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Learning disabilities (LD) have frequently been criticised for their conceptual ambiguity, often described as a “dumping ground” for diverse learning problems, its definitional vagueness and close proximity to the notion of underachievement have made it one of the most contested categories within special education (Beers & Beers, 1980; Kavale & Forness, 2000). In light of this, identification processes tied to this special education needs category have historically and globally been uneven, shaped by distinct socio-cultural and institutional contexts. Typically involving a multidisciplinary team of teachers, psychologists, counsellors and medical professionals, the process unfolds across multiple sites and timelines and includes an array of diagnostic and psychometric tests before educational interventions are planned, or support reaches the child.
In India, rising public awareness on LDs in the late 2000s, on account of growing media attention and global inclusive education agendas, led to its evolving definitions, imported diagnostic models, and tentative efforts at standardisation of the identification process. However, LDs became legally recognised as a special needs category only in 2016 through the Rights of Persons with Disabilities Act. Yet today there are still no official national prevalence estimates, studies suggest a wide variation, with estimated prevalence of 8% (Scaria et al, 2023). Other challenges include availability of diagnostic tools in regional, or home languages and diagnostic disposition towards the highly criticised IQ-achievement discrepancy model. Attempts at standardisation have given rise to several tools such as the Dyslexia Screening Test, NIMHANS Battery and PRASHAST, yet the validity, credibility and equitable use of these tests in Indian classrooms remain under researched (Misquitta & Panshikar, 2023). Overall, LD identification in India continues to emphasise categorisation over intervention, often reinforcing stigma and labelling, disrupting students’ educational trajectories.
In contrast, Germany has long institutionalised the concept of Lernbehinderung (learning disability), supported by extensive research as well as a formalised system of diagnostic legislation and infrastructure (Eggert, 1988). Critics, however, contend that these procedures disproportionately affect children from marginalised groups, particularly those from immigrant and socio-economically disadvantaged backgrounds. For instance, the study by Brandenburg et al (2016) notes that non-native German speakers continue to face a higher risk of misidentification or misclassification within special education needs services, especially regarding learning disabilities. Furthermore, the rigidity of the diagnostic process and special school placement has further been criticised for creating an undisputed juncture of classification, that determines a child’s inclusion in, or exclusion from, mainstream schooling. Comparable concerns have been raised across Europe, especially in countries that employ such classification-based systems, where there is growing advocacy for a shift towards individualised, needs-based approaches (Weber et al, 2025). Nevertheless, while LD special needs categories have been introduced for the purpose of providing individualised support, their diagnostic accuracy remains contested and ambiguous.
This paper undertakes a comparative study of learning disability identification processes in India and Germany, examining how distinct policies on LD, professional practice, and diagnostic frameworks shape children’s educational experiences. The study adopts a qualitative research design, and the data corpus includes national policy frameworks and guidelines from both countries and publicly available exemplary assessment tools and test protocols. Comparative analysis focuses on identifying points of convergence and divergence between the two systems, with added attention to actors, mechanisms, and institutional consequences for children. The study addresses two central questions: (1) What constitutes the end-to-end process of LD identification in India and Germany during the past two decades and how do they compare? (2) What are the implications of these processes for children’s educational pathways in these two countries? By placing India (Global South) and Germany (Global North) in dialogue, the paper reflects on the challenges of standardising diagnostic practices for learning disabilities in two different contexts and its implications for designing special education needs and inclusive education frameworks.