Science and Practical Fee; Examination Fee; Accidental Insurance; Admission Fee; and Activity Fee.
4	Kendriya Vidyalaya No. 2 [49], Delhi Cantt.	East Delhi	Public	Under 'About Us' https://no2delhicantt.kvs.ac.in/mandatory_public_disclosure	Complied	Staff details (along with pictures) disclosed	Disclosed
5	Modern School [50], Barakhamba Road.	New Delhi	Private	No	Particulars not available on the website	Details of the Headmasters and the Administrative Staff disclosed	Not disclosed
6	Dr Rajendra Prasad Kendriya Vidyalaya [51], President's Estate.	New Delhi	Public	No	No data available on the website.	Staff details (along with pictures) disclosed	Yes
7	Presentation Convent [52], Red Fort.	North Delhi	Private	Not available	Not disclosed	Managing Committee Members ERP Software: 'CampusCare®' and communication tools for managing the data of students, exam, fees, staff and their accounts, available to parents as well.	Not disclosed
8	Guru Teg Bahadur Public School [53], Model Town.	North Delhi	Private	No	Not disclosed on the website	List of Teaching Staff stated	Detail Of Fee Structure 2015-16
9	Siddharth International Public School [54], East of Loni Road.	North East Delhi	Private	Under 'School Information' http://www.siddharthschools.edu.in/wazirabadroad/school-information/mandatory-public-disclosure/	Not disclosed on the website	Staff list available.	Disclosed
10	D. A. V. Public School [55], East of Loni Road.	North East Delhi	Private	No.	Not disclosed on the website	Limited list of management and teaching staff.	Not disclosed on the website.
11	Lancers Convent School [56], Prashant Vihar.	North West Delhi	Private	Not available on the website.	Available on Google search https://www.lancersconvent.ac.in/pdf/Oasis/OASIS_website.pdf	Labour Compliance details available[1] Names of Faculty, Members of Managing Committee, transportation details available Safety Audits, Police Verification and Psychometric Tests are a recent addition to the already taken measures. Counsellor available	Disclosed in OASIS form
12	KIIT World School [58], Pitampura.	North West Delhi	Private	Not available on the website.	Not disclosed	Entab- CampusCare available for parents	Not disclosed
13	Rukmini Devi Public School [59], Pitampura.	North West Delhi	Private	Under the heading 'Quick links' https://rdpschool.edu.in/wp-content/uploads/2021/08/OASIS-2.pdf	Complied	Have digital application for parents: Attendance Detail, location etc displayed Particulars of Members of Executive Committee, Counsellor and Special Educator displayed in OASIS Form	Fee structure of year 2021-22 disclosed in OASIS Form
14	Kulachi Hansraj Model School [60], Ashok Vihar Phase-III.	North West Delhi	Private	Not disclosed on the website	Not disclosed on the website	List of the Members of the LMC, and Parent Body Members displayed List of Teaching Staff Members displayed	Not disclosed on the website
15	Vikas Bharti Public School [61], Rohini Sector 24.	North West Delhi	Private	Under the heading 'Home' https://www.vikasbharati.com//uploads/mpd.pdf	Complied	List of School Management Committee, and Parents Teachers Association (PTA) Members displayed Counsellor available Infrastructure and Faculty Details disclosed	Under Mandatory Public Disclosure
16	Vasant Valley School [62], Vasant Kunj.	South Delhi	Private	Yes https://www.vasantvalley.org/cbse-public-disclosures/	Not available on the website.	List of School Management Committee (SMC), and Parent Teacher Association (PTA) Members displayed.	Fee structure displayed.
