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Dear PM , Shri Modiji :
In the context of the ongoing controversy / agitation / student protests re NEET paper leakage and your assurance to the nation regarding complete overhaul of NTA ( National Testing Agency ) , you have already taken following steps :
> Set up Fast Track Courts
> About to introduce a bill for " Prevention of Leakage of Exam Papers "
While these are very welcome steps , I feel these are merely peripheral to the central issue of RESTRUCTURING of NTA
Towards this , I submit herewith , a Comprehensive Framework for :
' Central Testing Commission "
- a Constitutional Statutory Body , similar to our current Central Election Commissiion
I urge you to circulate this draft ( with modifications that you deem necessary ) to all Political Parties for their considerations
with regards,
Hemen Parekh
www.ntaNEET.net / 25 July 2026
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DISCUSSION DRAFT — FOR CIRCULATION AMONG POLITICAL
PARTIES
A FRAMEWORK FOR THE
CENTRAL TESTING COMMISSION (CTC)
A Constitutional, Statutory Body for
India's Testing Infrastructure — Modelled on the Election Commission of India,
Governed in the Federal Spirit of the GST Council
Originating proposal:
“The Structural Reform: A Federal ‘GST Council’ Model for NTA”, from the open
letter to the Prime Minister, “No More Exam Paper Leaks? YES”, published 22
July 2026 at myblogepage.blogspot.com.
Prepared by: Hemen
Parekh |
Mumbai | 25 July 2026
Purpose of this document:
to translate a one-paragraph structural proposal into a complete, examinable
institutional design — suitable for circulation to the Union Government, all
recognised political parties, State Education Departments, and the
Parliamentary Standing Committee on Education, for comment before any
legislative drafting is undertaken.
1. Background and Rationale
India's National Testing
Agency (NTA) currently functions as an autonomous body registered under the
Societies Registration Act, working under the administrative control of the
Ministry of Education. It conducts examinations of enormous national consequence
— NEET-UG alone drew over 2.4 million candidates in recent cycles, JEE (Main)
over 1.2 million — yet it carries none of the constitutional insulation,
permanent physical infrastructure, or federal governance that its scale and
stakes demand.
This creates three
recurring failure modes, each visible in the paper-leak and malpractice
controversies of 2024–26:
•
Political
exposure — a body under a Ministry is one order away from being pressured on
scheduling, centres, or re-tests, and one change of government away from a
change of leadership.
•
No
permanent infrastructure — the NTA rents private computer centres and school
premises exam-by-exam, recreating the same physical vulnerabilities (printed
papers, human couriers, temporary staff) every cycle.
•
No federal
ownership — States bear the law-and-order, administrative, and reputational
burden of exams conducted on their soil, without a seat in how those exams are
designed, secured, or scheduled.
Two institutions already
solve analogous problems in India's constitutional architecture, and this
framework proposes fusing their logic:
•
The
Election Commission of India (Article 324) — a permanent constitutional body,
insulated from the Executive, reporting to the President, that conducts free
and fair elections at a scale (nearly a billion voters) larger than any
examination system.
•
The GST
Council (Article 279A) — a federal policy-making body where the Centre and
every State/UT sit together, with a weighted voting formula that prevents
unilateral action by either side.
The proposal below is a
Central Testing Commission (CTC) that borrows its constitutional independence
and permanence from the Election Commission model, and its federal policy
governance from the GST Council model — exactly as set out in the originating
blog post.
2. Constitutional and
Statutory Status
2.1 Instrument
The CTC is established by
a new constitutional provision (proposed insertion, on the pattern of Article
324), supplemented by a Central Testing Commission Act enacted by Parliament
that fleshes out procedure — the same two-tier design (brief constitutional
anchor + detailed parliamentary statute) used for the Election Commission.
