INCLUSIVE EDUCATION ACTS & POLICIES IN SOME SELECTED COUNTRIES INCLUDING BANGLADESH

Introduction:

Inclusive education is currently one of the most discussed educational topics all over the world. The world has got a number of Declarations and Agreements in favour of inclusive society for all as an output of inclusive education. These include the Universal Declaration of Human Rights 1948; The UN International Covenant on Civil and Political Rights 1966; The UN Convention Against Discrimination in Education 1960; Declarations on the Rights of Mentally Retarded Persons 1971; The Rights of Disabled Persons 1975; International Year of Disabled Persons 1981; Decade of Disabled Persons 1983-1992; The UN Convention on the Rights of the Child-CRC 1989; The UNESCO Declaration on Education For All (EFA) 1990; The Salamanca Declaration on Inclusive Education 1994. These international documents acted as prime mover for education systems of different countries towards inclusive education (Florin & Florin, 1998). Bangladesh is the signatory of these international declarations (Directorate of Primary Education- DPE & Centre for Services and Information on Disability-CSID, 2002). The theoretical concept of inclusive education is an expression of desire to ensure equal opportunity of education to all; but in practice, inclusive education varies from one context to another, which has made the issue controversial (Wisconsin Education Association Council-WEAC, 2001). Therefore, the definition and the comprehension of inclusive education vary from country to country and even within a country.

This article has been prepared on the basis of a research that was conducted by the author for partial fulfillment of the requirements for the degree of Master of Special Education at the Flinders University of South Australia in 2005.

Objectives and Research Questions of the Study:

The broad objective of the thesis was to explore the overall situation of inclusive education in some developed countries (UK, USA, and Australia) and to compare the findings with the situation in Bangladesh. The following research questions were formulated keeping the specific objective in view:

1. What is the present situation of inclusive education (from conceptual and legal points of view) in developed countries of the world?
i) What is/are the functional definition/definitions of inclusive education?
ii) What is the legislative framework of inclusive education?
iii) How widespread inclusive education concept is in comparison with other special-need education approaches?

2. What are the trends in inclusive education for children with disabilities?

3. What are the differences in inclusive education practices between developed countries and Bangladesh?

4. What recommendations and policy guidelines can be suggested for Bangladesh in view of the current status of inclusive education in the developed societies?

Research Methodology:

Document analysis/literature review: Information from secondary sources such as text books, journals, printed materials, programme reports of different agencies, and internet publications were the major source of information.

Observation and case study: Some observations and communications were also conducted to develop case studies on inclusive education practices of different organizations. Case studies of those organizational activities were developed on the basis of observation findings.

Study Findings:

Definition of inclusive education:

It has been mentioned earlier that there are controversies regarding the concept of inclusive education in different parts of the world as well as among the stakeholders. This study found different definitions on inclusive education in literature of different countries. The Salamanca Declaration 1994 describes inclusive education in this way: that all children regardless of their diversity in gender, race, class, religion, ethnicity, economic and social position and special need or disability should be included in the regular education programmes in a community setting. The Centre for Studies on Inclusive Education (CSIE) describes inclusive education as a setting where children and young people of any type and abilities participating fully in the mainstream educational provisions with the presence of required supports (CSIE, 2002). WEAC (2001) discussion opened in these words: that inclusive education can be an approach to bringing assistance to children rather than taking them to support services. In contrast, some educators argue in favour of full inclusion which means all children will be placed into regular education settings full time (WEAC, 2001). Just as in other parts of the world, the concept of inclusive education varies from state to state in Australia. Some follow the integration model of inclusion and some follow full inclusion (Moss, 2003). However, most children with diverse needs in Australia are now in inclusive education programmes (Huang, Brown & Rickards, 1998).

Different countries and agencies have functional definitions of inclusive education in different ways, but the meanings of these definitions are very similar; UNESCO (2001) defines inclusive education as follows:

schools should accommodate all children regardless of their physical, intellectual, social, emotional, linguistic or other conditions. This should include disabled and gifted children, street and working children, children from remote or nomadic population, children from linguistic, ethnic or cultural minorities and children from other disadvantaged or marginalized areas or groups. (in Aniftos, 2004: 4)

The Salamanac Statement (1994) further describes inclusive education in a functional language as:

Regular schools with the inclusive orientation are the most effective means of combining discriminatory attitudes, creating welcoming communities, building an inclusive society and achieving education for all; moreover, they provide an effective education to the majority of children and improve the efficiency and ultimately the cost-effectiveness of the entire education system. (in Vaughan, 2002: 5)

In the US, Phi Delta Kappa’s Centre for Evaluation, Development and Research (1993) provided definition of inclusion which suggests strategies for implementing inclusive education:

