———- Forwarded message ———-
From: GM Free India <indiagmfree@gmail.com>
Date: 11 September 2017 at 14:17
Subject: Response to NAAS’s report “Falsehoods perpetrated by GM technology bashers on GM mustard”
To: naas@vsnl.com
Cc: panjabsingh03@yahoo.com, drhrshvardhan@gmail.com, ps2mefcc@gov.in

Dear NAAS scientists,

Please find pasted below, and attached a response from the Coalition for a GM-Free India, to your report flashing on the NAAS website called “Falsehoods perpetrated by GM technology bashers on GM mustard”.



A so-called ‘report by NAAS scientists’ titled “Falsehoods perpetrated by GM technology bashers on GM mustard” was put out by the National Academy of Agricultural Sciences (NAAS) recently (http://naasindia.org/). This report is supposed to have been prepared by Prof R B Singh and ‘a few other colleagues’, in defence of GM mustard. The report claims that after perusing various arguments put forward by “GM bashers” and analysing the same, the authors have come to a conclusion that the reports are fallacious and wilfully distort scientific data.

NAAS scientists have conveniently chosen to put out “analysis of some of the arguments” and have avoided picking up uncomfortable questions and evidence, which we have listed at the end of this note once again. It is not as though NAAS has the responsibility to defend the crop developers’ or regulators’ fraudulent practices and be their PR agent – however, it is also clear that certain key issues are being avoided when NAAS did choose to join the debate. Meanwhile, GEAC has the responsibility to provide answers. The regulators have not dared to proffer any evidence so far on the scientific questions raised over two years now.


It is not out of place to recall that NAAS has already brought disrepute on itself in 2010, when it joined hands with other science academies, to plagiarise some PR material of GM crop developers, in the name of reviewing the safety of Bt brinjal. The then Environment Minister remarked that the science academies’ report is best put in a dustbin. This is another such piece from NAAS which deserves the same, a dustbin.

The main responses given by NAAS to some of the arguments against GM mustard, and our counter arguments on the same are given below:

NAAS’s so called analysis Our Counter Arguments, that show how unscientific and compromised NAAS is

1.       European rapeseed yields at 3.9 tons/hectare cannot be compared with Canadian yields of 1.9 tons/hectare as European rapeseed (winter types) is a 300-day crop, while in Canada (spring type), it is a 120-day crop.

a.       The GM mustard blind-promoters have always showcased only Canada’s GM canola experience, both in the regulatory submissions and in PR materials. This needed to be countered with a picture from higher yielding situations, as well as more impressive yield improvements, and that is where the comparison is relevant – including looking at China, for example.

b.      We agree that the comparison is not just about absolute yields as per FAO averaged over the past 5 years across different countries. Data clearly reveals that yield increases in Europe have outpaced yield increases in Canada, when it comes to rapeseed, along the same timelines where Canada relied on GM hybrids/transgenic R&D and Europe relied on CMS hybrids/R&D (https://gmoinquiry.ca/wp-content/uploads/2015/11/Are-GM-crops-better-for-farmers-E-web-singles.pdf).

c.       Spring oilseed rape yields in the UK in the recent years have averaged 2.5 tons/hectare for several cultivars. In general, in both Eastern and Western Europe, spring oilseed rape yields are around 2 tons/hectare to 2.2 tons/hectare. This is still significantly higher than GM canola (spring oilseed rape mainly in the Western provinces) of Canada and NAAS surely knows this.

d.      In the case of China, yield increases, compared to the decades before the advent of CMS hybrids and the yields in the decades thereafter show that yield has increased by more than two-fold. In China, yields of around 1.24 tons/ha from mid-80s to 1999, when the advent of (non-GM) hybrids began, to 1.71 tons/ha during 2000-09, and around 1.95 tons/ha by 2015. This is better than the Canadian yield increases. The average canola yield in several provinces of Canada was 1.3 tons/ha between 1981-82 and 1999-2000, while it was 1.67 tons/ha between 2000-01 and 2012-13, when GM HT canola took over.