2.2 Reporting Line
The CTC reports directly
to the President of India and is functionally independent of the Executive (the
Ministry of Education retains a policy-sponsor role only, through the Governing
Council described in Section 3, and has no power of superintendence, direction,
or control over the CTC's testing operations).
2.3 Central Testing Commissioner — Appointment
and Protection
•
Appointed
by the President on the recommendation of a selection collegium comprising the
Prime Minister, the Leader of the Opposition in the Lok Sabha, and the Chief
Justice of India — mirroring the reformed CEC/EC appointment process.
•
Fixed,
non-renewable tenure of six years or until age 65, whichever is earlier.
•
Removable
only through the same process as a Supreme Court judge (address by Parliament
on grounds of proven misbehaviour or incapacity) — not at the pleasure of the
Executive.
•
Salary,
allowances, and the Commission's establishment expenditure charged to the
Consolidated Fund of India — not subject to annual budgetary vote, exactly as
with the ECI.
•
Supported
by two additional Central Testing Commissioners, so that major decisions (exam
calendar, centre closures, results annulment, re-test orders) are taken by a
three-member Commission rather than one individual — mirroring the three-member
Election Commission.
3. The Governing Council —
Policy-Making Role ONLY
The Governing Council is
the GST-Council-equivalent federal forum. Its role is strictly confined to
policy. It has no operational, administrative, or exam-conduct authority — that
authority is exclusively vested in the CTC and the STCs (Sections 4–5),
insulated from the Council by statute.
3.1 Composition
•
Chair:
Union Minister for Education.
•
Members:
Education Ministers of every State and Union Territory.
•
Member-Secretary
(non-voting): Central Testing Commissioner, ex officio — present to brief the
Council and receive its policy directions, not to vote on them.
•
Up to
three domain experts (assessment science, cybersecurity, federal governance)
nominated for fixed two-year terms, non-voting.
3.2 Voting Formula (on the GST Council pattern)
Every decision requires a
three-fourths majority of weighted votes cast, with the Centre's vote having a
weight of one-third of the total votes cast, and the votes of all States and
UTs together having a weight of two-thirds — preventing the Centre from
imposing policy unilaterally, and equally preventing a State minority from blocking
reform.
3.3 Matters within the Council's Policy Mandate
•
Approving
the annual national testing calendar (which exams occur when, to avoid
clashes).
•
Approving
syllabus and eligibility frameworks referred to it by subject-expert
committees.
•
Approving
the principles governing examination fees, fee waivers, and concessions.
•
Deciding
whether a new exam should be brought within, or an existing exam removed from,
the CTC's ambit.
•
Approving
the CTC's multi-year technology and infrastructure roadmap and its budget
allocation formula across States.
•
Laying
down the overarching data-protection and citizen-data-governance policy for
testing data.
•
Adjudicating
inter-State disputes over exam scheduling, centre allocation, or quota-related
policy questions referred to it.
3.4 Matters Explicitly EXCLUDED from the Council
(reserved to CTC/STC)
•
Setting
or reviewing any individual question paper.
•
Evaluation,
scoring, moderation, and result generation for any specific exam.
•
Appointment,
transfer, or discipline of any CTC/STC official below Commissioner rank.
•
Individual
candidate grievances, malpractice inquiries, or re-test decisions for a
specific exam (these go to the Testing Tribunal, Section 4.3).
•
Day-to-day
security protocols, encryption architecture, or vendor selection for exam
delivery.
4. Central Testing
Commission (CTC) — Scope of Functions
The CTC is the executive,
operational arm — the permanent, round-the-year body that actually conducts
examinations, exactly as the Election Commission's secretariat conducts
elections between policy inputs from Parliament.
4.1 Structure
•
Headquarters:
New Delhi, with five Zonal Offices (North, South, East, West, North-East) —
mirroring the ECI's regional structure.
•
A
permanent Testing Corps of technical, security, and invigilation staff,
employed directly by the CTC — not contracted afresh for every exam cycle.