Inclusion is a term which expresses commitment to educating each child, to the maximum extent appropriate, in the school and classroom he or she would otherwise attend. It involves bringing the support services to the child (rather than moving the child to the services) and requires only that the child will benefit from being in the class (rather than having to keep up with the other students). Proponents of inclusion generally favour newer forms of education service delivery. …Full inclusion means that all students, regardless of handicapping condition or severity, will be in a regular classroom/program full time. All services must be taken to the child in that setting. (in Wisconsin Education Association Council-WEAC, 2001: 1-2)

In the UK, CSIE (2002) defines inclusive education as:
all children and young people with and without disabilities or difficulties – learning together in ordinary pre-school provision, schools, colleges and universities with appropriate network of support. Inclusion means enabling all students to participate fully in the life and work of mainstream settings, whatever their needs. (CSIE, 2002: 1)

In addition, the Index for Inclusion published in UK defines inclusion as:
the process of increasing the participation of students in, and reducing their exclusion from, the cultures, curricula and communities of local school (CSIE, 2002: 2).

WEAC (2001) further suggests that this controversy about concepts of inclusive education depends on social values, education systems, existing facilities and resources and on individual identity of children with special needs. These definitions provide some functional ideas about inclusive education in different parts of the world. However, when we examine the practices of inclusive education, the reality is different?

Inclusive education acts and policies in some selected countries

The United Kingdom
Before early 1970s, children with disabilities in the UK were treated as uneducable and it was the responsibility of health authorities to provide training for these children (Vaughan, 2002). The 1970 Education Act, for the first time, included these children in the education programs a consequence of enacting this new law, 24000 children with disabilities from different training centres and 8000 children with disabilities from 100 hospitals were enrolled in education (Vaughan, 2002). This was the first formal legal initiative in the UK to ensure that all school age children were enrolled in education (Vaughan, 2002). The 1976 amendments of the Education Act gave responsibilities to the Local Education Authorities (LEA) to include children with disabilities into mainstream school, but the law was not practiced much at that stage (Vaughan, 2002). However, the Warnock Report on special education in England, Scotland and Wales (1978) raised the integration of children with special needs into education as a national agenda, as this was not considered a human rights issue, the report simply suggested that special education would be better for some children (Vaughan, 2002). In 1981, the Education Act was reformed and the new Act gave formal authority to the LEAs to integrate children with disabilities into mainstream, but faced huge opposition from a range of professionals (Vaughan, 2002). In 1992, the Audit Commission and Her Majesty’s Inspectorate report found that a number of malpractices had occurred in the field in providing educational opportunities for children with disabilities, these included the time took for assessments to be conducted by LEA; some articles in previous laws were so vague that LEAs became confused in decision making, specific procedures for placement in educational settings were not clearly stated; a lack of resources in regular schools caused problems in some placements; annual review and inspections were not satisfactory, and there was lack of accountability in schools and LEAs (Vaughan, 2002).

Then, in 1993, a new education Act was passed in England that tried to overcome the limitations of previous Acts and this law was revised again in 1996 to make a consolidated mass education Act in favour of inclusion (Vaughan, 2002). The Disability Discrimination Act-1995 outlawed any discriminatory approach towards people with disabilities in any sector of development, including education (Vaughan, 2002). In 1997, the new Labour Government published the Green Paper on Special Education in which they provided major support for all mainstream schools to become more inclusive, while the Human Rights Act 1998 confirmed that education of children with disabilities is a human rights issue (Vaughan, 2002). In 2001, The Special Educational Needs and Disability Act (SENDA) Part 1 was enacted which ensured parents’ rights to choose appropriate educational provision for their children and gave importance to the quality of education for other children in these schools; SENDA Part 2 was enacted in 2002 with the object to develop more accessible curriculum, physical environment and information interchange for children with disabilities (Vaughan, 2002).

The Department of Education of England and Wales (1994) developed guidelines for identifying and assessing child with special educational needs (SEN); this document does not formally establish inclusive education, but provides statements in support of inclusion:

Children with special education needs, including those children with statements of special educational needs, should, where appropriate and taking into account the wishes of their parents, be educated alongside their peers in mainstream schools. (Department of Education, 1994 in Florin & Florin, 1998: 2)

In establishing these laws relevant to inclusive education, The UK education system has also taken a number of initiatives to make it more inclusive. It now has a sound policy framework and additional funding to implement inclusive education (Mittler, 2000 in Mittler, 2004). All regular schools, special schools and college of further education had to develop inclusion policies for next eight years (Mittler, 2004). However, there is a huge range of variations in the activities of LEAs in implementing inclusion legislations as different schools need different specialist services according to individual needs, and variations are also visible even within the same LEA due to lack of clear policy guidelines for defining future roles of special schools (Mittler, 2004; Florin & Florin, 1998). However, the number of special schools in the UK has decreased within the last few decades and 60% of all school aged children attend mainstream schools at the moment (Mittler, 2004). LEAs provide additional resources including funding and multi-professional support for assessment and intervention needs to make inclusion effective (Mittler, 2004). The UK government is also facilitating collaboration between mainstream and special schools and 80% of special schools are now under this link-program (Department for Education and Employment, 2000 in Mittler, 2004).

