This article reconceptualises multilingualism not simply as a matter of language choice or medium of instruction, but as a critical mechanism for epistemic justice, structural transformation and the reconfiguration of knowledge production and institutional identity. This reconceptualisation is advanced at a theoretical level and is informed, as compared to empirically proven, by the policy analysis undertaken in this article. The article aims to analyse how multilingualism is problematised and represented in the LPF (2020), and to examine the implications of these representations for institutional transformation. The article does not seek to evaluate policy implementation or outcomes, but to interrogate the assumptions, silences and rationalities through which multilingualism is constructed in policy discourse. To achieve this aim, the article employs Carol Bacchi’s WPR analytical approach to address the following objectives, which are analytically distinct but conceptually related:

Whilst the first two objectives are addressed through systematic textual analysis of the policy framework document, the third question is pursued through theoretically informed interpretation of the policy’s representational effects. Through this analytical focus on problem representations and their implications, the article advances a conceptual argument about the extent to which current policy discourse enables or constrains the mobilisation of multilingualism as a transformative praxis, instead of claiming this as an empirically observable outcome.

Globally, higher education has been pressured to change in response to widening inequalities, demands for social relevance and critiques of Eurocentric knowledge production. Scholars argue that transformation in universities needs to reach beyond access and representation to address curriculum, pedagogy and epistemic authority, that is, who counts as a knower and which knowledges count as valid (Omodan 2025; Stein 2017). This literature stresses that surface reforms (such as new enrolment figures and altered admission rules) will not, by themselves, disrupt deep structures of knowledge reproduction. Instead, transformation requires interventions that change the terms of knowledge production and classroom practice. Within this literature, multilingualism is conceptualised as more than technical accommodation. Scholars distinguish between instrumental multilingualism (Ferreira-Meyers & Horne 2017), focused on access, translation and linguistic support and transformative multilingualism (Namakula, Kimani & Kadenge 2025), which engages curriculum, assessment and knowledge production. This distinction is analytically important because it strengthens the difference between language as a vehicle for existing knowledge and language as a potential avenue for epistemic reconfiguration.

In South Africa, the transformation agenda is constitutionally mandated and institutionally visible, but its success is contested. The post-1994 policy environment put redress and equity at the centre of higher education reform. National instruments such as the LPF (2020) signal a formal commitment to multilingualism and inclusive practices. Nonetheless, multiple studies conducted largely under the pre-2020 policy regime show a gap between policy statements and on-the-ground practice. Universities retain English (and Afrikaans in some institutions) as the supreme medium of instruction, whilst African languages remain marginal in teaching, research and publication (see Aiseng 2025). Recent research in South African higher education (including Mutongoza 2025; Ngcobo et al. 2025) sharpens this critique and points to specific mechanisms that stall change. These studies document resource constraints, weak monitoring and the lack of institutional will as recurring barriers. Scholars (including Salomone 2022) also highlight the role of neoliberal pressures such as funding models, global rankings and English-preferred research norms in supporting monolingual practices.

Studies (e.g. Makalela 2016; Namakula et al. 2025) argue that multilingual practices, if properly implemented, do more than increase access. They can unsettle the assumed neutrality of colonial languages, open space for alternate epistemologies and enable students and scholars to work in and with knowledge forms grounded in African languages and contexts. However, these authors also caution that such epistemic effects are neither automatic nor uniform across disciplines, and that multilingualism must be deliberately connected to curriculum design, assessment practices and research cultures if it is to function as a praxis of transformation.

Claims that multilingualism can unsettle the assumed neutrality of English (and other colonial languages) and enable alternate epistemologies have generated significant debate. Whilst some scholars (e.g. Zeleza 2006) argue that African languages carry conceptual resources shaped by particular historical, cultural and social contexts, others (e.g. Mchombo 2016) caution against conflating linguistic diversity with epistemic equivalence across all disciplinary spheres. Debates in comparable contexts, such as controversies surrounding Mātauranga Māori and science curriculum in New Zealand (see O’Sullivan 2024; Stewart 2022), illustrate that recognising indigenous knowledge systems culturally and politically does not automatically resolve questions about their relationship to empirical scientific methods.

Critics in these debates argue that the scientific method produces universally valid knowledge regardless of the language in which it is articulated, and that English dominance is primarily exclusionary in terms of access and not necessarily epistemically limiting per se (O’Sullivan 2024). These counter-positions vindicate the need to distinguish between language as a medium of communication and language as constitutive of different ways of knowing. The epistemic potential of multilingualism is therefore likely to vary across disciplines, being more readily mobilised in fields such as education, social sciences and humanities than in highly formalised empirical sciences. This article does not seek to resolve these debates. Instead, it takes them as an essential theoretical perspective for analysing how policy discourse positions multilingualism, whether as an access mechanism, a representation of inclusivity or an avenue for epistemic intervention.