4.2 Core Functions
•
Sole
ownership and operation of all Central-level examinations listed in Section 6.
•
Ownership
and enforcement of the anti-leak security architecture — the two-layer,
time-stamped encrypted question-paper delivery model (the OSOD — One Session,
One Day — architecture proven at ntaNEET.net), extended nationally.
•
Design,
procurement, and maintenance of the permanent physical testing infrastructure
described in Section 7, for use by both CTC and STCs.
•
Functional
oversight of every State Testing Commissioner (Section 5).
•
Empanelment
and periodic security/integrity audit of every exam centre, Central and State.
•
Publication
of a public, auditable national testing calendar and results database.
4.3 Testing Tribunal
A statutory Testing
Tribunal, attached to the CTC but functionally independent (retired High Court
judges as members), to hear malpractice complaints, re-test petitions, and
candidate grievances — on the model of the Election Petitions process — so that
individual disputes no longer default to writ litigation before High Courts and
the Supreme Court.
5. State Testing
Commissioner (STC) — Scope of Functions
5.1 Appointment and Dual Reporting
One STC per State/UT,
appointed by the President on the CTC's recommendation — to insulate the
appointment from State-level political capture, exactly as District Election
Officers are State civil servants but come under the ECI's direct functional
command during an election.
•
Administrative
reporting: to the concerned State Education Minister — for staffing, local
logistics, land/building allocation, coordination with district administration
and police, and day-to-day resource support.
•
Functional
reporting: to the CTC — for exam methodology, the encrypted-delivery security
protocol, technology platform standards, integrity audits, the exam calendar,
and results processing. On functional matters, the CTC's direction is binding
and takes precedence over any conflicting administrative instruction.
5.2 Core Functions
•
Sole
conduct of all State-level, Municipal-level, and Panchayat-level examinations
listed in Section 6.
•
Local
implementation of the CTC's security protocol, using CTC-owned infrastructure
(Section 7) situated within the State.
•
First-level
grievance redressal for State-level exams, with appeal to the Testing Tribunal.
•
Liaison
with the State Education Department, State Public Service Commission, and local
bodies on eligibility criteria for State-notified posts.
6. Comparative Scope of
Functions — CTC vs STC
|
Function |
CTC (Central) |
STC (State) |
|
Governing
Council policy implementation |
Executes Council
policy nationally |
Executes within
the State, per CTC standards |
|
Central-level
exam conduct |
Full ownership —
JEE, NEET, CUET, UGC-NET, central recruitment, etc. |
Provides
venue/local support only, on CTC's instruction |
|
State/Municipal/Panchayat
exam conduct |
Sets security
& technology standard only |
Full ownership
within the State |
|
Question bank
& AI paper generation (OSOD model) |
Owns and
operates the architecture |
Uses the
architecture under CTC licence |
|
Anti-leak
security & encryption protocol |
Designs,
mandates, audits |
Implements and
reports compliance |
|
Physical testing
infrastructure (Section 7) |
Owns
Tier-1/Tier-2 centres nationally |
Operates centres
within the State |
|
Result
processing & certification |
Central-exam
results |
State-exam
results, on CTC-approved platform |
|
Grievance
redressal |
Testing Tribunal
(final appellate) |
First-level
redressal within the State |
|
Budget |
Consolidated
Fund of India + Council-approved allocation formula |
State share +
CTC infrastructure grant |
7. Examinations within the
CTC/STC Ambit
The allocation below
follows the electoral analogy in the originating proposal: Central-level exams
are conducted directly by the CTC (as the ECI conducts Lok Sabha elections);
State-level exams are conducted by the STC under CTC's functional standards (as
State Election Commissions/ECI conduct Assembly elections); Municipal and
Panchayat-level recruitment exams follow the same STC-conducted,
CTC-standardised model as local body elections.
7.1 Central Level (CTC-conducted — parallel to
Lok Sabha elections)
1.
