What the UGC Gazette Notification 2016 Portends for the State of Higher Education in India

The much-debated API (Academic Performance Indicator) system, linking promotions of faculty members in Indian universities/colleges to a quantifiable assessment of their performance, was introduced by the University Grants Commission (UGC) in its 2010 Regulations. Since then, there has been mounting resistance and discontent among massive sections of the teaching community – forcing the UGC to withdraw the said assessment framework for a while in 2013, before reintroducing it across institutions of higher education.

However, over the years, the ire of protesting teachers has translated into a sustained critique of the API system and its failure to account for the infrastructural inadequacies of public institutions as adversely impacting the promotion prospects of thousands of teachers across the country.

It was rightly argued that a point-based appraisal pattern reduces teaching as an adventure of ideas into a standardised set of visible-verifiable outcomes and deliverables, expending in this, the necessary surplus of every academic encounter. The clock-timed hours of classroom-teaching – convertible into digits and decimals – were not only incommensurate to the disaggregation of thought beyond workdays and work-hours, but also insisted on a corporate-model professionalism limiting the exact interface between the teacher[-as-service-provider] and the student[-as-client].

The perils of quantification notwithstanding, the API system practically sought to make teaching a redundant exercise in terms of ‘necessary qualifications’ for faculty promotions. With a lucrative price-tagging of the ‘value’ of research activities conducted by individual teachers outside of teaching-schedules and the consequent structures of waging intellectual productivity through the numbers of projects and publications, the API contributed to a voiding of the classroom in undergraduate colleges in many parts of the country.

Forced to prove her/his levels of productivity as the most essential claim to survival and growth within the field, the teacher needed but little to do by way of engaging students. And yet, on the contrary, the government persisted with its policy of withdrawing research grants and forcing research organisations to look for alternative sources of funding to sustain their work. Consequently, teachers have been infrastructurally forced into producing dubious research in the cause of ‘career advancement’, self-funding their way into business-rackets parading as scholarly platforms.

Conference coteries branched out like neighbourhood pandals with open-to-all subscription-routines, and citational pledges gave birth to kinship-alliances with a crass mechanising of the ‘impact factor’. In all of this, what suffered the most was the state of undergraduate education – thus diminishing the relevance of public institutions in popular perception, and aiding their systematic destruction in the cause of advocating whole-scale privatization.

While demanding research output from teachers as a ‘minimum’ requirement for promotion, the UGC chose to ignore the state of infrastructural collapse and the acute resource-crunch that most state-run colleges in India suffer from – where teachers often lack seating-space in staffrooms, let alone dedicated work-space or research facilities. When, in the cause of promotion prospects, these teachers therefore decided to fight for berths in conference schedules than inside the staffroom, the ‘biometric’ baton of attendance was threateningly brandished.

And then, predictably enough – with the dramatic flourish of bureaucratic finality! – came a Committee.

In July 2015, the Ministry of Human Resource Development constituted a committee under the chairmanship of Prof. Arun Nigavekar to conduct an “evaluation of the Academic Performance Indicator (API) Scheme as regards the entry point and career advancement of teachers by taking into account its criticism and suggest suitable improvements/alternatives”, among other issues.

In all of this, what suffered the most was the state of undergraduate education – thus diminishing the relevance of public institutions in popular perception, and aiding their systematic destruction in the cause of advocating whole-scale privatization.

But, instead of its declared aim of suggesting “improvements/alternatives” to the API, the Committee – which is reported to have submitted its recommendations to the regulatory body earlier this year – proposed a host of aggravations that not only legitimised the existing system of performance-based career advancement, but also made it far more unequal and irrational. The Gazette Notification of the Third Amendment to UGC Regulations 2010 — dated May 10, 2016 — incorporates the Nigavekar Committee recommendations with regard to both direct recruitment of teachers and API-linked promotion policy. A close reading of the Amendment notification, in the light of the original Principal Regulations 2010 as well as subsequent Amendments of 2011 and 2013, serves out an ominous foreboding for the state and status of teaching jobs in the country as also for research.

Subsequently, the DUTA (with support from other teachers’ associations across the country) launched a powerful movement against the Amendment notification and issued a call for a complete evaluation boycott in Delhi University centres. The overwhelming success of the movement and its mobilizations jolted the MHRD into first offering a ‘clarification’ and then a public statement dated May 26, 2016.

In what follows as an attempted reading of the Amendment and the government’s consequent responses, one may hope to find an answer to the question: does the Nigavekar Committee, in avowedly setting out to review the API system, try to remedy the latter’s ill-effects on teaching and research – or, does it rather seek to systemically delegitimize both teaching and research activities within institutional spaces by further entrenching the API?