The LPF (2020) represents a revision of earlier national language policy instruments, most notably the 2002 Language Policy. The policy decorum entails that a ‘policy framework’ is not a ‘policy’ but a foundation for an actual policy, that is, a meta-policy or roadmap (Lakhno 2023). Therefore, the expectation has been that the LPF (2020) would result in an actual policy, which may be forthcoming. Still, the LPF (2020) emerges within a policy environment already shaped by documented critiques of instrumental multilingualism and disjointed implementation. However, given its relatively recent promulgation, systematic empirical evaluations of its institutional effects remain limited.

Policy analyses using critical frameworks have been particularly useful for showing how multilingualism is represented in official documents and institutional plans. Erdocia, Nocchi and Ruane (2022) argued that when policy frames language as a matter of administrative accommodation as opposed to as central to knowledge production, implementation tends to focus on translation or optional language modules. On the contrary, where policy language explicitly links multilingualism to curriculum redesign, research methods and assessment practices, there is greater potential for substantive change (Gorter & Cenoz 2017).

Using Bacchi’s ‘What’s the Problem Represented to Be?’ approach allows this article to interrogate the LPF (2020) as a discursive avenue where transformation is imagined and delimited. Instead of presuming continuity or failure, the analysis examines what forms of multilingualism the policy renders thinkable and actionable, and what kinds of institutional change it implicitly encourages or constrains. This approach helps reveal how policy language constructs the problem and thereby limits or enables transformational possibilities (Cele 2021).

The literature converges on three key insights. Firstly, multilingualism is widely recognised as central to equity and inclusion in higher education, but its transformative potential depends on how it is conceptualised and institutionalised. Secondly, historical evidence from South Africa demonstrates a pertinacious gap between language policy and practice, cautioning against rhetorical commitments without structural change. Thirdly, epistemic claims about multilingualism are contested and discipline-specific, requiring careful theoretical grounding and not assumption. This article responds to these insights by analysing LPF (2020) as a policy text that structures the conditions of possibility for transformation, as opposed to an implemented solution. The article interrogates how language problems are represented and what forms of multilingual praxis are envisioned, thereby contributing to debates about whether multilingualism in South African higher education can function as a substantive mechanism of transformation beyond cosmetic representation.

This article is theoretically framed by two perspectives: Carol Bacchi’s (2009) ‘What’s the Problem Represented to Be?’ approach and decolonial theory (synthesising ideas of different scholars). ‘What’s the Problem Represented to Be?’ approach is a post-structural framework for policy analysis (Bacchi & Goodwin 2025). The WPR approach views policy not as a neutral solution to pre-existing social problems but as a discursive practice that actively constructs those problems through language. In this sense, policies do not simply respond to issues. They define what counts as a ‘problem’, shape how it is understood and delimit which solutions are rendered legitimate or thinkable (Bacchi 2025). In the context of South African higher education, the WPR perspective is particularly relevant because transformation and language policies are entangled with questions of identity, power and knowledge production. The WPR framework (Figure 1) strengthens how policy discourse can simultaneously signal reform whilst stabilising existing hierarchies. The article analyses how multilingualism is represented as a problem (or solution). This approach enables the study to examine how policy discourse may enable, constrain or defer epistemic and institutional transformation, without assuming such effects a priori.

Figure 1 shows the six key questions in the WPR approach.

Whilst WPR provides the methodological structure for analysing policy discourse, decolonial theory (including work by Mignolo 2011, De Sousa Santos 2014 and Mbembe 2016) functions as a complementary interpretive perspective. In this article, these frameworks are understood as forming part of the broader theoretical architecture that informs how policy representations are read and made meaningful. Decolonial discourse does not replace WPR but deepens its analytical reach by accentuating the historical and epistemic conditions under which particular problem representations become intelligible and authoritative.

Mignolo’s (2011) notion of epistemic delinking is especially pertinent in interrogating how contemporary policy discourses continue to privilege Eurocentric knowledge systems whilst marginalising alternative epistemologies. This concept enables a critical reading of policy silences not merely as omissions, but as effects of enduring epistemic hierarchies. Similarly, De Sousa Santos’s (2014) formulation of epistemologies of the South provides a framework for recognising the plurality of knowledges that are usually excluded or rendered invisible within institutional discourse. It offers a perspective through which absences identified by WPR can be interpreted as structured exclusions tied to broader regimes of knowledge validation.

