This study aimed to shed light on the early phase of implementation of India’s landmark Right of Children to Free and Compulsory Education Act, 2009 (RTE Act), effective as of April 2010, with special attention on the role of the private sector (i.e. private unaided schools). This working paper reports on the household- and school-level results of a larger project conducted in a Delhi slum. Data in this working paper were collected between June 2011 and April 2012 by a survey of 290 households in the selected slum area, semi-structured interviews with a sub-sample of 40 households, semi-structured interviews with principals from the seven most accessed schools in the survey sample, and documentary analysis of offi cial documents including draft versions of preceding RTE bills, the fi nal Act, Central Government model rules, Delhi rules, and associated government orders and notices. We report results on the implementation and mediation processes in schools; experiences of households accessing schooling under the RTE Act, with a focus on their ability to access free school places under the 25 percent free seats provision; and household and school understandings of the Act and its provisions. Results indicate a considerable gap between the offi cial articulation of the Act’s provisions and its implementation in practice by schools in the study. Data also expose that fee-free “freeship” private education for households in the study, was not a reality in the early phase of the RTE Act’s implementation. While the focus of our study was on the private sector and the 25 percent free seats provision, our investigation showed that this was just one facet, albeit important, of the Act. In fact, the Act necessitates fundamental changes, procedural and conceptual, to education as a whole.