17	Cambridge School [63], Swami Pranavananda Marg.	South Delhi	Private	Yes (under 'About') https://snp.cambridgeschool.edu.in/mandatory-public-disclosure/	Documents attached under Mandatory Disclosure are unavailable.	List of teachers, and the Managing Committee are unavailable.	Document attached under Mandatory Disclosure is unavailable
18	Laxman Public School [64], Hauz Khas Enclave.	South Delhi	Private	Yes, on the main page https://sites.google.com/a/laxmanservices.com/laxman-school-resources-2-0/mandatory-disclosure	Complied	List of teachers, and Managing Committee available under Mandatory Disclosure	Available for 2021-22 under Mandatory Disclosure
19	South Delhi Public School [65], Defence Colony.	South East Delhi	Private	Yes, at the bottom of the main page, not updated though. http://www.southdelhipublicschool.com/downloads/INFORMATION%20OF%20THE%20SCHOOL%20REQUIRED%20TO%20BE%20UPLOADED%20ON%20WEBSITE.pdf	Not disclosed on the website	-	Fee structure for 2016-2017 disclosed
20	Dr. RadhaKrishnan International School [66], Defence Colony.	South East Delhi	Private	No	Not disclosed on the website	-	Not disclosed
21	Army Public School [67], Dhaula Kuan	South West Delhi	Private	Yes https://www.apsdk.com/cbse-mandatory-public-disclosure	Complied	Counsellor available Special Educator available	Tuition Fee and Admission Charges displayed
22	J.M. International School [68], Sector-6 Dwarka.	South West Delhi	Private	Not on the main page https://www.jminternationalschool.com/dwarka/school-information?enc=e3pykX7PMGtBMW3QV1clzw==	Under School information page (documents are not clear)	Names of members of Managing Committee disclosed	Not disclosed
23	Holy Child Schoolḍ [69], Tagore Garden.	West Delhi	Private	Yes, on the main page https://holychilddelhi.org/mandatory_public_disclosure.php#undefined	Not disclosed on the website	List of School Management Committee, and PTA members disclosed.	Only Tuition Fees disclosed.
24	Hansraj Model School [70], Punjabi Bagh.	West Delhi	Private	Not disclosed on the website	Not disclosed on the website	List of teachers disclosed.	Not disclosed on the website
25	Angels Public Senior [71], Mayur Vihar Phase-III.	Shahdara district	Private	No	Not available on the website.	Names and details of teachers given.	Displayed
26	Little Flowers International School [72], Kabir Nagar, Shahdara.	Shahdara district	Private	No.	Not available on the website.	List of the Management Committee given.	Not disclosed

The list is illustrative and not exhaustive.

Observations:

1. The mandate, as per the circulares issued (Circular No. 03/2021 dated 05.03.2021^[73] and Circular No. 09/2021 dated 21.05.2021^[74]) by the CBSE, is to display the "Mandatory Public Disclosure" at home page of the school's website under prominent icon levelled as "Mandatory Public Disclosure" for easy access by the stakeholders to ensure transparency. In the sample taken, only 12 out of 26 schools displayed Mandatory Public Disclosure. However, the stakeholders would have to go through the website of the school to look for the same which often is a hassle.
2. Government run schools^[75] do not have a website. Therefore, it could not be confirmed whether such schools are complying with the statutory mandates.
3. Majority of the schools have not disclosed on their websites whether the schools have been linked to OASIS or not. While out of the small number of schools which have provided documents under OASIS and/or Mandatory Public Disclosure, have uploaded blur documents and some of these documents are unavailable. A few schools have just provided the affiliation number or have only disclosed that the school is affiliated with CBSE.
4. Schools have fairly disclosed the safety measures being taken by the school. Majority of them have disclosed the staff details and few have provided pictures of the staff as well. Counsellors have been provided in almost all the schools.
5. In general, schools do not disclose their fee structure. Out of those which do, often disclose just the tuition fee. Some schools have disclosed the fee structure of the previous academic years.

The author, Pragati Dhawan has contributed this write-up during her research assistantship at M/s. Black Robes Legal. The views, thoughts, and opinions, as are so expressed, belong solely to the author, and not to any other person in any manner whatsoever.