JEE
(Main) — engineering entrance
2.
NEET-UG
and NEET-PG — medical entrance
3.
CUET-UG
and CUET-PG — central university common entrance
4.
UGC-NET
— university faculty/JRF eligibility
5.
CSIR-NET
— science research eligibility
6.
CTET —
Central Teacher Eligibility Test
7.
Central
Government recruitment exams currently under the Staff Selection Commission
(CGL, CHSL, MTS, GD Constable, etc.)
8.
Railway
Recruitment Board (RRB) examinations
9.
Common
written examination stage of Public Sector Bank recruitment (IBPS PO/Clerk/SO,
SBI)
10.The objective/screening (Preliminary) stage of the UPSC Civil
Services Examination — integrity layer only; the subjective Mains and Interview
remain with UPSC
11.Common written entrance test for Defence recruitment
(Agnipath and equivalent streams)
12.All-India Bar Examination (if brought within scope by future
legislation)
7.2 State Level (STC-conducted — parallel to
State Assembly elections)
1.
State
Common Entrance Tests — Engineering / Medical / Pharmacy / Agriculture / Law
(e.g., State CET)
2.
State
Teacher Eligibility Test (State-TET)
3.
State
Public Service Commission recruitment examinations (Group A/B/C posts)
4.
State
Police recruitment (Constable, Sub-Inspector, and allied cadres)
5.
State
polytechnic and diploma common entrance tests
7.3 Municipal Level (STC-conducted — parallel to
Municipal Corporation elections)
1.
Municipal
Corporation staff recruitment (clerical, engineering, sanitation supervisory,
health-worker cadres)
2.
Municipal
school teacher recruitment
7.4 Panchayat Level (STC-conducted — parallel to
Panchayat elections)
1.
Gram
Panchayat and Zilla Parishad staff recruitment
2.
Written-test
component of Anganwadi worker / ASHA worker eligibility, where a written test
is prescribed
8. Permanent Physical
Infrastructure
The central structural
flaw in the present system is that it owns almost no infrastructure: computer
centres are rented exam-by-exam from private players and schools. This
framework proposes CTC/STC-owned, round-the-year infrastructure — on the same
logic that EVMs and VVPATs are State property maintained year-round by the ECI,
not rented for each election.
8.1 Proposed Network (illustrative sizing, for
Council approval)
|
Tier |
Locations |
Seats per
Centre |
Total Seats |
|
Tier 1 — Mega
Testing Centres |
100 cities
(State capitals + major metros) |
5,000 desktops |
5,00,000 |
|
Tier 2 —
District Testing Centres |
766 centres (one
per district, matching ECI's district machinery) |
500 desktops |
3,83,000 |
|
Tier 3 — Surge /
Hybrid Capacity |
Requisitioned
schools & colleges for peak exams (NEET/JEE) |
variable |
on demand, via
encrypted hybrid delivery |
With multiple daily
shifts, this permanent base of roughly 8.8 lakh owned seats can service well
over the current annual candidate volumes of the largest Central exams, while
the Tier-3 hybrid layer — retaining the encrypted-delivery-to-local-printer model
already demonstrated at ntaNEET.net — absorbs peak demand without recreating
the current fully-rented, fully-improvised model.
8.2 Equipment and Security Specification per
Centre
•
Desktop
computers with biometric (fingerprint/iris) candidate authentication at login.
•
AI-assisted
CCTV proctoring, recorded and retained for the Testing Tribunal's evidentiary
use.
•
Local
server rack for the CTC's two-layer encrypted question-paper delivery and
decryption — papers decrypt only at the pre-programmed start time, with no
reliance on live internet connectivity at the moment of the exam.
•
Mobile-signal
jammers and metal-detection at entry, on the pattern used at present-day
NEET/JEE centres.
•
Dedicated
power backup (UPS + generator) to guarantee zero exam-time downtime.
