(1) The AIFUCTO welcomes the clarification issued by UGC, withdrawing some of the most restrictive provisions in the draft regulations in regard to CAS in respect of incumbent teachers who were placed on Reader / Lecturer (selection grade) as on 1.1.2006 and demands that similar clarification be issued in respect of Readers/ Lecturers (selection grade) in service as on 31.12.2008, in accordance with clause 2 (a) XI of MHRD notification of the above date. The same conditions should apply for Deputy Librarian/Assistant Librarian (selection grade)/ College Librarian (selection grade) /Deputy Director of Physical Education/Assistant Director of physical Education (selection grade ) College Director of Physical Education (selection grade).
(2) AIFUCTO further demands that the UGC seriously introspect on the circumstances under which unsavory provisions were incorporated in the draft regulations, which have now been partially withdrawn. The entire episode has cast a shadow on the credibility of the drafting committee. It is unfortunate that the Committee could not even appreciate the limits of its mandate, which is confined to proposing regulations in areas that are specifically mandated by the MHRD notification of 31-12-2008. It is requested that the UGC withdraw all proposals of the committee, for which there is no specific mandate in the above notification of MHRD. While the drafting committee has exceeded its terms of reference with a view to denying the teachers some benefits graciously granted by MHRD, the committee has preferred to ignore issues like rectification of the anomalies of the previous pay revision, which has been specifically referred to the Committee for its views.
(3) The MHRD and the UGC took about three years to finalize the pay scales. The exercise of framing regulations which are to be uniformly implemented across the country would be more complex than finalizing the pay scales. The regulations proposed by the committee involve drastic changes from existing practices, the implications of which need to be studied in detail. The effective implementation of UGC scheme for ensuring uniform standards in higher education through out the country would depend up on the content and character of UGC regulations---their desirability, usefulness, inclusiveness, feasibility and effectiveness. Appropriate norms for ensuring quality and strategies for their implementation in different regions with wide disparities in socio-economic and educational infrastructure and differential local needs have to be identified. Otherwise the regulations would only become punitive measures to deny the new scales to large sections of the teachers rather than enabling incentives for greater efforts for improving the quality of higher education and, through it, promoting the ideal of inclusive development. The regulations should not therefore be finalized in haste. The committee should discuss the draft with teachers in detail by holding regional meetings as was done by Chadha Committee and modify the proposals by evaluating the feedback .UGC should then hold a final round of discussion on the revised proposals with AIFUCTO ,before finalizing the regulations.
(4) However the UGC should clarify that new pay scales would be immediately implemented and arrears paid and that recruitment and promotions at all levels would continue in accordance with existing provisions, pending finalization of the regulations ,as the entire system of higher education cannot be permitted to come to a standstill till UGC notifies its new regulations.
(5) AIFUCTO welcomes the proposal to give weightage to the functions of teaching, research and extension for direct recruitment and CAS promotions, thereby conceding the long standing demand for recognition of the crucial role of extension in a wholesome programme of higher education. However the criteria suggested for the measurement of the contributions to teaching and research are seriously flawed. The criteria for extension need to be supplemented.
In respect of teaching, an arbitrary decision based on the percentage of classes actually engaged by a teacher in relation to the actual workload assigned to him/her may not always be justifiable as classes are often disrupted for reasons beyond the control of the individual teacher. A more appropriate method would be to fix the minimum requirement of contact hours to be engaged by a teacher in relation to the number of actual contact hours the institution concerned would engage and the total workload assigned to the teacher, making due allowances for eligible leave, duty leave and other factors. Similarly, the extent of familiarity with up to date teaching material and contribution to the development of innovative teaching methods would depend to a large extent upon the institutional resources actually available to the teacher. The production/publication of teaching materials would not only require intellectual input, but inputs from external agencies, the distribution of which is often skewed. At present there is little scope for individual teachers in affiliated institutions for developing new curricula and teaching new courses. Developing innovative teaching methods/CDs/ICT materials/teaching learning modules require creation of sufficient infrastructure and opportunities in the colleges/universities, which is beyond the control of individual teachers. Parameters for assessing contribution to professional activity are arbitrarily fixed. Institutional governance responsibilities are often arbitrarily allotted to teachers in colleges and universities .Hence this is an unrealistic indicator of the performance of a teacher. No teacher should be victimized due to the operation of factors beyond his control. The norms for ensuring social accountability should not impinge on the claims of the individual teacher for career advancement or encourage the procurement of false evidence through dishonest means. The UGC should evolve a broad set of transparent norms which could be applied in different situations.