Clause 15.1 of the UGC Regulations 2010 (under the Section titled “Workload”) categorically maintains that the “direct teaching-learning process hours per week” will be 16 for Assistant Professors and 14 for Associate Professors/Professors, whereas Appendix III Table I of the same document (detailing the distribution of API scores for “Teaching, Learning and Evaluation Related Activities”) explains in ‘Note a’ that “lectures and tutorials allocation [are] to add up to the UGC norm for particular category of teacher”. For all legal and policy purposes hence, this implies that the “UGC norm” is as specified in Clause 15.1, and that both “lectures and tutorials” must be counted as direct teaching-learning contact hours to be included within the specified workload norm. Accordingly, colleges and universities across the country followed the 16/14 hour time-table pattern as inclusive of tutorial periods. It needs mentioning here that owing to student enrolments exceeding maximum intake-limits alongside the infrastructural paucity of space/resource, the tutorial sessions originally envisioned with groups of 4-6 students, now effectively include between 16 to 20 members thus qualifying as full-fledged teaching workload.

The Third Amendment Notification of 2016 performs a curious sleight of calculation here. While keeping the “UGC norm” spelt out in Clause 15.1 of the Principal Regulations unamended, it overhauls Appendix III Table I of the API-based promotion scheme and deviously adds a new tally of “Direct teaching work load…to be given to different levels of teachers”. This new insertion does two things. First, it increases the “Direct Teaching Hours per week” (in obvious contravention of Principal Regulations 15.1) to 18+6 (=24) for Assistant Professors, 16+6 (=22) for Associate Professors and 14+6 (=20) for Professors.

Second, it goes on to explain that tutorials can no longer be deemed as class hours, though they must by default be included in official workload computations as a separate 6-hours-per-week bracket for every teacher. As a result, the recent Amendments effectively propose the upper limit of 24/22/20 hours of “direct teaching workload” to be reflected in official time-tables, thus leading to an average of at least 50 percent increase in computational workload arithmetic. Practical classes have been halved in terms of weightage, as compared to lectures, thus promising an even steeper change in workload within science departments.

The obvious (and clearly intended) fallout of this will be that nearly 50 percent of the existing teaching workforce in all universities will be rendered redundant henceforth, thus drastically curtailing the numbers of sanctioned posts or vacancies. Of course, the worst affected will be the ad-hoc or contractual teachers – a prodigious community of migrant teaching labour, already deprived of professional entitlements and often the basic right to human dignity — who will, in one fell swoop, be eliminated from colleges/universities on account of the unavailability of workload.

The conjecture that the current prescriptions of workload are flexible upper limits which empower colleges to keep lower cut-offs is absolutely futile, since the Amendment also mentions that for Assistant Professors the hourly tally of ‘direct teaching’ holds 100 percent weightage. Any teacher working on an “official timetable” of lower class numbers than 24 will risk an adverse impact on promotions, in terms of API scores for Category I.

While ‘Note 4’ under Category I of the same Appendix still continues to maintain that “lectures allocation [mark the deletion of the word ‘tutorials’ here!] to add up to the UGC norm for particular category of teacher”, one wonders how a ‘norm’ mandated by the Principal Regulations can be changed through sly insertions within an Appendix.

The deliberate erasure of the word “tutorials” in the above Note serves an important ideological function. Incidentally, the bi-partitioning of “direct teaching hours” through an additional 6-hours-per-week fixture for every category of teachers needs explanation in this context. ‘Note 2’ under Category I of the Amendment clarifies: “6 hours per week include the hours spent on tutorials, remedial classes, seminars, administrative responsibilities, innovation and updating of course contents”.

This means that even as these 6 hours of fixed workload must be mandatorily computed and reflected in time-tables as ‘tutorials’ or ‘remedial classes’ allotted to every teacher, they can effectively be used up for non-instructional purposes like administrative work and course-updation etc. Such a measure goes on to institutionally delegitimize and informalise the pedagogical purpose of ‘tutorials’, originally designed as a closer interface between teachers and students in order to address the problem of dismal student-teacher ratios in most colleges.

The tutorials are crucial interims facilitating rigorous practice-oriented teaching in groups smaller than a classroom lecture allows — aimed primarily at helping students from socially deprived sections who require focused guidance. The tutorial-system is a mechanism tested over time — one that has helped students struggling with the truncated learning time bequeathed by ill-planned reforms like Semesterization and CBCS. Further, it has served to inscribe an ethic of mutuality through discussions and academic interactions outside of monologic lecture-based curriculum-patterns.