Some special schools in the UK developed a linked program with the nearest primary schools and small groups of students with disabilities were sent to those primary schools to attend classes with support from a teacher or teaching assistance about three hours a week on average, while mainstream students also visit special schools on a regular basis (Mittler, 2004). LEAs provide additional funding and human resource support, and other resources to selected schools to include children with special needs, with the aim of developing those schools as resource centres or model schools (Mittler, 2004). The UK government conducted a restructure to make the regular schools more inclusive and this includes curriculum reform; revision of pupil-assessment techniques; appropriate distribution of responsibilities and funding in all schools; development of obligatory special needs Code of Practice for all schools, development of school-based identification and assessment tools; providing appropriate support services; facilitating student learning through teaching assistant support, adding inclusion issues to staff development programs; and ensuring parental participation in inclusive program planning and in their implication strategies (Mittler, 2004). In summary, in the UK, the legal authority and responsibility for providing education to children with special educational needs lies mostly in the activities of the LEAs and variations can be observed in the service delivery approaches of the LEAs as some are extremely inclusive, while others practice segregation. An Index for Inclusion has been developed in the UK to conduct self-evaluation of different inclusion related programs and to update information for other bodies involved in inclusion movements (CSIE, 2000 in Mittler, 2004). Therefore, the dominance of inclusion is visible in the UK education sector while segregated settings are decreasing.

Initiatives in the United States of America (USA)
In the US, the education of children with disabilities is defined by different federal laws as well as state laws, as well as by civil rights movements and legal determinations of court cases (Friend & Bursuck, 1996 in Florin & Florin, 1998). The movement from segregation towards inclusion in the US began in the early 1970s (Croser, 2004). Section 504 of the Vocational Rehabilitation Act, enacted in 1973, described the anti-discrimination view towards people with disabilities and two years later in 1975, the fundamental law for establishing inclusive education the Education of All Handicapped Children Act or PL94-142 was passed (Florin & Florin, 1998). This Act established, for the first time, the right of all children to access their local school and ensured the least restrictive environment (LRE) for learners in the classroom (Croser, 2004; Florin & Florin, 1998). In 1990, this Act was revised and renamed the Individuals with Disabilities Education Act (IEDA) or PL101-476, this new version of the law replaced the term ‘handicapped’ with the new one ‘disabilities’ and defined inclusive education more clearly as well as introducing the Individualized Education Plan (IEP) into schools (Florin & Florin, 1998: 2; Croser, 2004). Moreover, the Assistive Technology Act (1998) ensured the necessity of technological supports in inclusive settings (Croser, 2004). Therefore, the legal framework for inclusive education in the US was well organized from the very beginning.

The US Constitution acts as the basis of all the anti-discrimination laws enacted in different stages, the Fourteenth Amendment of the US constitution clearly stated about the protection of individual rights irrespective of diversity factors, such as race, class, ethnicity, physical appearance and traits; this amendment also gives clarification about the position of the state in relation to educational discrimination (Devine, 2002). However, the IEDA 1997 has left an option of specialized education together with inclusive schooling for those children who are not capable of being enrolled in regular education, as Section 612 (a) (5)(A) demonstrates:

to the maximum extent appropriate, children with disabilities are educated with children who are non-disabled; and that removal from the regular education environment occurs only if the nature of severity of the disability is such that education in regular classes with supplementary aids and services cannot be achieved satisfactorily.(Koltz, 2003: 1; CSIE, 2002)

As a consequence of this option for segregation, many regular schools in the US have special classes that are criticized for discriminatory practices (Mittler, 2004). Hence, several court cases have shaped the district education systems as well as enriched the IEDA into more inclusive approaches (Devine, 2002). The IEDA was revised again in 2002 (CSIE, 2002). Nevertheless, in practice, the aims and objectives of inclusive education go beyond federal mandates; and the benefits that all children gain in inclusive schools as a result of learning to respect individual differences are highly valued (Koltz, 2003). As a result of these holistic initiatives, the US Department of Education states that over 95% of children with disabilities are now enrolled and served by regular schools in an inclusive environment (Koltz, 2003). Clearly, this is a positive outcome of the inclusive philosophy.

