Spurred by the Unnikrishnan judgment and a public demand to enforce the right to education, successive governments from 1993 worked towards bringing a constitutional amendment to make education a fundamental right. That led to the 86th amendment in December 2002 which inserted the following articles in the Constitution:
1. Insertion of new article 21A- After article 21 of the Constitution, the following article shall be inserted, namely:-
Right to education.-
"21A. The State shall provide free and compulsory education to all children of the age of six to fourteen years in such manner as the State may, by law, determine."
2. Substitution of new article for article 45- For article 45 of the Constitution, the following article shall be substituted, namely:- .
"Provision for early childhood care and education to children below the age of six years."
"45. The State shall endeavour to provide early childhood care and education for all children until they complete the age of six years."
3. Amendment of article 51A- In article 51A of the Constitution, after clause (J), the following clause shall be added, namely:-
"(k) who is a parent or guardian to provide opportunities for education to his child or, as the case may be, ward between the age of six and fourteen years."