It is clear that non-GM hybridisation options exist, and have greater potential compared to GM hybrids as seen in other countries.

Given all the above, it is very apt that various stakeholders concerned about GM mustard are pointing out to the substantial potential that exists with non-GM alternatives that other countries have adopted successfully and that is the main point with the bar graphs being used on yields of other countries.



2.       Testing of DMH-11, against Varuna, Maya, RL-1359 are apt; Kranti not included in the trials is justifiable with data from AICRPRM trials of past 8 years.

The justification being provided by NAAS is ridiculous. First, it is retro-fitting yield data of certain zonal checks used, to how they are similar to the national check that is supposed to have been used. In this argument, it is forgetting that the appropriate check should have been a Hybrid!

If particular Zonal and National Checks as comparators need to be justified in this manner, and not the national and zonal checks as decided by the AICRP-RM system, then NAAS better get down to changing the AICRP protocols. Why has it kept quiet all these years if it thinks that Varuna needs to be the comparator for all new varieties and hybrids to be assessed and released in India? Can hybrids in different crops be tested against those varieties which have received the highest indents in the public sector seed establishment and will ICAR accept NAAS’s arguments?

Why has the GEAC laid down other hybrids and also isogenic lines as comparators? NAAS should go and challenge all these systems which are “nothing but mischief” and not just do some retro-fitting to defend DMH-11.

If the AICRP system is just “mischief”, then hundreds of scientists being put through it in the name of collective wisdom is questionable, and NAAS has to make a case for dismantling the system not just in rapeseed mustard, so that DMH-11 testing can be propped up unscientifically, but across crops.

Importantly, it is not just the protocols adopted that are unscientific, unprescribed and unreliable, but the doctoring of data, as presented in detail by civil society representatives to the regulators. NAAS has no responses to provide and has kept quiet, compromising on scientific integrity on this matter.


3.       Low yields of DMH-11 justified on the grounds that “finding and breeding parental lines for developing hybrids with higher yields is an ongoing process”.


NAAS should realise that this applies to CMS technology hybrids also. Let India also invest on non-GM hybrids like in the case of China and most other rapeseed-mustard growing countries, rather than tread the path of just 3 countries. India should also explore several non-seed based technological and policy options for obtaining higher yields, which are bound to emerge, as evidence indicates already.



4.       Comparisons with some new varieties which apparently outperform DMH 11 are scientifically infructuous, because these are comparisons from different field trials.


NAAS is intentionally missing the point being made with such comparisons. No one claimed that these results are from the same trials. In fact sources of such data have always been quoted proving that these are comparisons of data from different trials.  But the point remains that the results from more robust (more locations, more zones, more seasons) testing of other cultivars is showing them to have good and better yields. It is to point out why DMH-11 was conveniently compared against particular outdated, unprescribed comparators disregarding the AICRP system, that yields of such newer varieties and hybrids have been put out, in addition to showing their potential.

NAAS surely knows that in 2005-06, GM mustard was compared with non-GM hybrid under AICRP where the yield of GM mustard was not found better and during BRL trials, comparators were changed to show GM mustard better against poor comparators. How does NAAS justify this? What is the interest of NAAS to promote non-AICRP protocols? And why can’t the protocols adopted in the case of GM mustard be called “scientifically infructous”?

Given that DMH-11 itself was not tested properly, showcasing data of other cultivars was done by independent scientists and others to present their high potential, the fraudulent testing of DMH-11, the violations of regulatory conditions imposed on the crop developer by the regulator and the bypassing of the AICRP norms. NAAS, despite its so-called analysis, has no convincing answers as to why all these violations should, and have been allowed and why DMH-11 did not get tested against AICRP protocols and the best cultivars in our research system.


5.       Analysis of post-release yield data of new varieties shows that these are more or less on par with current national check Kranti.


It is not clear what NAAS wants to say here. It is a well known fact that there is a ‘yield gap’ between research plots and post-release yields. Kranti is being defended as a national check here by NAAS, but has not been used in DMH-11 testing. In fact, a hybrid should have been used.

