One Nation, Many Tongues: The Legal Struggle Against Linguistic Dominance in Indian States

I. Introduction:

India is one of the most linguistically diverse countries in the world, with the Constitution recognising 22 official languages under the Eighth Schedule and hundreds more spoken across its regions. This diversity reflects India’s complex social fabric, where language is closely tied to culture, identity, and regional pride. Each state often has its own dominant language, while many also host significant linguistic minorities. For instance, while Hindi is the most widely spoken language nationally, states like Tamil Nadu, West Bengal, and Kerala primarily use Tamil, Bengali, and Malayalam, respectively. This multilingualism has both united and divided the nation—enriching its cultural landscape, but also giving rise to tensions when one language is seen to dominate at the expense of others, especially in education, administration, and public services. The challenge lies in managing this diversity without allowing linguistic majoritarianism to marginalise minority voices. The historical roots of linguistic federalism in India can be traced back to the colonial period when the British administration grouped people primarily by language for easier governance. However, it was after independence that language became a key factor in shaping the political map. The demand for states organized on linguistic lines gained momentum in the 1940s and 1950s, driven by the belief that language was central to cultural identity and effective administration. This led to the States Reorganisation Commission in 1953, which recommended the redrawing of state boundaries based mainly on language, resulting in the States Reorganisation Act of 1956. This landmark reform established linguistic federalism as a fundamental principle in India’s governance, balancing regional aspirations with national unity, but also sowing seeds for ongoing legal and political debates over linguistic dominance and minority rights within states. This article aims to examine the legal tensions that arise from India’s rich linguistic plurality and the state policies that sometimes impose a dominant language within particular regions. While the Constitution recognises and protects multiple languages, the practical enforcement of language policies often leads to conflicts—especially when states promote one language at the expense of others, affecting education, administration, and public life. The article explores how these conflicts challenge constitutional guarantees, minority rights, and the balance between regional identity and national unity. It also investigates judicial responses, policy shortcomings, and the ongoing struggle to ensure that linguistic diversity is respected without allowing any language to dominate unfairly.

II. Constitutional Framework of Linguistic Rights in India :

Article 343 to 351: Official Language Provisions:

Articles 343 to 351 of the Indian Constitution lay down the framework for the use and development of official languages at the national level. Article 343 designates Hindi in the Devanagari script as the official language of the Union, while also allowing English to continue as an associate official language for a transitional period. These provisions originally envisaged a gradual shift to Hindi as the sole official language, but due to strong opposition, especially from non-Hindi speaking states, this transition was extended indefinitely. Article 344 establishes a Commission to recommend measures for the progressive use of Hindi and the development of other languages. Article 350 mandates that every state provide facilities for linguistic minorities to use their language in education and public services. Overall, these provisions reflect an attempt to balance the promotion of Hindi with protections for linguistic diversity, but tensions persist due to competing regional linguistic identities.

Eighth Schedule: Recognised Languages and the Concept of “Scheduled Languages”:

The Eighth Schedule to the Constitution lists the official languages recognised by the Union government. Initially containing 14 languages, it now includes 22 languages, reflecting India's vast linguistic diversity. Recognition in this Schedule grants languages special status and enables their development through official support, including inclusion in education, broadcasting, and administration. The concept of “Scheduled Languages” also has political significance, as it influences language policy, resource allocation, and minority protections. Languages outside this Schedule often struggle for recognition and support, which sometimes leads to demands for inclusion. The Eighth Schedule thus serves as a constitutional tool to acknowledge and preserve India’s multilingual heritage, though it also raises questions about the criteria for recognition and the representation of linguistic minorities.

Article 29 and Article 30: Cultural and Linguistic Rights of Minorities:

Articles 29 and 30 safeguard the cultural and educational rights of minorities in India, including linguistic minorities. Article 29 protects the right of any section of citizens residing in the territory of India to conserve their distinct language, script, or culture. It ensures that minorities are not denied admission to educational institutions on grounds of language or culture. Article 30 grants minorities, whether based on religion or language, the right to establish and administer educational institutions of their choice. These provisions affirm the constitutional commitment to protect the linguistic identity of minority groups, enabling them to preserve their heritage and promote their language through education. They are vital in countering the effects of linguistic dominance by majority groups and play a key role in India’s pluralistic framework.