The informalisation of ‘tutorials’ through the UGC Amendment of 2016 ends in a strengthening of the WTO-GATS model of higher education as service-providing exercise, requiring no commitments outside of impersonal spaces of transactional exchange between students and teachers. It further seeks to widen the gap between students coming with differential histories of social privilege, by re-entrenching the logic of merit as a priori inheritance.

Furthermore, technically speaking, while the Amendment encourages a teacher to trade time-tabled tutorial hours for “administrative responsibilities [and] innovation and updating of course contents”, they may be claimed points for in Category I under the head of “Lectures – Classroom Teaching”. The teacher will also be allowed to factor these same hours of ‘administrative’ and ‘course-updation’ routines within Category II b (titled “Contribution to Corporate life and management of the department and institution through participation in academic and administrative committees and responsibilities”) and II c (titled “Professional Development activities”).

If Clause 15.1 remains as the “UGC norm” for workload calculations for teachers, there is an interesting aporia to be noticed in the Second Amendment dated 13 June 2013. Here again, without any reference being made to the original Clause 15, ‘Note 2’ under Category I of API (within Amended Appendix III Table I) explains the manner and method of calculating teaching hours thus:

“For example, if a teacher has been assigned 20 hours of classroom teaching per week in an institution that teaches for 16 weeks per semester, the teacher would write 320 hours….Since this is 2 hours higher than the UGC norm, she would claim additional 2 x 16 hours in row 1A (ii).”

It appears from this portion of the UGC Regulations (Second Amendment) 2013 that “20 hours of classroom teaching per week” is deemed “2 hours higher than the UGC norm”.

When and how is it that 18 hours of classroom teaching per week became the “UGC norm”? Assuming that the teacher referred to in the extract is an Assistant Professor, the UGC norm followed across colleges/universities (since 2010, till 2013 and after) stipulated “16 hours” of classroom teaching, as per Clause 15.1 of the Principal Regulations. Is it true then that the change in direct teaching workload did not come about now, but was already referenced way back in 2013? In such a case, the only modality through which such a change might have been effected could be the First Amendment of 2011 – the Gazette Notification for which, dated April 9-15, 2011, however makes no reference to the Section on ‘Workload’.

Collectively examined, the three Amendments of the UGC Regulations 2010 give out a sense of secret changes being introduced not only without an acknowledgment of the need for larger consultations, but also without due process and public notification. These constitute grave procedural lapses and (intentional) errors within the UGC’s regulatory legislations, aimed at producing confusion and stealthily affirming policy-directions in higher-education.

In fact, the most frequently encountered phrase in these documents — “UGC norm” – functions as an empty shibboleth, deliberately invoked to lend a legalistic finality to bizarre violations and internal contradictions.

Following protests by teachers’ associations like DUTA, FEDCUTA and AIFUCTO, the secretary of the higher education department under MHRD had reportedly observed on May 24, 2016 that the Gazette Notification is merely ‘advisory’ in intent and not binding on teachers. And, yet for as much as an ‘advice’, the ministry issued a public statement on May 26 claiming to have “reviewed the recent amendment…and [given] direction to the UGC, under Section 20(1) of the UGC Act, 1956, to undertake amendments in the Regulation”. One only has to engage with the letter and spirit of the both the ‘clarification’ and the ‘statement’ in order to understand how they actually proceed to justify the Amendment in an oblique fashion, rather than overrule it.

Nowhere within the sham of the MHRD’s statement is there a proposal to withdraw the Gazette Notification. Instead, it vindicates the latter by morally exhorting teachers to move beyond “prescribed hours…, measured either in weeks or months”, and ironically promotes a transcendental horizon of ‘teaching’ as philanthropic voluntarism exceeding the material limits of a wage-for-work economy. Where work itself becomes a means of self-denial in the cause of higher goals of ‘social service’, there can neither be a workload-calculus nor exploitations on the basis of it. As a result, the ministry goes further in re-emphasising the 40-hour working week as the prescribed “overall workload” for all teachers – which, it asserts, is not superseded “even with the amended Regulation”.

This is not only tantamount to granting legitimacy to the Amendment, but also empowering the regulatory body to successively step up workload and make teachers be accountable for “not less than 40 hours a week for 180 teaching days”. There’s of course a hidden moral-spiritual clause in the profession that defies arithmetic and demands even more. The 26 May statement also does not retract the ‘top-up’ stipulation of “6 additional hours per week” by falsely and illegally equating it with the research time allowed to a teacher by Clause 15.2 of the Principal Regulations.