Legislative framework for inclusive education in Australia
In Australia, 19% of the population has disabilities (Australian Bureau of Statistics, 2000 in Horrocks, 2004). Australia does not enshrine anti-discrimination rights in the Constitution, but the policies initiated in Australia are very much influenced by commitments to international declarations and the recommendation outcomes gathered for the PL 94-142 and IEDA in the USA (Florin & Florin, 1998; Devine, 2002). However, Australia has enacted a number of laws to create an anti-discriminatory environment, such as the Racial Discrimination Act 1975, the New South Wales (NSW) Anti Discrimination Act 1977, the Sex Discrimination Act 1984, the Queensland Anti Discrimination Act 1991 and the Disability Discrimination Act- (DDA) 1992 (Devine, 2002). These laws ensure that no organizational body, including education authorities, can discriminate against any Australian citizen on the grounds of race, sex, political identity, disability or other special needs such as health conditions (Devine, 2002). Moreover, Australia produced a ten-year Commonwealth Disability Strategy in 1994 which affirms that Australia provides equal educational opportunities in primary, secondary and tertiary education (Florin & Florin, 1998). The DDA definition of disability covers wide range of diversity of people, such as presence of total or partial loss of a person’s bodily or intellectual functions; total or partial loss of a part of a body; any chronic disease that is causing or capable of causing illness; malfunction of any part of a person’s body; and any disorder that can make a person’s perception, learning process, or thinking process different from others can be considered a disability (Devine, 2002). All these people are protected and served under the laws and policies mentioned above. Therefore, it is clear that Australia has various kinds of laws and policies to ensure inclusion.

Australia is very much different from other developed countries like the USA and England in practicing inclusive education and it differs from state to state (Florin & Florin, 1998). The Australian Constitution (1900) pronounces that ‘the organization and governance of education is a responsibility of the states’ (Florin & Florin, 1998: 3). Like the Federal Government in the USA and the Department of Education of the UK, the Commonwealth Government of Australia does not have any legislative authority over the state education system, but it has indirect authority through developing federal education policies and providing funding to the states (Florin & Florin, 1998). However, on the basis of the DDA 1992, the state governments all over Australia have developed their own inclusion policies and including The South Australian Students with Disabilities Policy 1991, The NSW Special Education Plan 1998, The Equity in Schooling Policy of Tasmania 1995 and the Victorian Program for Students with Disabilities and Impairments 1998 (Croser, 2004). Other states have legislations for providing inclusive education, such as the Western Australia Schools in Education Act 1999 (Croser, 2004).

According to the DDA 1992, it is unlawful for any educational institution to refuse enrolment to, or discriminate against, any child with disability (Devine, 2002). Therefore, in Australia, school authorities are bound to enroll children in their local school when parents want this whether the school has skilled human resources or not to manage the special needs of children with disabilities and despite the challenging environment this creates for teachers (Florin & Florin, 1998). However, the placement policies of children with disabilities in educational institutions vary in different states of Australia (Florin & Florin, 1998). In Western Australia, Tasmania, Victoria, Northern Territory and South Australia there is a provision to empower the State Education Minister to decide the placement issue on the basis of the severity of child’s disability, but in NSW, Queensland and the Australian Capital Territory, the laws do not clarify this matter and the placement issue is controlled by the anti-discrimination and equal opportunity Acts in place at both federal and state levels (Florin & Florin, 1998).

Research demonstrates that most states and territories do not have uniform definition of disability (Kraayenoord, Elkins, Palmer, Rickards, Colbert et al., 2000). As a result of this, identification procedures vary in different states of Australia and many students with disabilities remain unidentified due to variations in defining disability (Kraayenoord et al., 2000). Research conducted by Kraayenoord et al. (2000) further suggests that most children with disabilities in Australia attend regular schools and some attend special classes in regular schools as an integration model, and some children with severe disabilities attend special schools. Research has also been conducted on the inclusive schooling policy of Tasmania by Julian Moss of the University of Melbourne (2003). This research suggests that Australia follows three broad approaches to implementing inclusive education in different parts of the country and those approaches are the psycho-medical based approach, the traditional centre-based special education approach and the recent sociology-based inclusive approach (Moss, 2003). Research conducted in South Australia (SA) by Horrocks (2003) reveals that by the year 2002, 92% of children with disabilities in SA were enrolled in regular schools, and the remaining 8% were enrolled either in special schools or in special units of regular schools. Children with severe or multiple disabilities mostly attend special schools (Horrocks, 2003). One NSW study showed that the number of special schools in this state as well as other states had declined, but the total number of students in special schools remained unchanged, and this indicates that there is a hidden segregation occurring in educational institutions (Dempsey & Foreman, 1997). The good thing is that research is exploring these issues from the field level.