Article 19(1)(a): Freedom of Expression and Its Linguistic Implications :

Article 19(1)(a) guarantees all citizens the fundamental right to freedom of speech and expression, which extends to the use of language. This means individuals have the right to express themselves in the language of their choice, whether in speech, writing, or other forms of communication. The linguistic implication of this right is significant in a multilingual society like India, where language is often closely linked to identity and cultural expression. However, this freedom is subject to reasonable restrictions in the interest of public order, morality, and sovereignty, which sometimes leads to legal debates when states impose restrictions on the use of certain languages. Thus, Article 19(1)(a) forms an important constitutional safeguard for linguistic expression while balancing the need for social harmony.

III. State Policies and Language Dominance:

Language-Based Reorganisation of States (States Reorganisation Act, 1956):

The States Reorganisation Act of 1956 was a landmark legislation that fundamentally reshaped India’s political map by reorganizing states largely along linguistic lines. This move was a response to widespread demands from linguistic communities who sought political recognition and administrative convenience in their mother tongue. The act aimed to create states where the majority population shared a common language, thus facilitating governance, cultural expression, and economic development. While the reorganisation helped reduce some interlinguistic conflicts, it also entrenched linguistic identities as central to regional politics. The creation of linguistic states set the stage for both greater self-expression and future tensions, especially when dominant languages in a state started marginalizing smaller linguistic communities within the same territory.

Case Studies of Dominant Language Imposition in States:

Hindi Imposition in Non-Hindi States: The promotion of Hindi as the national language has frequently met resistance in several non-Hindi speaking states such as Tamil Nadu, West Bengal, and Karnataka. Many of these states view Hindi imposition as a threat to their linguistic and cultural autonomy. This opposition has manifested in protests, political movements, and legal challenges against policies mandating the use of Hindi in administration, education, and public communication. The tension reflects a broader struggle between centralization and regional identity, where Hindi is often seen as symbolic of cultural dominance by the Hindi heartland, leading to demands for the protection of local languages and the maintenance of multilingualism.

Regional Language Hegemony:

Within many states, one regional language often dominates at the expense of minority languages. For example, in Karnataka, Kannada enjoys official primacy, sometimes resulting in the marginalisation of other linguistic communities such as Tulu and Konkani speakers. Similarly, in Tamil Nadu, Tamil is promoted vigorously through education and media, leading to resistance from linguistic minorities and migrant communities. This internal linguistic dominance can create exclusionary practices in government jobs, education, and public life, sparking demands for greater recognition and rights by minority language speakers.

Medium of Instruction in Education and the Three-Language Formula:

Education policy in India has long grappled with how to balance language instruction, especially in states with diverse linguistic populations. The three-language formula, introduced by the Central Government, mandates that students learn three languages: the regional language, Hindi, and English (though the exact combination varies by state). The formula’s intent is to promote multilingualism and national integration. However, its implementation has been uneven and sometimes controversial. In many non-Hindi states, there is resistance to compulsory Hindi instruction, while in Hindi-speaking states, regional languages and English sometimes get sidelined. The choice of medium of instruction directly affects linguistic minorities and their ability to learn in their mother tongue, which impacts educational outcomes and cultural preservation. This educational policy arena remains a key battleground for linguistic rights and dominance.

IV. Judicial Responses to Linguistic Disputes:

The judiciary in India has played a crucial role in interpreting and safeguarding linguistic rights amidst the country’s complex multilingual landscape. Courts have been called upon repeatedly to resolve conflicts arising from state language policies, minority rights, and educational language mandates. Through various landmark decisions, the Supreme Court and High Courts have shaped the contours of linguistic federalism, balancing the rights of states to promote regional languages with constitutional guarantees protecting minorities and freedom of expression.

Landmark Supreme Court Decisions:

T.M.A. Pai Foundation v. State of Karnataka (2002) Education and Language Rights:

The Supreme Court’s judgment in T.M.A. Pai Foundation v. State of Karnataka is a landmark case dealing with the right to establish and administer educational institutions, including the medium of instruction and language rights within private and minority educational institutions. The Court affirmed that minorities, including linguistic minorities, have a constitutional right under Article 30(1) to set up educational institutions and manage them according to their cultural and linguistic preferences. However, this right is not absolute and must be balanced against the state’s regulatory powers aimed at maintaining educational standards and ensuring equitable access.