This is in line with the immediately preceding ‘clarification’ of the higher education secretary that the erstwhile API norm mandating research activities for all college and university teachers (in Category III) has now been relaxed, giving teachers an option of either undertaking research or conducting tutorial classes. The Amendment is unequivocal, however, in not providing an option between tutorial hours and research activities – because while the former accounts for API scores in Category I, the latter is applicable only for determining scores under Category III. Contrary to such dubious ‘clarifications’ and ‘advisory’ intentions, research requirements have not been waived off for any category of teachers.

The “minimum scores” required in Category III for promotion have been halved for only Stages 1 and 2 (Asst. Prof), while for Stages 3, 4 and 5 (Asst./Assoc./Prof), they have been reduced by a meagre 20 to 30 percent. Correspondingly, the individual “maximum score” attainable for almost every research activity has been slashed by 30 to 67 percent. So, for all practical purposes, one will have to show MORE ‘research output’ than earlier to reach the reduced ‘minimum scores’.

There’s more to the underlying intent within the “evaluation of the API system” that the Nigavekar Committee performs and edifies through the Third Amendment Notification. While on the one hand it seems to bring about an increase in teaching workload by about 50 percent (albeit through incorrect terms of reference and an ill-placed insertion countervailing the Principal Regulations!), the maximum permissible API score that one may claim for “Teaching, Learning and Evaluation Related Activities” under Category I has been visibly reduced from 180 points in the Second Amendment to 100 points in the Third. While the original Regulations of 2010 mandated a maximum score of 125 points in Category I, it was subsequently amended as 180 in 2013 and has now been slashed by nearly 50 percent to a meagre 100 points.

Isn’t it a remarkable irony that the same document which hikes teaching hours by 50 percent slashes its weightage for promotions by 50 percent as well? The real intention of the Nigavekar Committee is clear: far from bolstering teaching-learning activities through an apparent increase in teaching hours, it merely sought to cut down teaching jobs while at the same time delegitimizing the ‘value’ of teaching within the API-based PBAS scheme for promotions.

The devaluation of teaching-learning processes continues well into the number-games structurally incorporated by the Third Amendment within Categories II and III for API quantification. In Category II[a] (described as “Student related co-curricular, extension and field based activities”) – which includes “study visit, student seminar and other events” or “public/popular lectures/talks/seminars etc.” – the maximum annual score obtainable for promotion was originally fixed at 20 points in the 2010 Regulations. It was subsequently made 30 points in 2013, while the current Notification exactly halves it to 15. Institutionally speaking, this would inevitably translate into a lack of administrative will in terms of promoting exchange-platforms between students, while also discouraging teachers from mobilising intellectual spaces/resources for such student-activities.

Interestingly enough, the maximum allocations for the other two bureaucratic sub-heads within Category II (namely, “contribution to corporate life and management” and “professional development”) have been kept the same as originally stipulated in 2010, while it is only student-related activities which have been de-incentivised.

Category III of the API Scheme – entitled “Research and Academic Contributions” – has been integrally overhauled with the corresponding point-weightages for all kinds of publications/projects/conference papers being reduced by as much as 20 points. Not only does this downgrade academic research as of lower relative ‘worth’, but it will also aggravate apparent concerns of ‘quality’ in terms of research output — by forcing teachers to look for more such opportunities to make up for the lower weightage of each. While a singularly authored “text/reference book by [an] international publisher” carried 50 points as per 2010 Regulations and all subsequent amendments, the recent notification brings it down to 30 points. In deliberately diminishing the rigour of thought and labour that goes into authoring a book and pitching it in a publishing-market of speculative investments, this move deems the time taken for serious academic research as rather being inimical to ‘career advancement’.

Insofar as publications are now expected to pass the UGC test of being brokered by ‘commissioned’ publishers (that is, those “notified” or “identified” by the regulatory body), the Amendment conjures and abets the spectre of the mainstream while relegating alternative forms/spaces of work as irrelevant. The UGC’s enlisting of publishers as potential avenues for ‘good’/‘useful’ work will also naturally reinstate networks of monopoly capital within the publishing-market.

The recent Amendment goes as far as discouraging academic or intellectual collaboration between teachers of different universities/spaces by substituting the 60:40 ratio of point-distribution for jointly-authored publications with a 70:30 scale. An asterisked note to Category III maintains that the “API for joint publications” shall be calculated through an apportioning of 70% of the total points to the First Author, while “the remaining 30% would be shared equally by all other authors”.

And thus, in times that claim better days, and a ‘Make in India’ rhetoric which vocabularizes the need for supporting industry while resting on the backs of invisibilised labour, the teacher-worker will always remain beyond the pale of the state’s support and pride.