Legislative framework for inclusive education in Bangladesh
After achieving independence in 1971, the People’s Republic of Bangladesh enacted the constitution in 1972, and it was revised in 2000 (The Ministry of Law Justice & Parliamentary Affairs, 2000). The Constitutional provision regarding education helped moving towards conceptualisation of inclusive education. Part II of the Constitution describes education in the following way:

Article 17: The state shall adopt effective measures for the purpose of –
establishing a uniform, mass oriented and universal system of education and extending free and compulsory education to all children to such stage as may be determined by law;

Part III of the Constitution specifically mentions of non-discrimination in education as contained in Article 28 (3)–
No citizen shall, on grounds only of religion, race, caste, sex or place of birth be subjected to any disability, liability, restriction, or condition with regard to access to any place of public entertainment or resort, or admission to any educational institution.

Article 28 (4)-
Nothing in this article shall prevent the State from making special provision in favour of women or children or for the advancement of any backward section of citizens. (Ministry of Law Justice & Parliamentary Affairs, 2000: 8)

The first ever education policy of Bangladesh known as the Education Commission Report 1974, suggested special education opportunity for children with special needs.

However, the concept of special education was not clear to Bangladeshi educationists during that period, as religious education and physical education were also considered special education at that time. In Education Commission Report of 1988, special education was addressed properly but inclusive education was not familiar to the policy makers yet (Ministry of Education, 1988). In 1990, Bangladesh signed the Education For All (EFA) Declaration (WECEFA) at Jomtiein, Thailand in 1990 and enacted a law known as the Compulsory Primary Education Act 1990 for achieving EFA goals. Primary education was declared free for all children (Ahsan & Tonmoy, 2002). However, children with disabilities remained out of regular primary education because only special education provisions were suggested in the education policies, and education of disable children were not considered then within special education category.

In 1997, Bangladesh implemented a new education policy, and in that policy, the education of children with disabilities was described clearly (The Ministry of Education, 1997 in Ahsan & Tonmoy, 2002). The strategy for the education of children with disabilities in the National Education Policy 1997 recommends the importance of conducting a survey to ascertain the exact number and identify the type and degree of disability in Bangladesh; that regular settings would benefit children with disabilities more than the other options; that special education is also required for some children; that appropriate training is necessary for schoolteachers; that the issue of disability needs to be included in the primary education curriculum to raise awareness; that an alternative curriculum has to be followed for those handicapped students who are unable to follow the regular curriculum; that necessary educational materials have to be supplied for handicapped learners free of charge or at a low cost; and at least one special education teacher has to be appointed in regular schools (Ministry of Education, 1997 in Ahsan & Tonmoy, 2002).

Bangladesh does not have any database or survey result on total number of people with disabilities and their types yet, so Bangladesh follow the World Health Organization’s (WHO) estimation that 10% of any given population have disability (DPE & CSID, 2002). Bangladesh did not have any laws to ensure the rights of people with disabilities until 2001, but Bangladesh developed a National Disability Policy in 1997 which was transformed into the Bangladesh.

Persons with Disability Welfare Act-2001 four years later (Ministry of Social Welfare, 2001). Part D of this Act discusses the educational rights of people with disabilities and proposes to create opportunities for free education for all children with disabilities below 18 years of age; to provide them educational materials free of cost or at a low cost; to create opportunities for the integration of students with disabilities in regular schools; to undertake programs for imparting vocational training for people with disabilities; to arrange trainings for teachers and other employees working with people with disabilities; to incorporate/include appropriate articles and other related subjects in the introductory social science subjects; aiming to create public awareness about the lifestyle and associated problems faced by people with disabilities; and to arrange accessible transport facilities for students with disabilities to use for attending school (The Ministry of Social Welfare, 2001). The Bangladesh Persons with Disability Welfare Act-2001 defines disability as absence or loss of total or partial body parts; any impairment in sensory abilities, such as vision or hearing problem; and any malfunction in a person’s intellectual process (The Ministry of Social Welfare, 2001). After enacting this Act, the educational rights of people with disabilities received a legal base in Bangladesh.

Trends in Inclusive Education:

It is clear from literature review that `inclusive education’ is very much focused in human rights declarations which mention that every child has an equal right to be enrolled in the local regular school and to receive the same type of education as their peers (Bunch & Valeo, 2004). In inclusive education, in the true sense of the term, every child is warmly received and considered a contributing member, and every individual’s developmental activities are facilitated by manipulating the environment and through providing children opportunities to apply their full capabilities (Stainback & Stainback, Halvorsen & Sailor, Forest & Pearpoint, Villa, Thousand, Ayres, Yell cited in Bradley et al., 1997). Moreover, inclusion is not an educational system or a legal phrase; rather it is an educational philosophy to reform the existing teaching-learning methods of regular or special educational settings (Inos & Freagon in Walker & Ovington, 1998). However, it is clear from the literature that there is an absence of a sound universal definition for inclusive education.