In this case, the Court also discussed the relevance of the three-language formula and language instruction in schools, holding that while the state can prescribe a three-language policy, it must be implemented in a manner that respects minority language rights and does not impose unjust restrictions on linguistic minorities. The judgment underscored the importance of preserving linguistic diversity and recognized education as a key sphere for the protection and promotion of linguistic identities.

Mohd. Yakub v. State of Uttar Pradesh Use of Urdu in Official Communication:

In Mohd. Yakub v. State of Uttar Pradesh, the Supreme Court dealt with the issue of the use of Urdu as an official language in certain districts of Uttar Pradesh where Urdu-speaking minorities are significant. The case arose from the refusal of authorities to provide official communication and services in Urdu, which was contrary to constitutional and statutory provisions.

The Court emphasized that under Article 350A, the state has a constitutional obligation to provide facilities for instruction in the mother tongue at the primary stage of education to linguistic minorities. Furthermore, the official use of minority languages in areas where linguistic minorities predominate is essential for their access to government services and participation in public life. The judgment reinforced that denying official status or facilities for a minority language where the minority is concentrated violates their constitutional rights and principles of equality and non-discrimination.

High Court Rulings on Mother Tongue and Linguistic Rights:

Several High Courts have also contributed significantly to the jurisprudence on linguistic rights, particularly in protecting mother tongue education and resisting linguistic domination by majorities.

For example, the Madras High Court has consistently upheld Tamil language rights, protecting Tamil as the medium of instruction and official communication in Tamil Nadu, while also safeguarding the rights of linguistic minorities to receive education in their mother tongues. Similarly, the Karnataka High Court has adjudicated on disputes regarding the status of Kannada and the rights of other language speakers like Tulu and Konkani communities.

These rulings often emphasize the need for states to respect linguistic plurality within their jurisdictions and caution against policies that unduly favor the dominant language to the detriment of minorities. High Courts have also reinforced that linguistic rights are an integral part of cultural identity and human dignity, deserving protection under Articles 29 and 30.

Interpretation of the Constitutional “Spirit of Linguistic Plurality”:

The Indian Constitution embodies a deep commitment to linguistic plurality, recognizing that India’s unity is enriched, not threatened, by its diverse languages. The Preamble and the Fundamental Rights chapter, particularly Articles 29 and 30, protect the cultural and linguistic rights of minorities, while the language provisions in Articles 343 to 351 reflect a pragmatic approach to managing official languages without negating diversity.

Judicial interpretation consistently reinforces this “spirit of linguistic plurality,” which requires a delicate balance between majority language promotion and minority language protection. Courts have emphasized that linguistic plurality is a constitutional value essential to India’s democratic ethos and federal structure.

In practical terms, this means the state cannot impose a single language unilaterally as a condition for political or economic participation. The judiciary has reiterated that linguistic rights must be safeguarded in education, administration, and public life to prevent majoritarian dominance that can lead to social alienation and conflict.

In landmark rulings, the Supreme Court has advocated a flexible, context-sensitive approach to language policies—one that respects regional linguistic identities while promoting national integration and mutual respect among diverse linguistic communities. The “spirit of linguistic plurality” thus serves as a guiding principle in interpreting constitutional provisions and resolving language-related disputes, ensuring that India’s multilingual character remains a source of strength rather than division.

V. Language and Political Identity:

Language in India is not merely a means of communication but a powerful marker of identity, culture, and political allegiance. The multilingual nature of the country has deeply influenced regional nationalism, separatist movements, electoral dynamics, and the functioning of the federal system. Linguistic identity often acts as a rallying point for political mobilization, shaping demands for autonomy, statehood, and even secession. At the same time, it presents complex challenges for India’s federal structure, which seeks to accommodate diversity while maintaining unity.

Role of Language in Regional Nationalism and Separatism:

Language has historically been a core element in the formation and assertion of regional nationalism in India. Several movements for statehood and autonomy have been driven by linguistic identity, as communities seek recognition and political power to preserve and promote their language and culture.For example, the creation of Telangana as a separate state in 2014 was partly influenced by distinct linguistic and cultural identity claims, even though Telugu is spoken in both Telangana and Andhra Pradesh. The movement underscored perceived economic and political marginalization of Telangana within the larger Andhra linguistic region, highlighting how language can intersect with regional pride and socio-economic grievances.