Sources and additional information:

1. https://www.education.gov.in/sites/upload_files/mhrd/files/NEP_Final_English_0.pdf
2. National Institute of Public Cooperation and Child Development, "Statistics on Children in India" 11 (2018).
3. Section 43. Power to issue instructions The Administrator may, if he is of opinion that in the interest of school education in Delhi it is necessary to do so, issue such instructions in relation to any matter, not covered by these rules, as he may deem fit.
   https://righttoeducation.in/sites/default/files/The%20Delhi%20School%20Education%20Rules,%201973.pdf
4. Released on 14 January, 2022 https://theprint.in/india/is-police-verification-of-staff-engaged-in-schools-being-carried-out-ncpcr-asks-delhi-govt/803839/
5. The NCPCR said in the letter to the Principal Secretary, Education Department of the Delhi government.
6. Section 2(h) of the RTI Act, 2005.
7. Special Leave Petition (Civil) No.34868 of 2009.
8. a. The victim's parents reported the crime to the school, their daughter was threatened with expulsion. https://theirworld.org/news/india-school-children-taught-to-tackle-sexual-abuse-gender-violence/ b.Three-year-old girl raped by school music teacher. https://www.dnaindia.com/india/report-three-year-old-girl-raped-by-school-music-teacher-2494837 c. The accused was arrested by the police for the third time is connection with sexual abuse cases against school students. He was acquitted in the first case. https://timesofindia.indiatimes.com/city/kozhikode/school-teacher-arrested-in-pocso-case-for-third-time/articleshow/87938778.cms d. The department of school education in Coimbatore instructed the Chief Educational Officers (CEO) to ensure that schools are not hiding incidents of child sexual abuse. The direction was issued at the meeting of CEOs held in Chennai on Tuesday following the recent death of a 17- year- old school girl by suicide in Coimbatore. Preliminary police inquiry revealed that the girl was sexually abused by a teacher. She had informed the school principal about the incident, but no action was taken against the teacher. Further, the girl was made to feel that she is responsible for the incident. Subsequently, she hung herself. Coimbatore CEO N Geetha said. "But the principal tried to hide the incident, fearing that the reputation of the school would be harmed," she said. https://timesofindia.indiatimes.com/city/coimbatore/stop-hiding-incidents-of-child-sexual-abuse-edu-dept-tells-schools/articleshow/87898097.cms.
9. Study on Child Abuse, Ministry of Women and Child Development, Government of India, 2007. http://www.indianet.nl/pdf/childabuseIndia.pdf.
10. Trudell, Bonnie; Whatley, Mariamne H. (January 1988). "School sexual abuse prevention: Unintended consequences and dilemmas". Child Abuse & Neglect. 12 (1): 103–113. doi:10.1016/0145-2134(88)90012-9. PMID 3365575.
11. Briggs, Freda; McVeity, Michael (2000). Teaching Children to Protect Themselves. Allen & Unwin. p. 2. ISBN 9781741154214.
12. https://ncpcr.gov.in/index2.php.
13. Steps to follow:
    a. open https://ncpcr.gov.in/index2.php
    b. Show the animation movie which appears on the page. The animated movie reassures the child that whatever has happened to him is not his fault and he need not feel guilty for the same. It further ensures that the NCPCR is a friend which will help her. c. Click on the arrow appearing below the movie. It will navigate the child to the next page where he can select a picture (or multiple pictures) portraying the abuse he has experienced.d. Lastly, fill the form with details such as mobile number, e-mail and description of the harassment followed by the 'submit' button. The complaint would then be registered and a unique auto-generated complaint number would be flashed.
14. https://theirworld.org/news/india-school-children-taught-to-tackle-sexual-abuse-gender-violence/.
15. https://www.ohchr.org/en/professionalinterest/pages/crc.aspx.
16. Child sexual abuse, WHO, Table 14. https://www.who.int/violence_injury_prevention/resources/publications/en/guidelines_chap7.pdf
17. https://www.nipccd.nic.in/file/reports/pocso12.pdf.
18. Leach, F., & Sitaram, S., Sexual harassment and abuse of adolescent schoolgirls in South India. Education, Citizenship and Social Justice, 2007, 2(3), 257–277. doi:10.1177/1746197907081262. The study further revealed from the data procured by open-ended interviews and a participatory workshop in two schools that girls were vulnerable to sexual harassment both within the school grounds (mostly by male pupils) and while travelling to and from school (by older boys and adult men), especially on public transport.
