
New Delhi – In a strongly worded formal representation to the University Grants Commission (UGC), Dheeraj Singh, founder of the Global IIT Alumni Support Group and an IIT Kanpur alumnus from the class of 2004, has called for robust accountability measures in the draft UGC Guidelines on Uniform Policy on Mental Health & Well-being for Higher Educational Institutions. The submission, based on RTI-derived data and publicly reported incidents, highlights critical gaps in implementation and oversight, particularly within the Indian Institutes of Technology (IIT) system, where at least 40 student suicides have been recorded since the Ministry of Education's Framework Guidelines for Emotional and Mental Wellbeing of Students in Higher Education Institutions were issued on July 10, 2023.
The representation comes in response to the UGC's invitation for stakeholder comments on the draft guidelines, which aim to standardize mental health support across higher educational institutions (HEIs). Singh argues that while the 2023 framework addressed judicial concerns and high-profile student deaths, the persistent tragedy underscores a "prima facie case that the central issue is not absence of policy, but failure of implementation and oversight."
Singh's letter points to a glaring "absence of enforceable accountability" in the draft guidelines. Despite outlining institutional structures, committees, reporting formats, and activities, the policy fails to specify who bears responsibility for ongoing failures, such as continued student suicides despite claimed compliance. Key concerns include:
Unclear Consequences: No provisions for repercussions in cases of persistent institutional failure.
Ambiguous Apportionment: Lack of clarity on dividing responsibility among institutional heads, governing bodies, regulators, and the Ministry of Education.
"In matters involving loss of life, such ambiguity undermines both administrative responsibility and constitutional safeguards," Singh writes, emphasizing that these shortcomings erode the policy's effectiveness.
The draft's heavy reliance on internal committees and self-generated data for compliance monitoring raises red flags for Singh, who describes it as creating an "inherent conflict of interest" – especially in student death cases. He insists that "independent scrutiny is a minimum requirement where fundamental rights under Article 21 are implicated," referring to the right to life enshrined in the Indian Constitution.
Additionally, Singh criticizes the "selective and ad-hoc inquiries" into suicides at individual campuses, often prompted by public outcry. While acknowledging their necessity, he argues they lead to "unequal treatment" and cannot replace "continuous, system-wide oversight." All student suicides post-July 2023, he contends, deserve equal and systematic examination to prevent episodic responses from substituting for proactive measures.
Underpinning the representation is a firm invocation of constitutional duties. Citing the Supreme Court's affirmation that mental health is integral to the Right to Life under Article 21, Singh asserts that student mental health is "not a discretionary welfare measure but a constitutional and institutional obligation." Without enforceable accountability, he warns, the guidelines "risk falling short of constitutional compliance."
To address these issues, Singh urges the UGC to implement the following reforms:
a. Permanent Independent Commission: Establish a body with judicial or quasi-judicial representation to examine all student suicides in HEIs since July 2023.
b. External Audits: Mandate regular, independent audits of institutional mental health systems.
c. Fixed Responsibility: Assign personal and institutional accountability to heads of institutions and governing bodies for failures in prevention, response, and reporting.
d. Outcome-Based Incentives: Link accreditation, funding, and leadership tenure to demonstrable outcomes, rather than mere procedural compliance.
e. Annual National Report: Publish a yearly report on student suicides, mental health outcomes, and institutional performance, drawing from verified data.
Singh concludes his letter with a stark warning: "A uniform policy without accountability risks becoming a record-keeping exercise rather than a life-protective framework. The credibility of this initiative will ultimately be judged not by the comprehensiveness of guidelines, but by whether preventable deaths decline and responsibility is clearly enforced."
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