Special education, integrated education models exist in addition to inclusive education in Australia, UK and the US. Some countries practice these education approaches through developing link programs and some practice these approaches in a mixed way (Mittler, 2004; Koltz, 2003). Data from the UK, the US and Australia indicates that most of the children in these developed countries are now receiving education in regular inclusive settings Mittler, 2004; Horrocks, 2003; Koltz, 2003). Positive responses to inclusive education have occurred for a number of reasons. Research indicates that if the environment is designed properly, even children with moderate to severe disabilities show evidence of improved educational development in regular education, and children with hearing impairment can show a remarkable development in this setting (Halvorsen & Sailor, Mercer & Denti, Stainback & Stainback, Villa et al., Willis in Bradley et al., 1997). In inclusion, all students experience a wide-ranging curriculum that helps their learning, while children with special needs get more chance to learn social norms and values in regular settings and are treated like their siblings as they share the same school (An Inclusive Talkback: Critics Concerns and Advocates’ Responses in Walker & Ovington, 1998). Inclusion also helps to develop a healthy family life and ultimately it facilitates social inclusion (An Inclusive Talkback: Critics Concerns and Advocates’ Responses in Walker & Ovington, 1998). However, some students still exist in segregated settings.

Other researches suggest that children who were educated in segregated settings had lower rates of employment and showed lower ‘self-esteem’ (Brown et al., Lipsky & Gartner, Thousand, Wagner in Bradley et al., 1997: 12). Peterson in Bradley et al. (1997) showed that children with disabilities who experienced diverse groups achieved improved development and became more active than segregated children. Their research suggests that inclusive education gives more free time to special education teachers to provide assistance, while students with special needs get more time in classroom activities as they are not attending special classes. Moreover, mainstream schoolteachers experience diverse ways of delivering instruction in the inclusive classroom (Marwell in Bradley et al., 1997). Children without disabilities can also benefit from inclusive settings as they get flexible curriculum, more technological and other support services for effective learning, and experience team-teaching in the classroom (Freagon in Walker & Ovington, 1998). Research by Goodlad, Lovitt, Oakes and Lipton (in Walker & Ovington, 1998) also supports the view that children can learn more when they receive rich and diversified teaching in regular settings. Clearly, inclusive education has educational and social benefits for children with special needs and also benefits students who are already in regular education. These findings indicate the success of inclusive education approaches.

In the UK, the concept of inclusive education is well supported by different legal frameworks, but in practice, there is a huge range of variations in the activities of LEAs in implementing inclusion because different schools need different specialist services according to individual needs (Mittler, 2004). Moreover, variations occur even within the same LEA due to lack of clear policy guidelines for defining the roles of special schools (Mittler, 2004). However, special education and integrated education are still visible, despite the decrease in the number of special schools (Mittler, 2004). All special schools have to prepare inclusion policies and have to work as linked partners with regular schools (Mittler, 2004). This suggests that inclusive approaches will be applied everywhere.

In the US, four categories of reforms in the education system have marked the journey towards inclusion: mainstreaming, regular education initiatives, first generation inclusion and second generation inclusion (Turnbull, Turnbull, Shank & Leal, 1999). Mainstreaming started in the early 1980s and students with special needs were directly placed in some of the mainstream school programs in this practice (Turnbull et. al., 1999). Such schools still exist in the US. Then, in the mid 1980s, due to mainstreaming practices, the regular education system had to take some initiatives in the areas of curriculum, policies and physical environments for children with special needs so that they could be mainstreamed more effectively (Turnbull et. al., 1999). By the late 1980s, regular schools started to provide additional support to all students, in first generation inclusion (Turnbull et. al., 1999). Finally, in the late 1990s, huge initiatives were taken to reform the entire school system from teaching methods to policy options, which is known as second generation inclusion (Turnbull et. al., 1999). Because of these reforms, 95% of US children with disabilities are in regular schools now, but other provisions are still used (Koltz, 2003).

In Australia, most states and territories do not have a uniformed definition of disability and identification procedures also vary in different states and most children with disabilities in Australia attend regular schools (Kraayenoord et al., 2000). Some attend special classes in regular schools where the integration model operates, and some children who have severe disabilities attend special schools (Kraayenoord et al., 2000). Australia practise full inclusion as well as partial inclusion, integration and special education. The State governments provide support to promote inclusive education. There are evidence of resource centres, linked programmes and inclusive pre schools in South Australia and Victoria.