Mbembe’s (2016) engagement with metaphysics of presence further contributes to this interpretive layer by surfacing how certain forms of being and knowing are stabilised as prescriptive within higher education, whilst others are deferred or negated. This perspective is particularly useful in analysing how policy texts implicitly construct the subject of higher education, and how colonial continuities survive through these ontological assumptions.

In this article, decolonial theory is therefore mobilised primarily at the level of interpretation, not problem identification. ‘What’s the Problem Represented to Be?’ guides the systematic identification of representations, presuppositions and silences in the LPF (2020), whilst decolonial theory provides the conceptual resources to interpret the significance of these findings in relation to epistemic dogmatism, knowledge legitimacy, colonial continuities and apartheid hangovers in higher education. This layered approach is made explicit to avoid presenting theoretical critique as a self-evident textual fact, and instead situates interpretation in a clearly articulated analytical framework.

The article adopts a qualitative critical policy analysis design informed by post-structural interpretations traditions (see Stacey & Mockler 2024). These traditions assume that policy texts do not merely describe social realities but actively participate in producing them through discourse. Accordingly, the study focuses on meanings, assumptions, rationalities and silences embedded in policy language, instead of implementation outcomes or institutional practices. The primary data source is the 2020 LPF, which is analysed as a standalone policy text situated within the wider post-apartheid higher education context.

As indicated earlier, the analysis does not seek to evaluate the effectiveness or implementation of the policy framework but to interrogate how multilingualism and transformation are discursively constructed within it. Analytically, the study is not deductive in a strict positivist sense. Whilst Bacchi’s six WPR questions (Figure 1) provide a structured analytical scaffold, the process of identifying problem representations, assumptions and silences is inherently interpretive and iterative. The analysis, therefore, combines theoretically informed sensitisation with close, repeated engagement with the text, acknowledging personal judgement in meaning-making.

Bacchi’s WPR approach provides the primary analytical perspective for examining how multilingualism and transformation are represented in LPF (2020). The analysis followed a systematic, multistage process of reading the policy framework. Firstly, the policy document was read multiple times to familiarise with the overall structure, stated objectives and recurring terminology. During these readings, analytic notes were made on key terms, emphases and absences related to language, transformation, knowledge production and institutional responsibility. Secondly, the six WPR questions were operationalised as interpretive prompts guiding close textual analysis as shown in Figure 2.

Thirdly, illustrative quotations were selected based on their relevance to dominant representations identified through this process. Quotations were chosen because they exemplified recurring framings and not because they singularly supported the argument. Alternative readings were considered during the analysis, particularly where passages appeared ambiguous or internally contradictory.

To strengthen methodological rigour, the study draws on established qualitative criteria for trustworthiness (as outlined in Anney 2015). Credibility was enhanced through prolonged engagement with the policy text, repeated readings and iterative comparison across sections of the document to ensure consistency of interpretation. Interpretive claims were grounded in explicit textual evidence, and strong theoretical inferences were presented as analytical arguments as opposed to definitive policy effects. Confirmability was addressed through collaborative analysis amongst the authors. Interpretations were discussed, challenged and refined through analytic dialogue, reducing the likelihood of idiosyncratic or unchecked readings. Analytic notes were retained to provide an audit trail of interpretive decisions. Transferability is necessarily limited by the study’s focus on a single national policy framework. The analysis speaks to macro-level policy discourse and does not claim applicability to institutional implementation contexts or outcomes. Reflexivity was integral to the analytical process. The engagement with decolonial theory shaped the interpretive perspective and created a risk of confirmation speculation. To mitigate this, attention was paid to passages that complicated or resisted decolonial readings, and claims about epistemic effects were carefully distinguished from what is explicitly stated.

This study is delimited by its design as a critical policy analysis as opposed to an empirical investigation (cf. Mockler & Stacey 2024). It engages the national higher education LPF as a discursive text, a place where the problem of multilingualism is represented, negotiated and stabilised, and not as a lived institutional practice. As such, it does not include empirical data. Its strength lies in theoretical depth and interpretive reach, not in descriptive generalisation. The focus on the macro-systemic level, the national LPF, positions this analysis in the space where state discourse sets the parameters for institutional transformation.