6.       There is no significant seed indent for new varieties as old varieties like Varuna and Pusa Bold remain the most popular varieties amongst farmers.


This then is a point that we are making too – that given the low uptake of DMH-1 and other such cultivars, the grand projections being made around DMH-11, just to create opportunistic and specious excuses around edible oil import bill being brought down to get GM mustard approved, are unfounded. While there will be no uptake, there is the unacceptable danger of contamination even from limited release. Meanwhile, taxpayers’ funds are being wasted.

Further, as argued above, seed indents cannot be the basis for selecting comparators in regulatory assessment. If that were so, NAAS should first change the AICRP system and GEAC permission letters, and then make its case in reports such as this.

However, we do agree that appraisal has to take into account, after utilising proper scientific protocols, many other socio-economic criteria, institutional shortcomings in actual seed production and supply, shortcomings in regulatory capabilities etc. when it comes to decision-making.



7.       Contrary to the ‘propaganda’ that there is very high diversity in Indian mustard, the Indian gene pool of mustard is very narrow.


The only way out of the current yield stagnation is to exploit hybrid breeding in mustard

The fact that there is diversity in Indian mustard is to be considered “propaganda” only if NBPGR data is to be called “propaganda”. NAAS is wilfully ignoring the fact that intra-specific diversity will certainly be contaminated if GM mustard environmental release is permitted. Why or how is this ‘propaganda’? Just because NAAS decides to use the word ‘propaganda’? It is unscientific for a scientific body to ignore the diversity that exists, and the implications on that diversity from GM mustard. What is the mechanism in place to avoid such contamination? Who is liable for such contamination?


Secondly, about the point that hybrid breeding has to be exploited – this cannot be equated with transgenic hybrid breeding. There is absolutely no proof or evidence or comparison that was provided to show how GM hybridisation is superior to, or required, vis-à-vis non-GM technologies. What is “robust” about this hybridisation that is not there in CMS, which has been proven in a comparative framework as part of GM mustard testing? NAAS cannot provide an iota of proof on this since no such comparison was done!



8.       Yes, GM mustard ‘contains a herbicide (glufosinate) resistance conferring transgene’ but “the hard fact” is that HT trait will be used only for hybrid seed production.

Just because NAAS uses a phrase (“the hard fact”) does not mean that Indian regulators will suddenly become capable of regulating either GM seeds or pesticides’ end use at farmers’ level. This rhetoric has been shown for the big lie that it is several times in the past and this letter to the PM also cites the same: http://indiagminfo.org/coalition-writes-to-pm-on-how-conditional-approval-to-gm-mustard-is-unfeasible/

GM mustard is a HT crop and farmers are not going to wait for NAAS scientists or an inept GEAC to give them a go-ahead if they choose to use glufosinate on the crop. About the debate about HT crops and their suitability or requirement in India, several committees have looked into the matter and have clearly recommended against it, even if NAAS does not like the fact.

What did NAAS or GEAC do to curb illegal cultivation of Bt cotton and HT cotton in India? On what basis is NAAS saying that end use of pesticides will be controlled /regulated at farm level – is there any regulatory mechanism being proffered here? This example was brought up earlier and is being put again – in India, monocrotophos use is restricted in vegetable cultivation. However, farmers routinely use it as various evidences show. In such a case, what is NAAS’s solution for end-use regulation that has shown results in India, and given large regulatory failures in the past, on what basis is NAAS saying that herbicide will be used only in seed production of GM mustard?



9.       Genetic pollution of existing varieties is a myth being conjured. Transgene spread follows well established models of population genetics. Since herbicide will not be used, there will be no selection advantage.

Simple cross pollination of non-GM mustard crop in neighboring fields with GM mustard, or contamination through intentional or unintentional admixtures is a hard reality and cannot be denied as a conjured myth by NAAS.

While the crop developer, regulators and blind advocates of GM mustard like NAAS have not worked out the population genetics, in a presentation to GEAC, civil society representatives attempted to, and showed how GM mustard will end up compelling all farmers (the GM hybrid adopters as well as non-adopters) to shift towards GM mustard due to this contamination possibility.