Discussion and Recommendation:

In reviewing literature, it has been observed that there is a great deal of controversy regarding the concept of inclusive education. Some believe full inclusion, others believe in partial inclusion, or integration model of inclusion or special education. It has also been observed that functional definitions of inclusive education vary between countries and within a country. For example, the DDA definition in Australia considers disability as total or partial loss of a person’s bodily or intellectual functions; total or partial loss of a part of a body; any chronic disease that is causing or capable of causing illness; malfunction of any part of a person’s body; and any disorder that can make a person’s perception, learning process, or thinking process different from others (Devine, 2002). This includes both permanent and temporary disabilities, including psychiatrist illness (Devine, 2002). In contrast, the Bangladesh Persons with Disability Welfare Act-2001 defines disability as absence or loss of total or partial body parts; any impairment in sensory abilities, such as vision or hearing problem; and any malfunction in a person’s intellectual process (Ministry of Social Welfare, 2001). Therefore, people suffering from chronic diseases, psychiatrist illness or learning or perceptual problems are not considered disabled in Bangladesh. That is why the percentage of people with disabilities in Australia (19%) is higher than that, of Bangladesh (10%) according to WHO Report.

As mentioned earlier, the Constitution of People’s Republic of Bangladesh (Article 28. 3 of part III) is against any kind of discrimination in providing human rights on the grounds of religion, race, caste, sex or place of birth or disability. Again, Article 28.4 supported the need to provide specialized facilities to meet children’s special needs. Bangladesh has developed a National Disability Welfare Policy and enacted a law known as the Bangladesh Persons with Disability Welfare Act-2001. Furthermore, Bangladesh is a signatory to the international declarations made by the United Nations to ensure basic human rights for all people like most other countries in the world. Despite being a developing country, Bangladesh is not behind UK, the USA or Australia in enacting laws and policies to protect the rights of people with disabilities. However, it is important to consider the level of implementation of these laws and policies in improving the educational situation for people with disabilities.

It is to be noted that 89% of Bangladeshi school age children with disabilities are not in education because of the confusion between policy and practice. In Bangladesh, special education, integrated education, some provition of inclusive education and few placements in mainstream schools are available for children with disabilities. However, it is important to note that special education is still considered by parents and educators the best option for all children with disabilities in Bangladesh; however most children with disabilities in Bangladesh are found in mainstream regular schools as there is an absence of special education opportunities in rural area. Moreover, education provisions for children with disabilities provided by Government and NGOs are extremely inadequate considering the number of people with disabilities in Bangladesh (about 14 million). There is no dual placement provision, as found in UK and Australia, for children with disabilities in Bangladesh. Besides, there is absence of any placement policy for children with disabilities in Bangladesh like developed countries. According to the Disability Discrimination Act (DDA) 1992 in Australia, any educational institution can not refuse enrolment to or discriminate against any child with a disability (Devine, 2002). Therefore, all children have to be included in regular school programs if parents enroll them at the school. Bangladesh enacted the Compulsory Primary Education Act 1990, but the perception of this Act does not inclusion of children with special needs in education system.

People who still believe in special education state that inclusive education is ‘economically motivated’ Top (1996) argues that there is apprehension fear of insufficient funding, inadequate training of teachers, and crisis in teaching and other support materials in inclusive schools (in Walker & Ovington, 1998). Conversely, others argue that inclusive education is appropriate only for children with slight to mild disabilities. Both professionals and parents of non-disabled children comment that children with severe disabilities might cause trouble in regular classrooms (Dorries & Haller, 2001). Followers of full inclusion do not support labelling disability (as this require predefining the child’s abilities after measuring their degree of disability) and this may misrepresent the child’s potential (Gallagher, 2001). However, Hallahan & Kauffman (1994) argue that labelling is necessary, as it does not cause the problem; it is the belief of a society about labelling that cause the problem (in Gallagher, 2001). It would appear that people’s attitudes towards inclusive education can be a barrier to this new reform. Therefore, it requires more social awareness raising initiatives to overcome such a situation.

There are other factors that can cause barriers to inclusion. Inclusive education requires a change in the whole school system that involves teaching techniques, assessment systems, and even the surrounding physical environment. Bradley et al. (1997) state that in this changed environment, mainstream teachers and other staff members can feel uncomfortable and less confident, which may create negative attitudes towards inclusive education. According to Sailor (1991), the wide range of individual differences between students can cause ‘social discrimination’ in a school (in Bradley et al., 1997). Besides, there are some people with disabilities who do not want to be included in the mainstream, such as, some members of the Deaf Society (Gallagher, 2001). In addition, some professionals choose partial inclusion rather than full inclusion. For example, the Learning Disabilities Association of America disagrees with full inclusion and Leesburg School in the US includes children with autism in regular settings only in art, music and gym classes (Walker & Ovington, 1998). Therefore, these factors reflect the diversity in practising inclusive education.