However, multilingualism materialises in the micro-systems of institutional life: university-specific language policies, pedagogical practices and academic cultures where national intentions are translated, contested or re-signified. The national LPF thus functions as a representative architecture that anticipates transformation but cannot itself perform it. For this reason, further participant-focused critical policy analyses (as compared to the document-focused critical policy analysis in this article) are needed at the institutional level to trace how universities rearticulate the national discourse of multilingualism in their own epistemic and cultural orders. Such studies would not only supplement this work but extend its argument to demonstrate how transformation is lived, negotiated and, perhaps, resisted in the everyday academic project of the multilingual university.

This study does not involve human participants and therefore qualifies as non-human participant research. In line with Rhodes University research ethics guidelines, publicly available policy documents can be analysed without formal ethical clearance. Nevertheless, ethical responsibility was maintained through transparent representation of interpretations, clear distinction between textual evidence and theoretical inference and avoidance of claims about authorial intent. The policy interpretations presented here constitute critical reading and do not purport to represent the intentions of policy drafters, hence the use of a critical policy analysis approach alongside the conceptual framing.

The LPF (2020) constructs the ‘problem’ of language in higher education as the underdevelopment and underutilisation of indigenous languages in academic, administrative and communicative domains. The document states that ‘indigenous languages have in the past and at present, structurally not been afforded the official space to function as academic and scientific languages’ (DHET 2020:9). It locates the failure not in the epistemic or political hierarchies of the academy but in a deficit of institutional mechanisms to promote multilingualism.

The policy therefore recasts linguistic inequality as a technical and developmental problem that can be addressed through improved coordination, planning and monitoring. It claims its purpose is to ‘provide a framework for the development and strengthening of indigenous languages as languages of scholarship, teaching and learning and communication at higher education institutions’ (DHET 2020:10). This framing positions transformation as a process of incremental development within existing institutional architectures, and not necessarily as a change to those architectures themselves.

The consequence of this problem representation is that English dominance, the historical and structural core of linguistic inequity, is backgrounded instead of foregrounded as an object of critique. The ‘problem’ becomes insufficient development of African languages, not the over-development and epistemic centrality of English. In Bacchi’s terms, this illustrates a problematisation effect. By deciding what counts as ‘the problem’, the policy simultaneously delineates what lies outside problem status, including questions of epistemic power.

The framework’s problem representation rests on several interrelated assumptions about language, knowledge and transformation. Firstly, it assumes that multilingualism can be advanced without displacing English as the de facto academic language. English is accepted as the pragmatic lingua franca of higher education, described as having ‘de facto status … as the language of learning and teaching across South African higher education institutions’ (DHET 2020:15). Instead of interrogating this status, the policy frames it as a stable foundation upon which multilingual practices can be layered.

Secondly, the policy assumes that equity can be achieved primarily through policy instruments. The repeated invocation of ‘frameworks’, ‘guidelines’ and ‘implementation plans’ (DHET 2020:10, 16–18) reflects a managerial rationality in which language inequality is taken as an administrative coordination problem as compared to a place of epistemic contestation. Thirdly, transformation is assumed to be largely harmonious and non-conflictual. The policy asserts that multilingualism will ‘facilitate cognitive development, epistemic access, inclusiveness, transformation, social cohesion and respect for all languages’ (DHET 2020:13).

From a decolonial perspective, this emphasis on cohesion and respect downplays the antagonistic dimensions of epistemic change. However, this interpretation reflects a particular theoretical orientation, not an objective policy failure. In WPR terms, such assumptions stabilise the policy field by presenting transformation as a consensual and administratively manageable.

Historically and institutionally, this representation emerges from a policy genealogy by managerial reform. The framework positions itself as a ‘review of the 2002 Language Policy for Higher Education’ (DHET 2020:5) and identifies that policy’s ‘lack of enforceable mechanisms … lack of funding’ as key reasons for limited impact (DHET 2020:10). This diagnostic language reframes political and epistemic struggles as administrative shortcomings.

The 2020 revision intensifies this technocratic orientation by introducing ‘implementation plans’, ‘monitoring and evaluation’ and ‘funding models’ (DHET 2020:16–18) as primary levers of change. The policy is also shaped by the post-2009 reorganisation of the education governance, particularly the establishment of DHET and alignment with the National Development Plan. This developmentalist policy environment privileges efficiency, accountability and alignment whilst offering limited space for ideological or epistemic critique.

Through Bacchi’s perspective, this genealogy explains why the framework reads more as reformist than decentralist. Its representational logic is consistent with a governmental rationality in which policy and management are positioned as the primary instruments of transformation.