19. Chapman, Rebekah & Buckley, Lisa & Sheehan, Mary & Shochet, Ian, School-Based Programs for Increasing Connectedness and Reducing Risk Behavior: A Systematic Review, Educational Psychology Review 25, 2013, 95-114, https://doi.org/10.1007/s10648-013-9216-4.
20. https://www.childabuseroyalcommission.gov.au/sites/default/files/file-list/research_report_-_taking_us_seriously_children_and_young_people_talk_about_safety_and_institutional_responses_to_their_safety_concerns_-_causes.pdf.
21. Section 19 and 20 of the POCSO Act, 2012.
22. https://saras.cbse.gov.in/SARAS/Circulars/Circular3.pdf.
23. https://saras.cbse.gov.in/SARAS/Circulars/Circular9.pdf.
24. https://www.thehindu.com/opinion/open-page/the-transition-of-teaching/article31986382.ece.
25. https://pqars.nic.in/annex/256/AU1611.pdf and https://dashboard.udiseplus.gov.in/assets/images/pdf/UDISE+2019_20_Booklet.pdf.
26. https://akampat.kvs.ac.in/sites/default/files/CBSE_OASIS.pdf.
27. https://www.cbse.gov.in/cbsenew/infra.html.
28. As per the Right to Education Act, 2009, Pupil-Teacher Ratio (PTR) for primary schools must be 30:1 and for upper primary level, 35:1 and as per the Unified District Information System For Education (UDISE) the PTR for elementary schools is 24:1 and for secondary schools it is 27:1.# However, as per the latest data from Unified District Information System for Education Plus (UDISE +), in 2020-21 the Pupil Teacher Ratio (PTR) stood at 26 for primary, 19 for upper primary, 18 for secondary and 26 for higher secondary, showing an improvement since 2018-19. https://pqars.nic.in/annex/256/AU1609.pdf and https://www.education.gov.in/sites/upload_files/mhrd/files/upload_document/report_udise.pdf.
29. The Korean government played a key role in the development of Vocational education policies and established such policies in full-scale from the 1960s along with the implementation of the 5-year National Economic Development Plan. https://www.uned.ac.cr/ocex/images/stories/SINAES_1103_%20by%20LJY%201.pdf.
30. https://www.education.gov.in/sites/upload_files/mhrd/files/NEP_Final_English_0.pdf.
31. https://www.oecd.org/finland/2476019.pdf.
32. https://eacea.ec.europa.eu/national-policies/eurydice/content/national-reforms-early-childhood-education-and-care-21_en.
33. Kubiszewski V, Fontaine R, Potard C, Gimenes G. Bullying, sleep/wake patterns and subjective sleep disorders: Findings from a cross-sectional survey. Chronobiol Int. 2014.
34. Pasch KE, Laska MN, Lytle LA, Moe SG. Adolescent sleep, risk behaviors, and depressive symptoms: are they linked? Am J Health Behav. 2010;34(2):237–248.
35. In March 2000, a cross-sectional study of students in the 11th grade of eight higher secondary schools in Goa found that "Coercive sex had been experienced by approximately 6% of adolescents." The pupils affected by this experienced higher rates of substance abuse, poorer academic performance, as well as poor mental and physical health. Vikram Patel, Gracy Andrew (2001). "Gender, sexual abuse and risk behaviours in adolescents: A cross-sectional survey in schools in Goa". The National Medical Journal of India. 14 (5): 263–267. CiteSeerX 10.1.1.467.6130. PMID 11767217.
36. Wheaton AG, Chapman DP, Croft JB. School Start Times, Sleep, Behavioral, Health, and Academic Outcomes: A Review of the Literature. J Sch Health. 2016;86(5):363-381. doi:10.1111/josh.12388.
37. https://www.education.gov.in/sites/upload_files/mhrd/files/NEP_Final_English_0.pdf.