Collaborative work helps us teachers in testing the force of our convictions with others in the field, as much as they serve to form intellectual-political solidarities often outside of one’s own institution or discipline. The May 2016 Gazette Notification seeks to de-recognise the potential for inter-subjective alliances within communities of scholarship, as well as the very traffic of ideas so crucial to processes of intellectual production. Cultures of exchange and collective practices of work are argued to be less ‘valuable’ on the scale of point-tags, than the solipsistic egoism of ‘authorly’ teachers. By institutionalising a brand of possessive individualism premised on unequal claims of proprietorship, collegiality and its potential for meaningful dialogue are proven as detrimental to API measures of ‘advancement’.

Appendix III Table II (A) of the current Gazette Notification significantly does away with the differential API requirements for college and university teachers, by proposing a single standard of ‘minimum qualifications’ for the promotion of either. While the original UGC Regulations 2010 mandated two different tables for assessment scales of college and university teachers seeking promotion under CAS, the 2016 Amendment fuses them. This is a draconian step, threatening to take away focus from the methodological rigour of teaching demanded by UG colleges – which are traditionally expected to place more emphasis on classroom-learning than research activities. Urging a blanket homogenization of different levels of teaching and their divergent material priorities, the Nigavekar Committee – in the guise of the Third Amendment – ignores the distinct pedagogical requirements of UG teaching as opposed to PG/Ph.D supervision, and will only culminate in a climate of competitive self-aggrandisement at the cost of structural necessities and student needs.

Even as the UGC institutionalises an enumerative, quantifiable teaching-learning model through the API, its 2016 Amendment further egregiously hands out scorecards to students to rate teachers and determine their eligibility for promotion. The 2010 Regulations, Clause 6.0.11 had only offered by way of suggestion a student feedback medium — “The IQAC may also introduce, wherever feasible, the student feedback system as per the NAAC guidelines” – one that would allow students to respond to the larger institutional, infrastructural opportunities that were being made available to them, “without incorporating the component of students’ assessment of individual teachers”. The next Amendment of 2013 brings in the format of the anonymous questionnaire, even as it maintains its earlier caveat that prevents it from being used against the teacher at the time of hiring and promotion. But now the latest Amendment directly liases student feedback with an API scoring to determine promotions. An absurd score chart is given for assigning points/marks to teachers by students, which will then predicate promotions. This feedback mechanism, in all its offensiveness, can also insidiously warp the existing dynamic of mentoring, so valued by both the teacher and the student. With promotions resting crucially on feedback, the dangerous possibility of a nefarious alliance between marks and points proliferating through coteries remains high. Further, this would also create an unhealthy competitive bidding for promotions between teachers.

Within the UGC’s regulations, renewed and amended, its signing off line remains – ‘with immediate effect’, a dangling fait accompli that holds institutional funding in remand against any kind of defiance or deferral. And yet interestingly, colleges quick in implementing UGC’s farmans and diktats conveniently continue to sidestep the very important clause authorising the promotion to ‘Professorship’ for teachers in UG colleges. In 2010, Clause 6.5.1 of the Regulation read, “Ten percent of the number of sanctioned posts of Associate Professor in an Under Graduate College shall be that of Professors and shall be subject to the same criterion for selection/appointment as that of Professors in Universities”. How is it that non compliance in this case, has escaped the attention of the UGC?

What is obvious with the 2016 Amendment is how the UGC’s bureaucratised understanding rationalises intellectual labour in its deseguing of teaching, both from research as well as from the smaller group mentoring that Tutorials/Practicals make space for. Ill-conceived ‘reforms’ like the Semesterized model, the erstwhile FYUP and now the CBCS, have gone a long way in cementing both the idea and approach towards teaching that sees it as only nebulously and marginally productive in the creation of skilled, vocationalized labour. Within this is cleverly apportioned the larger goal of downsizing, double backing as it does on existing vacancies.

An entire workforce of beleaguered contractual teachers, numbering more than 4,000 in Delhi University alone, will be dismissively (un)accounted as collateral. And thus, in times that claim better days, and a ‘Make in India’ rhetoric which vocabularizes the need for supporting industry while resting on the backs of invisibilised labour, the teacher-worker will always remain beyond the pale of the state’s support and pride.

This article originally appeared on kafila.org

Rina Ramdev and Debaditya Bhattacharya teach literature to undergraduate students at Delhi University and the University of Calcutta, respectively. They have both done their Ph.D from Centre for English Studies, JNU. They are co-editors of Sentiment, Politics, Censorship: The State of Hurt (Sage, New Delhi, 2016).