The framework is notably silent on several issues that are central within the decolonial and epistemic justice discourse. Nowhere does the text explicitly problematise the historical processes through which English (and other languages such as Afrikaans) achieved epistemic preponderance in South African higher education. Instead, English is acknowledged as a pragmatic reality: ‘Recognising the de facto status of English …’ (DHET 2020:15), without undogmatic input.

Identifying this absence as a ‘silence’ reflects the application of an external theoretical framework instead of a claim about policy inadequacy per se. From a decolonial standpoint, the lack of engagement with coloniality of knowledge and epistemic hierarchy is significant. However, it is also the case that government policy documents do not typically adopt decolonial vocabulary or theoretical critique.

The policy does call for strengthening African Language Departments and conducting ‘continuous research … to intellectualise indigenous languages’ (DHET 2020:15). This commitment could be interpreted as opening a space for epistemic work within African languages. However, the framework does not specify what ‘intellectualisation’ entails in relation to curriculum design, research paradigms or criteria of scholarly legitimacy, leaving its epistemic implications indeterminate. In the absence of such specification, intellectualisation remains a largely aspirational construct and less operational directive. More concretely, the framework could have articulated how African languages are to function as media of knowledge production across disciplines, including the development of discipline-specific terminologies and glossaries (see Mawonga 2026), the incorporation of African language decorum into core curricula and the recognition of multilingual scholarly practices in research evaluation systems. It might also have more strongly outlined institutional mechanisms, such as dedicated funding streams, cross-institutional research networks and revised accreditation criteria, to support epistemic work in and through African languages, thereby linking linguistic inclusion to substantive shifts in knowledge production.

Similarly, greater clarity could have been provided on how curriculum transformation would be enacted, for example through guidelines for integrating indigenous epistemologies into teaching and learning, or through the reconfiguration of existing disciplinary canons to accommodate epistemic plurality. Without such provisions, the relationship between language policy and epistemic transformation remains implicit and programmatically undefined.

The framework also pays limited attention to structural inequalities between historically advantaged and disadvantaged institutions, treating implementation capacity as relatively uniform (cf. Mateko, Dowelani & Sinamano 2025). A stronger approach would have acknowledged these disparities and proposed differentiated support mechanisms, including capacity building initiatives, targeted resourcing and collaborative partnerships, to avoid reproducing existing institutional hierarchies under the guise of policy uniformity.

From a WPR perspective, these silences are analytically interesting. They delineate the boundaries of what the policy renders thinkable, whilst leaving deeper political and epistemic contestations outside its discursive frame. Meanwhile, specifying what remains unarticulated makes visible the extent to which epistemic transformation is deferred, managed or circumscribed within existing institutional logics instead of substantively reconfigured.

The policy’s representational logic gives rise to a range of potential and discursive effects, and not empirically demonstrable outcomes. The framework promotes a discourse of instrumental multilingualism, exemplified by requirements such as ensuring that ‘all official internal institutional communication must be conveyed in at least two official languages other than English’ (DHET 2020:15). Such measures enhance visibility and recognition but do not, in themselves, guarantee epistemic transformation, that is, transformative multilingualism.

Institutionally, the policy may encourage the introduction or expansion of language centres, translation units and reporting structures. These developments can enhance the capacity and employment of African language professionals, but they also risk bureaucratising linguistic justice by embedding it within compliance regimes. At the level of representational logic, the policy frames multilingualism as something to be accommodated within existing epistemic structures and not as a basis for rethinking curriculum, publication practices or assessment.

It is important to note that this interpretation concerns what the policy makes more or less likely, not what universities have done in practice, as institutional language initiatives since 2020 demonstrate considerable variation (as indicated in the literature review). From a WPR standpoint, these effects should therefore be read as discursive and anticipatory as claiming about realised institutional behaviour is beyond the scope of this article.

The framework’s representation of multilingualism is validated through dense intertextual alignment with constitutional, legislative and developmental discourses. References to the Constitution (1996), the Higher Education Act (1997), the White Paper for Post-School Education and Training (2013) and the National Development Plan function as authoritative warrants, thereby positioning the policy as legally necessary and administratively rational.

The emphasis on ‘practical and positive measures’ (DHET 2020:12), alongside rhetoric of collaboration and social cohesion, constructs multilingualism as a unifying national project. This discursive strategy insulates the policy from more radical critique by framing transformation in managerial and moral terms and less ideological ones. In Bacchi’s final analytic step, these representational alliances stabilise a vision of transformation that is ambitious in scope but cautious in epistemic reach.