Similarly, the Gorkhaland movement in West Bengal centers on the Nepali-speaking Gorkha community’s demand for a separate state to protect their linguistic and cultural heritage. This agitation reflects a broader pattern where linguistic minorities assert their distinctiveness against what they perceive as domination by larger regional or national groups.Such movements illustrate how language can become a potent symbol of political identity, leading to demands for self-rule, protection of language rights, and preservation of cultural uniqueness. However, they can also give rise to separatism and political fragmentation, challenging the unity and integrity of the Indian state.

Linguistic Assertions and Electoral Politics:

Linguistic identity plays a critical role in electoral politics across India. Political parties often mobilize support by championing language rights and regional pride, linking their electoral appeal to the protection and promotion of local languages.

In many states, political discourse revolves around language policies such as official language status, education in the mother tongue, and opposition to the imposition of dominant languages like Hindi. For instance, in Tamil Nadu, linguistic nationalism has been a major political force, with parties like the Dravida Munnetra Kazhagam (DMK) rising to prominence by vehemently opposing Hindi imposition and promoting Tamil identity.

Similarly, linguistic assertions influence candidate selection, party platforms, and voter behavior. Parties may promise enhanced funding for language promotion, recognition of minority languages, or resistance to central language policies to galvanize support from linguistic groups.

This politicization of language not only shapes regional political landscapes but also affects national politics, as language-based regional parties often become crucial players in coalition governments, influencing policy-making on language and cultural issues.

Impact on Federal Structure and Cooperative Federalism:

India’s federal structure is unique in its accommodation of linguistic diversity through the creation of states based primarily on language, as embodied in the States Reorganisation Act, 1956. This linguistic federalism was intended to foster administrative efficiency, cultural preservation, and political representation.However, the strong association between language and political identity sometimes strains cooperative federalism—the principle of harmonious relations and shared governance between the Union and states. Language-based demands and conflicts can lead to inter-state tensions, demands for further subdivision of states, or resistance to central policies perceived as linguistic impositions.

Moreover, linguistic nationalism can fuel regionalism, which may challenge national integration if demands for autonomy or secession grow stronger. The balancing act requires the central government to respect state linguistic identities while promoting policies that encourage national unity.Judicial and legislative measures often aim to mediate this tension by protecting minority language rights within states, promoting multilingualism, and encouraging cultural exchange. Yet, linguistic assertions continue to shape the dynamics of Indian federalism, requiring constant negotiation and accommodation.In this context, cooperative federalism involves not only sharing power but also recognizing and valuing India’s linguistic plurality as a cornerstone of its democratic governance. Language policy becomes a key instrument in ensuring that federal relations remain cooperative rather than conflictual, fostering an inclusive political culture where diverse linguistic identities coexist within the constitutional framework.

Role of Language in Regional Nationalism and Separatism:

For example, the creation of Telangana as a separate state in 2014 was partly influenced by distinct linguistic and cultural identity claims, even though Telugu is spoken in both Telangana and Andhra Pradesh. The movement underscored perceived economic and political marginalization of Telangana within the larger Andhra linguistic region, highlighting how language can intersect with regional pride and socio-economic grievances.

Such movements illustrate how language can become a potent symbol of political identity, leading to demands for self-rule, protection of language rights, and preservation of cultural uniqueness. However, they can also give rise to separatism and political fragmentation, challenging the unity and integrity of the Indian state.

Linguistic Assertions and Electoral Politics:

Impact on Federal Structure and Cooperative Federalism:

Judicial and legislative measures often aim to mediate this tension by protecting minority language rights within states, promoting multilingualism, and encouraging cultural exchange. Yet, linguistic assertions continue to shape the dynamics of Indian federalism, requiring constant negotiation and accommodation.In this context, cooperative federalism involves not only sharing power but also recognizing and valuing India’s linguistic plurality as a cornerstone of its democratic governance. Language policy becomes a key instrument in ensuring that federal relations remain cooperative rather than conflictual, fostering an inclusive political culture where diverse linguistic identities coexist within the constitutional framework.