38. Hazelwood, Robert R.; Burgess, Ann Wolbert (2016). Practical Aspects of Rape Investigation: A Multidisciplinary Approach, Fifth Edition. CRC Press. ISBN 9781315316345.
39. Vikram Patel, Gracy Andrew (2001). "Gender, sexual abuse and risk behaviours in adolescents: A cross-sectional survey in schools in Goa". The National Medical Journal of India. 14 (5): 263–267. CiteSeerX 10.1.1.467.6130. PMID 11767217.
40. Ibid.
41. Unstarred Question, Rajya Sabha, 16th March, 2022 - "As on 10.03.2022, a total of 5627 KGBVs have been sanctioned in the country. Out of it, 5018 KGBVs are operational with the enrolment of 665130 girls." https://pqars.nic.in/annex/256/AU1602.pdf.
42. http://www.edudel.nic.in/upload/upload_2021_22/4861_4871_dt_30112021a.pdf and https://www.registrationstatus.in/ews-admission/
43. Unstarred Question, Rajya Sabha, 9th February, 2022. https://pqars.nic.in/annex/256/AU844.pdf.
44. Vidya Pravesh Module or School Preparation Module is a three month play based school preparation module for Grade 1 students. The Central government has issued a 12-week play-based module as a transition aid to help students ease into physical classes for the first time as schools were closed due to COVID-19. This preparatory module should be used for all Class 1 students across the country even after the pandemic, according to the National Council of Educational Research and Training (NCERT) professors who prepared the Vidya Pravesh module. This three months School Preparation Module for children entering Class I has been launched which is completely activity based and is designed to bolster a child‟s pre-literary, numeracy, cognitive and social skills.
45. DIKSHA is a national platform for school education, an initiative of National Council for Education Research and Training (NCERT), Ministry of Education. In the context of COVID-19 related disruption of schooling, DIKSHA makes it possible for all states/UTs to enable learning/education at home through innovative state programs. DIKSHA policies and tools make it possible for the education ecosystem (educationist, experts, organisations, institutions - government, autonomous institutions, non-govt and private organisations) to participate, contribute and leverage a common platform to achieve learning goals at scale for the country. DIKSHA can be accessed by learners and teachers across the country and currently supports 18+ languages and the various curricula of NCERT, CBSE and SCERTs across India.
46. https://manavsthalischool.com/
47. https://bbpsgr.balbharati.org/
48. https://www.bps.edu.in/home
49. https://no2delhicantt.kvs.ac.in/
50. https://modernschool.net/
51. https://drrajendraprasadpe.kvs.ac.in/
52. https://www.pcsdelhi.in/.
53. http://www.gurutegbahadur.in/contactus.aspx
54. http://www.siddharthschools.edu.in/wazirabadroad/#undefined
55. https://daveastofloniroad.org/
56. https://www.lancersconvent.ac.in/.
57. https://www.lancersconvent.ac.in/labour_compliance.html.
58. https://www.kiitworld.in/
59. https://rdpschool.edu.in/.
60. https://khms.ac.in/.
61. https://vikasbharati.com/
62. https://www.vasantvalley.org/
63. https://snp.cambridgeschool.edu.in/
64. https://sites.google.com/a/laxmanservices.com/laxman-school-resources-2-0/home
65. http://www.southdelhipublicschool.com/index.php
66. http://www.rkischool.com/
67. https://www.apsdk.com/
68. https://www.jminternationalschool.com/dwarka.
69. https://www.holychilddelhi.org/Index.php
70. http://hansrajmodelschool.org/
71. http://www.angelpublicschool.com/
72. https://lfisdelhi.com/
73. https://saras.cbse.gov.in/SARAS/Circulars/Circular3.pdf.
74. https://saras.cbse.gov.in/SARAS/Circulars/Circular9.pdf.
75. For instance: Government Boys, Sr. Sec. School No. 4, Sarojini Nagar; New Surya Public School, Sangam Vihar; Navyug Schools; Veer Chander Singh Garhwali Govt. Sarvodaya Bal Vidyalaya.