The qualitative distinction sought to be drawn among international, national and local journals and the heavy reliance on impact factor and the insistence on publication as different from other evidence of research emanate from severely flawed notions about quality and its certification. The global/urban/colonial mindset which prioritizes publications in international journals over national /local journals will cultivate an inferiority complex in academics that would have long term adverse impact on innovative research in this country. More over, the avenues for publication in international journals with high impact factor would vary from discipline to discipline, with new generation subjects getting the most exposure and humanities, especially local languages, getting least exposure. The reliance on publication as evidence of research will only transform Indian higher education into a haven for academic mafia, who will dictate the terms and conditions for research, severely compromising the autonomy of the individual teacher-researcher. There are no quick fix solutions for ensuring quality. Quality in research cannot be promoted by authorizing an external agency to certify the quality of research output, as is done in relation to mass produced consumer items available in the global market. Each original research is unique and the UGC norms which encourage conformity to global/urban standards will only promote uniformity and mediocrity. We need to device an internal and localized quality assurance mechanism in each university, if we are to ensure originality in research. There should also be a proper mechanism to assess the quality of a research paper, even if it is not published, internationally, nationally or even locally. The insistence on publication as the only evidence of quality is academically unacceptable. Similarly the proposal to equate the quality of a project work with the quantum of financial input that goes into the project is academically indefensible. Such an approach would only further aggravate the existing unhealthy competition for cornering the most lucrative projects. The basic contradictions in the draft regulations---measuring quality in terms of quantity and academic input in terms of monetary input and of equating the global with the local and standards with standardization ---will have to be addressed.
The scope of extension activities that would count for CAS needs to be enlarged. The activities listed do not seem to provide any space for individual contribution to the extension of knowledge outside the boundaries of higher education institutions through lectures or written communications conducted through the visual/print media. All group/individual activities which would have an impact on the dissemination of knowledge/ services for the benefit of the larger community should count for CAS. Individual universities may be authorized to develop localized criteria for quantification of the contribution of the individual teacher to extension, which could include contributions for strengthening PRIs. There should also be provision for giving greater weightage to extended extension programmes and action researches, which are properly documented and certified. AIFUCTO would submit detailed proposals in this regard in due course. Uniform standards in higher education across the country are not ensured by promoting uniformity and conformity. What is needed is an enabling regulation that would encourage a variety of academic engagements that would spur creativity, which is the hall mark of quality in higher education. The global/urban centred norms presently set out encourage elitism and uniformity and discourage creativity. While a common weightage for teaching ,research and extension in the ratio of 50: 30:20 may be fixed across the board for universities and colleges and for all categories of teachers , the performance indicators may vary ,depending on local, institutional and individual resources/needs .A system of individualized performance appraisal for ensuring accountability which would not disturb the autonomy of the individual teacher to innovate and to make appropriate responses to the local needs will have to be developed. It is the considered view of AIFUCTO that the Performance Appraisal Scoring System (PASS) through Academic Performance Indicators (API) and Weightage Points (WP) should not be implemented without widespread consultation and consensus. AIFUCTO rejects the regulations in its present form and content.
(6) While it would be appropriate for UGC to fix the norms for subject experts, universities should be permitted to nominate them. The regulatory role of UGC is best exercised when it is not mixed up with executive functions. An apex national level agency like the UGC need not be entrusted with micro-level managerial functions, which would impinge on the autonomy of the universities.
(7)There should be separate committees for selection of new recruits and screening of existing teachers for CAS promotion. The composition of the selection committees and screening committees in colleges should be different. While the management of the college may be represented in the selection committee, the screening committee should be a body of experts in which the management need not be represented. The experts to the selection committees for recruitment/ screening committees for career advancement should be nominated by the Vice Chancellor from among a panel of experts approved by the Academic Council.
(8)The Screening Committee for CAS and the procedure for screening under CAS should be separately notified in the regulations.
(9) The provision that universities would identify the posts for direct recruitment/deputation /CAS promotion in consultation with colleges would provide room for nepotism and corruption, compromising autonomy of the individual teacher. Universities should take the decision on the basis of transparent norms, which can be uniformly applied.