VII. Policy Gaps and Administrative Practices:

India’s constitutional framework enshrines robust protections for linguistic diversity, yet the practical implementation of these protections often reveals significant policy gaps and administrative challenges. These gaps affect the effective promotion of both scheduled and non-scheduled languages, and complicate the delicate task of balancing the linguistic aspirations of majority and minority communities. Moreover, while cultural institutions such as the Sahitya Akademi play an important role in preserving and promoting linguistic heritage, their impact is constrained by broader systemic issues in policy execution and resource allocation.

Inconsistent Implementation of Constitutional Language Protections:

One of the major challenges facing India’s linguistic pluralism is the uneven and often inconsistent enforcement of constitutional safeguards. Articles such as 29 and 30, which guarantee cultural and educational rights to linguistic minorities, and Article 350A, which mandates instruction in the mother tongue at the primary level, are frequently not implemented uniformly across states.

For instance, states with strong regional language dominance sometimes neglect the linguistic rights of smaller minority communities within their borders. Despite clear constitutional mandates, many minority languages are deprived of adequate educational facilities, administrative use, or official recognition. This inconsistency stems from political reluctance, administrative inertia, and resource constraints.Furthermore, the enforcement of the threelanguage formula remains patchy, with states often prioritizing certain languages—usually their own regional language and English—while sidelining others, especially minority and nonscheduled languages. This selective implementation undermines the constitutional objective of fostering multilingualism and equal linguistic opportunities.

Issues in the Promotion of Scheduled and Non-Scheduled Languages:

The Eighth Schedule of the Constitution lists 22 “scheduled languages” that enjoy official recognition and government support. However, promotion efforts often disproportionately favor scheduled languages, leaving thousands of other languages and dialects marginalized.

Scheduled languages benefit from state-sponsored programs including literary awards, educational curricula, broadcasting, and translation efforts. Despite this, even among scheduled languages, disparities exist; dominant languages such as Hindi, Tamil, and Bengali receive more extensive support compared to smaller scheduled languages like Konkani or Sindhi.

Non-scheduled languages and dialects spoken by millions—face significant neglect. Many of these languages are at risk of extinction due to lack of institutional support and absence from formal education or administration. The lack of policy frameworks to identify, document, and revive non-scheduled languages creates a linguistic hierarchy that contradicts India’s pluralistic ethos.

This imbalance also fuels political and social tensions, as speakers of non-scheduled languages demand recognition and resources. The absence of a comprehensive national policy for protecting and promoting all languages equally remains a critical policy gap.

Role of Sahitya Akademi and Other Institutions in Balancing State and Minority Languages:

Cultural and literary institutions such as the Sahitya Akademi play an essential role in nurturing India’s linguistic heritage. Established in 1954, the Sahitya Akademi is an autonomous organization dedicated to promoting literature in all scheduled languages, including minority and tribal languages. It organizes literary awards, supports translations, and facilitates cultural exchange between linguistic communities.Through these activities, the Sahitya Akademi contributes to raising awareness and appreciation of linguistic diversity and fosters dialogue between majority and minority language speakers. It also acts as a platform for minority voices to gain national recognition, thereby promoting inclusivity.However, the reach and resources of institutions like the Sahitya Akademi are limited compared to the scale of linguistic diversity in India. The Akademi’s focus on scheduled languages means that many non-scheduled languages remain outside its ambit. Moreover, the institutional framework is often criticized for bureaucratic delays, uneven representation, and insufficient engagement with grassroots linguistic communities.Other institutions, such as the Central Institute of Indian Languages (CIIL), also work on documentation and development of languages, but systemic support at the policy level remains fragmented. There is a pressing need for coordinated efforts and enhanced funding to enable these bodies to effectively balance the promotion of dominant state languages with minority and endangered languages.

VIII. Comparative Jurisprudence:

India is not unique in grappling with the complexities of managing linguistic diversity within a democratic framework. Multilingual democracies around the world offer valuable insights into how language rights can be constitutionally protected, balanced with state unity, and practically implemented to foster inclusion and stability.

Canada is a notable example, with English and French as official languages at the federal level. The Canadian Charter of Rights and Freedoms guarantees language rights, including the right to receive government services in either language where numbers warrant. The country’s approach emphasizes institutional bilingualism, with constitutional protections that are actively enforced by courts. Canada’s federal system allows provinces to have their own language policies while adhering to national bilingualism, providing a model of cooperative federalism that respects linguistic duality without fragmenting the polity.