The argument that there is no selection advantage without herbicide usage is a specious and circular argument since the ones resisting GM mustard are pointing out that farmers will indeed use herbicide, and that then confers a selection advantage. The spread of HT gene is a reality in other countries and it would be good if NAAS does not expose its lack of review of scientific literature on this subject in this manner.


10.   GM rapeseed was introduced in Canada, USA and Australia after “very involved biosafety studies”.

NAAS should provide proof of the “very involved biosafety studies” that were taken up in Canada and elsewhere before propagating this lie. (https://www.canada.ca/en/health-canada/services/food-nutrition/genetically-modified-foods-other-novel-foods/approved-products.html and more specifically, the 1994-95 approvals to GM canola). What it needs to know is that no health studies of any kind (laboratory based feeding studies) were taken up in Canada on the simple grounds that GM canola oil will not contain any protein and therefore, no testing is required. No effects of combined herbicide+GM impacts were studied either. Here in India, we will be consuming not just the oil, but leaves and seeds too if GM mustard is approved.

The basic lacunae in biosafety assessment of GM mustard, within the limited data available in the public domain have been pointed out repeatedly. These are available on websites like http://indiagminfo.org. NAAS is choosing to ignore all the questions asked there.

Once again, NAAS is exposing its lack of basic review of literature.


11.   There are no reports of ill effects from any of the growing or consuming countries when it comes to GM rapeseed.


This has been responded to ad nauseum by several, including the Supreme Court TEC. Lack of scientific evidence in real life food supply chains, with unlabelled, unsegregated GM materials is not evidence of safety. Can NAAS show any study by which it can conclusively show that prevalence and incidence of illnesses in GM-consuming populations is not correlated to GM consumption?

Environmental ill effects have certainly been documented and the same presented to Indian regulators as a small compilation already. To deny that there are no ill effects is just a biased, unscientific position being taken by NAAS – resistant weeds, contamination and gene transfer, feral plants, increased use of chemicals etc. are certainly reported from growing countries.


12.   The value of edible oil imports (of upto Rs. 68000 crores of rupees) should have been earned by our farmers.


We certainly believe that India should have a policy vision and political will to reduce edible oil import dependency of this country – for that to happen, the government has to incentivise our farmers and not price them out through cheap imports and unsupportive price and procurement policies. Even a small part of the forex outflows as a public investment would have helped.

Further, NAAS should provide proof to this statement which implies that release of hybrids will lead to reduction in edible oil import bill. Data has already been put out to show that release of such cultivars has not resulted in greater production or reduction in imports.

It is clear that yield-centric techno-fixes, that too based only on seed-based monopolistic solutions, are not likely to address our edible oil import crisis. Using the edible oil import crisis to push a hazardous junk cultivar will no longer cut any ice with the public.


13.   DMH 11 and its parental lines were cleared by GEAC after thorough analyses by expert committees.


NAAS has appraised itself of all the conducted

studies and unequivocally

state that this technology

is as safe as the non-GE



It is not clear which are the expert committees in plural that NAAS is referring to. Much material has already been put out how a Sub-Committee has been constituted, how it has functioned and why it is unreliable. NAAS does not seem to have any defence of this.

It is also not clear how a scientific body like NAAS is claiming that it has appraised itself of all the conducted studies, unless it is talking about the crop developer and the sub-committee members being part of NAAS and they having appraised themselves of their own data! Independent scientists were not able to, since the regulatory body chose to hide data from public scrutiny. NAAS, being the self-appointed PR agency that it is, might have gone to the GEAC office to give an appearance of having gone through 4000 pages in an hour or so and “appraised itself” of all the studies.

There is nothing about NAAS’s analysis so far that inspires confidence that its appraisal can be relied upon, either in this report, nor its earlier resolution, nor its plagiarised work with other science academies on Bt brinjal.

If NAAS is serious about joining the scientific debate, it has to respond in detail to the queries raised on the appraisal of this GM mustard, available at http://indiagminfo.org .


