Gatekeeping by Design: The UGC Circular, the NCAHP Act, and the Systemic Erasure of Community-Based Mental Health Practice

In August 2025, the University Grants Commission (UGC) issued a circular that barred psychology and allied health programs from being offered in open and distance learning (ODL) or online modes starting from the academic year 2025–26. The stated rationale was that such programs fall under the scope of the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021, and therefore require stricter regulation and in-person standards. At first glance, this decision may appear as a simple quality-control measure. But placed in conversation with the broader policy frameworks governing mental health education and practice in India, it becomes evident that what is unfolding is not merely a matter of regulation, but a systemic design that restricts who gets to access, practice, and be legitimized in the field of mental health.

Online and distance education programs have historically been vital access points for learners who are structurally marginalized—Dalit-Bahujan students, queer and trans persons, disabled folks, caregivers, and those living in rural or economically precarious contexts. These programs have offered routes into the field of psychology for those whose lives cannot accommodate the demands of full-time, in-person, urban education. With one policy decision, that access has been closed off. But this is not just about access to education—it is also about what kind of psychology is being authorized, and who is being authorized to practice it.

The NCAHP Act further sharpens this narrowing. The Act mandates that only individuals with degrees from recognized institutions, registered in Central or State councils, and working within narrowly defined scopes of practice are legally permitted to offer services in allied and healthcare professions—including psychology. This move repositions psychology entirely within the domain of healthcare and biomedical governance. It erases practitioners who offer mental health support from frameworks rooted in community, embodiment, relational care, and lived experience. Peer supporters, feminist facilitators, trauma-informed practitioners, caste-aware counselors, and those practicing somatic, narrative, or grassroots therapy models suddenly find themselves unrecognized—not criminalized per se, but rendered illegible and unsupported by the State. Their practices are not seen, not counted, and therefore not resourced or protected.

This twin move—of withdrawing access to psychology education through online and distance modes, and enforcing a strict regulatory regime under the NCAHP Act—consolidates a specific vision of psychology. One that is institutionalized, standardized, clinical, and biomedical. It sidelines community-based, anti-oppressive, and justice-oriented ways of practicing mental health care. It assumes that pathology lies in the individual body, and not in the social body marked by caste, class, gender, and structural violence. It defines the “qualified practitioner” as one who has passed through formal, often inaccessible channels, and erases those who have been practicing in the cracks—on the margins, in solidarity, in collective care spaces, and through embodied knowledge.

At a structural level, mental health policy in India suffers from a disciplinary and bureaucratic split. While clinical practice is located within healthcare ministries, issues such as caste-based violence, gendered harm, and displacement fall under entirely different ministries—social justice, women and child development, or tribal affairs. This bifurcation leads to fractured services, scattered funding, and policy gaps that ignore the relational and systemic roots of mental distress. Mental health that is born of caste trauma or intergenerational violence is either treated as a purely clinical issue or not recognized as a health concern at all. This disconnect is embedded in the NCAHP Act and amplified by the UGC’s recent circular.

Together, these policies raise difficult but necessary questions. What kinds of knowledge are being legitimized as “mental health education”? Who is being invited into the profession, and who is being shut out? What forms of care are we institutionalizing, and what forms are we letting fall away? In a country as complex, layered, and wounded as ours, can we afford to limit the practice of psychology to the clinic, the diagnostic manual, and the university classroom?

What we need is not more control or standardization. We need more courage—courage to imagine regulation that includes rather than excludes, that affirms rather than erases. We need frameworks that honor multiple pathways to becoming a practitioner—ones that include lived experience, mentorship, peer support, and community-rooted training. We need curriculum that is contextual and critical, that draws from anti-caste, decolonial, queer-trans affirmative, and neurodivergent perspectives. We need recognition that healing, protest, and resistance are deeply intertwined, and that the body is not just a site of illness but of wisdom, aliveness, and refusal.

The UGC’s move to shut down online and distance psychology programs and the NCAHP Act’s narrowing of who gets to be counted as a professional are not isolated incidents. They are part of a larger architecture of gatekeeping—one that upholds a narrow vision of psychology while pushing out the many who have kept mental health care relational, context-based, and politically aware. We do not need fewer ways into the field. We need better ways forward—ways that make room for all of us.

At Pause for Perspective, we imagine psychology differently—integrated, interdisciplinary, and rooted in care. We believe that care becomes fragile, and often violent, when questions of what is taught, who teaches it, who it serves, and who it excludes are ignored. Across online, distance, and in-person education, the gaps remain wide, leaving behind those whose lives most urgently call for a psychology attentive to justice.

Even as policy narrows the field, we continue to nurture ways of learning and practicing that center the body, honor lived experience, and hold mental health and social justice together. Pause remains a space where caste- and gender-aware work, neurodiversity-affirmative practice, and community-rooted support are not afterthoughts—they are essential.

In this constricting landscape, we carve openings for a psychology that is both rigorous and relational, reflective and reparative. A psychology that, above all, moves with care.

-Aarathi Selvan