Switzerland manages four national languages—German, French, Italian, and Romansh— through a decentralized federal system. The Swiss model stresses linguistic equality and regional autonomy, where cantons decide their official languages and government functions. Switzerland’s success lies in institutionalizing language rights and promoting cross-linguistic cooperation, ensuring minority languages receive recognition and resources proportionate to their demographic presence.

South Africa, post-apartheid, adopted a constitutional model that recognizes eleven official languages, aiming to redress historic linguistic discrimination. South Africa’s Constitution explicitly guarantees language rights in education, government, and public media. The state is obligated to take practical steps to elevate previously marginalized languages. South Africa illustrates a proactive, rights-based approach to multilingualism designed to promote social justice and inclusion.

From these examples, India can draw important lessons:

The constitutional recognition of multiple official languages at both federal and regional levels is crucial for managing diversity.
Decentralized language policy-making allows states and regions to tailor language rights to local realities while respecting national unity.
Robust judicial enforcement of language rights ensures that constitutional guarantees are meaningful, not merely symbolic.
International frameworks like UNESCO’s Universal Declaration on Cultural Diversity and the International Covenant on Civil and Political Rights (ICCPR) emphasize linguistic rights as part of cultural rights and non-discrimination principles, offering normative guidance for India’s language policies.
Adopting these lessons can help India strengthen its legal and institutional framework to better protect minority languages, foster multilingual education, and promote inclusive governance.

IX. The Way Forward: Balancing Unity and Diversity:b

India’s challenge lies in harmonizing its rich linguistic diversity with the imperatives of national unity and administrative efficiency. The path forward requires thoughtful legal reforms, policy innovation, and inclusive governance strategies.

Legal reforms for equitable language treatment must begin with a comprehensive review of existing language laws and constitutional provisions. This includes clarifying the status of non-scheduled languages, expanding protections for minority linguistic communities, and ensuring consistent enforcement of linguistic rights across states. Amendments may be needed to strengthen the obligation of states and the Union government to provide education, administration, and communication in minority languages.

Promotion of multilingual education and administration is critical. India should reinforce the three-language formula by allowing flexible implementation tailored to local linguistic contexts. Expanding mother tongue instruction, especially at the primary level, will improve educational outcomes and cultural preservation. Similarly, government administration should be more accessible in multiple languages to enhance democratic participation.

Digital inclusion of minority languages represents an urgent frontier. The rise of digital media and technology offers unprecedented opportunities to preserve, promote, and revitalize endangered languages. Developing language technologies such as speech recognition, translation tools, and digital content in minority languages can democratize access to information and cultural expression, empowering communities and fostering inter-linguistic dialogue.

Empowering linguistic minorities through participatory policymaking is essential for sustainable linguistic pluralism. Language policies must be formulated with the direct involvement of linguistic communities to address their unique needs and aspirations. Establishing consultative bodies, funding grassroots initiatives, and promoting public awareness can strengthen social cohesion and prevent linguistic marginalization.

Together, these steps can foster a multilingual India that respects diversity as a foundation of its democratic identity, rather than a source of division.

X. Conclusion:

India’s pluralistic vision celebrated in its Constitution and lived in its vibrant society—faces continual challenges from linguistic centralism and the politics of language dominance. As the country evolves, reaffirming this pluralistic ethos becomes imperative to maintaining its democratic fabric and social harmony.

The judiciary, legislature, and administration each have distinct but complementary roles in this endeavor. Courts must continue to interpret constitutional guarantees in a manner that protects minority languages and fosters equitable coexistence. Legislators need to enact reforms that expand linguistic protections and promote inclusive policies. Administrators must implement language provisions uniformly and sensitively, ensuring that linguistic minorities receive tangible benefits.

Only through such harmonised efforts can India safeguard its linguistic diversity while nurturing national unity. This balanced approach will not only honor the constitutional promise of linguistic freedom but also strengthen the democratic, cultural, and social foundations of the nation.

Ultimately, India’s linguistic plurality is not a problem to be solved but a wealth to be celebrated—an enduring testament to the country’s commitment to “unity in diversity.”

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