(10) The contribution to extension should be taken into account along with teaching and research for the direct recruitment of the Principal. Administrative experience may also be counted as an additional qualification.
(11) The proposal to make IQAC mandatory and to entrust it with the responsibility of documentation and record keeping in respect of the academic performance of the teachers should be withdrawn.
(12) Insert Clauses 2 (a) ix, x and xi of MHRD notification dated 31-12-08 in place of draft UGC regulations 6.4.2., 6.4.3., and 6.4.4. Similar conditions should apply to Deputy Librarians / College Librarian and Deputy Director of Physical Education / College Director of Physical Education in equivalent positions.
(13) The benefit of reduction in the number of years for moving into higher AGP should be available to Assistant Librarian/ College Librarian/Assistant Director of Physical Education (senior scale) /College Director of Physical Education (senior scale), possessing PhD/MPhil, irrespective of whether it was acquired at the time of entry or later.
(14) Deputy Librarians /Director of Physical Education directly recruited prior to 1.1.2006 should be placed in pay band III, with AGP of Rs.8000 on 1.1.2006 and placed in Pay Band IV on completion of three years in the grade.
(15) Previous service with/without break, whether in permanent or temporary capacity, whether appointed against substantive or temporary vacancy, whether absorbed in same post in continuation of adhoc appointment or not, should be counted for placement/ promotion.
(16) Where the system of five day week is introduced in place of six day week, the number of working weeks would be appropriately increased and weekly workload of individual teacher appropriately reduced so that the yearly workload of a teacher under both systems would be the same.
(17) The stipulation that only PhD holders will be placed /promoted as Associate Professors should be deleted.
(18) It should be specifically stated in the UGC regulations that those already designated as professors shall continue to be so designated.
(19) The most important anomaly that needs to be rectified in respect of the implementation of the V UGC Pay scales is that pertaining to placement in the scale of pay of 14940/- on completion of five years in the post of Reader /Selection Grade Lecturer. While the placement was permitted on completion of five years in the Selection Grade /Reader in respect of all who had come into it as on 1.1.1996 , the benefits were denied to those who had come into Selection Grade /Reader after 1.1.96. Even as numerous petitions are pending in different High Courts, a judgment has been issued by the High Court of Kerala on 21st January, 2009 in Writ Appeal Nos.1394, 1881, 1925&2067 of 2008, a copy of which is enclosed herewith. As the petition has been disposed of with the concurrence of both MHRD and UGC, it has become conclusive, leaving no scope for further appeal. It has been ordered as follows:
“Those teachers who were Lecturers as on 1.1,1996 and who were subsequently placed in the Selection Grade after 1.1.1996 ,they will be entitled to draw the scale of pay of Rs.14940/-on completion of five years in the selection grade .”The above order is specifically applicable only to the petitioners. Other teachers would now move the courts to ensure the extension of the same benefits. In view of the conclusive nature of the judgment, AIFUCTO would appeal to UGC to urgently take up the matter with MHRD and issue general orders implementing the benefit of fixation at 14940/- to all teachers who come into selection grade after 1.1.96 and to release the central assistance for the payment of arrears to teachers across the country who will be benefited by the orders , with a view to earning the goodwill of the teaching community ,by avoiding further litigation in the long pending issue.
(20) UGC should address the Central Government on the following issues:
a. to provide 100% central assistance to the States for the first five years and 50% for the next five for the implementation of the scales and to mandate simultaneous and uniform implementation throughout the country, as recommended by the Chadha Committee.
b. to remove the cap on professorship to 10% of the number of teachers and to make professorship available to all teachers who fulfill the required norms.
c. to grant the triple benefits of Pension, Gratuity and GPF to teachers appointed after 1.1.2004 d. to do away with its insistence on PhD in “relevant discipline” for awarding advance increments, as such a provision is likely to exclude all research in interdisciplinary area from the purview of incentives (The very concept of a particular area of study as irrelevant to another area of study is questionable as the boundaries of established disciplines are becoming porous)e. to fix 12 years as minimum service for the post of University Librarian/ University Director of Physical Education, as in the case of a University Professor The above representation is submitted without prejudice to more comprehensive and paragraph wise responses to be made by AIFUCTO in due course, after holding detailed discussions at various levels.
Thomas Joseph Asok Barman President General Secretary