8.3 Staffing
A permanent CTC/STC
Testing Corps — technical administrators, security officers, and a core
invigilation cadre — supplemented during peak exam windows by requisitioned
government/teaching staff, exactly as the ECI's small permanent secretariat is
supplemented by requisitioned government employees during the election season.
9. Advantages of
Constitutional Status
1.
Political
insulation — exam scheduling, centre allocation, and result decisions are
shielded from ministerial or party-political pressure, exactly as electoral
conduct is shielded today.
2.
Institutional
continuity — a fixed-tenure Commissioner and permanent Testing Corps carry
forward technology and security learning across election cycles of government,
instead of restarting with every change of NTA leadership.
3.
Uniform
national standards without erasing federalism — the GST-Council-style Governing
Council gives every State a genuine policy voice, while the CTC/STC split keeps
day-to-day conduct professional and insulated from that same forum.
4.
Efficient
capital use — permanent, owned infrastructure used year-round across dozens of
exams is dramatically cheaper per candidate than repeated exam-by-exam private
rentals.
5.
A
structural, not just technological, answer to paper leaks — the two-layer
encrypted delivery model closes the technical vulnerability; constitutional
independence closes the political-pressure vulnerability that technology alone
cannot fix.
6.
Faster,
fairer grievance redressal — a dedicated Testing Tribunal, on the Election
Petitions model, resolves malpractice and re-test disputes far faster than the
writ-petition route currently clogging High Courts and the Supreme Court.
7.
Enhanced
international credibility — degrees, eligibility certificates, and recruitment
results issued through a constitutionally independent testing body carry
stronger evidentiary and reciprocal-recognition weight abroad.
8.
Better
policy data without operational interference — the Council receives aggregated
exam analytics to inform policy, while remaining statutorily barred from
touching any individual paper, evaluation, or result.
9.
Reduced
burden on the judiciary — the recurring cycle of PILs over leaks, re-tests, and
centre allocation is substantially absorbed by the Tribunal and by the
structural fix itself.
10.Permanent, skilled employment — a standing Testing Corps
across 800+ centres creates a cadre of technical and invigilation jobs that
does not exist today.
10. At a Glance — NTA Today
vs the Proposed CTC
|
Parameter |
NTA (Present) |
CTC
(Proposed) |
|
Legal status |
Registered
society, under Ministry of Education |
Constitutional
statutory body |
|
Reporting |
Ministry of
Education |
President of
India, functionally independent of the Executive |
|
Governance |
Ministry-controlled |
Governing
Council (Centre + all States) — policy only |
|
Head's tenure
& removal |
At the pleasure
of the Government |
Fixed six-year
tenure; removable only like a Supreme Court judge |
|
Infrastructure |
Rented,
exam-by-exam |
Permanently
owned, round-the-year (Tier-1/2/3 network) |
|
Security
architecture |
Centralised
printing & physical transport |
Two-layer
encrypted, time-stamped, decrypted only on-site |
|
State role |
None, beyond
hosting exams |
Statutory seat
on the Governing Council; STC administers locally |
|
Funding |
Annual budgetary
grant |
Charged to the
Consolidated Fund of India |
|
Grievance
redressal |
Writ petitions
to High Courts/Supreme Court |
Dedicated
Testing Tribunal (Election-Petition model) |
11. Note on Circulation
This framework
operationalises, but does not alter, the structural proposal set out in the
letter to the Prime Minister of 22 July 2026. It is offered as a discussion
draft — for the Union Government, all recognised political parties, State
Education Departments, and the Parliamentary Standing Committee on Education —
to invite comment before any constitutional amendment or legislative bill is
drafted. The companion technological proposal — AI-generated, two-layer
encrypted question papers delivered directly to secure printers inside the
locked examination hall — has already been demonstrated at www.My-Teacher.in
and www.ntaNEET.net.
Hemen Parekh |
Mumbai | 25 July 2026