The kind of remedial relief sought might differ on the basis of whether the government has failed to realise the right to education or whether a private provider of education is being held to account. Previous failures on the part of the duty bearer might also encourage a push for increased judicial oversight. Any decision to settle out of court should only be made with confidence that there is a willingness on the part of the private provider or government to fulfil their obligations under the right to education. Are stronger remedies that mandate specific action more appropriate in the context of private providers of education, and weaker, more deliberative remedies better suited to holding the state accountable for education provision?