Various researches have been conducted to identify the coverage of inclusive education in comparison with other approaches. The National Study of Inclusive Education (1994) in the United States indicates that higher percentages of dropouts in special settings compared to inclusive schools, and fewer were employed in the mainstream compared to those who had been educated in an inclusive setting (cited in Walker & Ovington, 1998). A study by Bunch and Valeo (2004) in Canada on peer attitudes in inclusive and special schools shows that students in inclusive settings were more accepting of their peers with special needs, and did not advocate removing them to a segregated setting; there were less teasing and bullying once friendships were developed, and students felt a shared responsibility to facilitate the activities of their peers with special needs. Another study conducted by Freagon et al. (1993) in the USA suggested that there is no negative impact on the performance of non-disabled children due to the presence of their peers with special needs (in Walker & Ovington, 1998). Walker and Ovington‘s (1998) research on children with severe disabilities shows that parents commented that students in regular schools warmly accepted their children. The same research shows that proper modification of environment, teacher and staff training, and team teaching with the collaboration of special schools gave positive results (Walker & Ovington, 1998). Furthermore, inclusive education is cost effective. The US Department of Education (2000) estimated that inclusion saves $ 10,000 per child (in Dorries & Haller, 2001). Furthermore, inclusive education gives opportunities for community involvement that helps learners appreciate each other’s individuality (Sands et al., 2000). Therefore, it is important that those who oppose inclusion understand that it can provide better learning opportunities of learning to all learners in a cost effective manner.

The following suggestions and recommendations are made for advancing the cause, opportunities and facilitates of inclusive education in Bangladesh.

* Establish a link program between regular and special schools: Bangladesh can develop link programs between regular schools and special schools where children can be enrolled either in a special school or in a regular school. Students will attend regular schools fulltime while special schools will provide link teachers, materials, and other supports to regular schools.

* Establish special units in regular schools: Some regular schools in the UK, USA and Australia have special units for children with disabilities: Bangladesh has also introduced special units for children with visual impairment (DPE & CSID, 2002). These could be extended for all types of disabilities.

* Develop resource centres: Bangladesh can develop resource centres like Special Education Resource Unit (SERU) as in Australia at the national level as well as at district level. Bangladesh has already developed some Upazila Education Resource Centres, but requirements for including children with disabilities in the education programs are not served through those centres yet (DPE & CSID, 2002). Therefore, reform of these resource centres is necessary.

* Restructure school clusters: Bangladesh has already introduced a cluster and sub-cluster system in the primary education sector to deal with its large population, limited funding and inadequate human resources. Australia has also benefited from the cluster system. Therefore, the existing cluster system in Bangladesh could incorporate disability issues in their teacher training, resource management and cooperative activities.

* Develop model schools: It is observed in the literature review that developed countries have introduced in some regular model schools extra funding and resources with the object that other schools will follow the practices of the model schools. Bangladesh could introduce regular model schools, at least in six divisional headquarters initially, where students with disabilities would receive inclusive education with adequate support.

* Government-NGO collaboration: About 200 Non-Government Organizations (NGOs) are working on disability issues in Bangladesh (DPE & CSID, 2002). However, lack of coordination in activities is evident. Clearly, cooperation between the Government and NGOs is very important for advancing the cause of the disable children.

* Inter-ministerial and agency coordination: Developed countries like UK and Australia have developed inter-ministerial coordination among the ministries that work in the areas of social welfare and security matters, education and employment and health issues (Ford, 1998). Bangladesh can follow this example. Therefore, an important factor in the context of Bangladesh is developing collaboration among lead ministries that are directly dealing with disability related issues, such as, Ministry of Education, Ministry of Primary and Mass Education, Ministry of Health and Ministry of Social Welfare for responding the needs of children with disabilities both at the national and local levels. The Ministry of Social Welfare is already dealing with disability issue, and Ministry of Education, Ministry of Primary and Mass Education and Ministry of Health have immense scope to include the issues related to disabilities in their regular activities.

Conclusion:

A through review and comparison of the status, provision and practices of inclusive education indicate that some confusion and absence of commitment among stakeholders and lack of resources are the main causes for implementation of inclusive education in Bangladesh. This is a common phenomenon in developing countries. In developed countries, clear understanding of what needs to be done and adequate funding has helped in successful implementation of inclusive education programs. Mittler’s (2004) comparison of developed and developing countries shows that US $ 8 billion is required to meet the target of EFA program and this is equivalent to four days of global military spending; half of what is spent on toys in the US, and less than Europeans spend on computer games or mineral water. This speaks volume about the resources available in developed and developing countries.

Bangladesh is not behind the developed countries in enacting Acts and Policies regarding special education or inclusive education. Bangladesh needs to develop required strategies based on experiences of advanced countries in regard to inclusive education. Financial assistance from international organizations will expedite the process of inclusion in the education system.

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COURTESY :MOHAMMAD TARIQ AHSAN