14.   Barnase/barstar is a very efficient system for hybrid seed production. It does not increase the yield of the crop per se, and is a pollination control mechanism to produce hybrid seed.


The basis for the assertion on the BBB system of hybrid seed production is missing. No testing has been done of this system with the CMS as well as other hybridisation options that exist. So, how has NAAS arrived at its conclusion?

Even in terms of its pollination control effect, the assessment of DU’s BBB system is unscientific and non-standardised, as data in the biosafety dossier shows (with male sterility breakdown pointed by particular studies as well as CCC field trial monitoring reports). Even the yield figures of the male sterile lines are questionable in all trials.


15.   On SMI: “we believe that this data is not authentic” and that yields of up to 4.7 tons/hectare are nothing short of a miracle.

NAAS is obviously impressed by the yield figures, and that is welcome. We feel glad that they are at least taking note of some innovative approaches emerging at the grassroots though not from academic agricultural institutions. They should now experiment themselves as well as go into the field to study this approach, to verify for themselves, and to see how its potential can be fully reached. In the SRI debate related to paddy too, this was the first reaction of the scientific establishment that is blind to innovations outside their campuses. Rather than take up a logical scientific inquiry, NAAS thinks that it suffices to say that it is ‘nothing short of a miracle’. As scientists concerned about Indian farmers, we expect NAAS to chase that promising approach which will give sustainable yield increases in perpetuity which they mention elsewhere.

NAAS should first begin to behave like the scientific body that it ought to be, rather than a PR agent and a biased loose cannon. By putting out a report of the kind that it has, NAAS has lost its credibility some more, and in fact, has not been able to defend anything about GM mustard – neither its herbicide tolerance trait, nor its fraudulent testing, nor its contamination potential, nor the experiences of growing such crops elsewhere.

The entire support to GM mustard is now resting on three assumptions, which have no basis whatsoever – that hybridisation is possible only through the transgenic BBB mechanism (quite apart from this is the assumption that only hybridisation will lead to yield improvements, and also an assumption that yield improvements will benefit farmers!!); that contamination will not happen or can be ignored, when it happens; that herbicide usage on a herbicide tolerant crop can be regulated. Flowing from these assumptions are many other wrong conclusions. These assumptions are unscientific and have no evidence base and NAAS has not been able to present anything otherwise in its so-called report.


Below are some of the questions that remain unanswered by the regulators as well as bodies like NAAS which are choosing to act like PR agents of the biotech industry:

  1. Why is Government of India claiming on oath in the Supreme Court that GM mustard is not herbicide tolerant when bar gene, that too driven by a double enhancer promoter in one of the parental lines, confers herbicide tolerance? What tests have been conducted on GM mustard as a HT crop?
  2. What are the mechanisms in place to prevent farmers from using herbicide on GM mustard, other than empty meaningless statements on paper that “it is not being recommended”? What proof is there of effective regulation in the past, of either GMOs or pesticides?
  3. Why is the charade of ‘high yields from GM mustard being a way to address India’s edible oil import crisis’ being continued without any data and evidence to support the same? Is there evidence to show that yield improvements of upto 25-30% that came about from non-GM breeding including non-GM hybrids have indeed improved production and reduced our import dependency?
  4. Why were the AICRP protocols and GEAC conditions violated in GM mustard testing, and what action has been taken on the same including the inconsistencies between derived yields and yields reported from the trials?
  5. Why is the biosafety dossier of GM mustard being hidden from independent scientific scrutiny?
  6. How do we know that BBB system is reliable without any comparison with other hybridisation technologies, without standardised protocols and data generation during GM mustard testing and appraisal? What is being done about inconsistent data about male sterile line yields (in fact, how much of the Varuna barnase line yields are due to male sterility breakdown and how much due to cross pollination and what is the basis of conclusions on this), about CCC team field trial monitoring findings, about male sterility breakdown etc.? Why is the limitation or insistence of one research centre (CGMCP) to use its own exclusive CMS line (126-1) being made the limitation of this country’s research establishment which has several CMS lines to work with?
  7. How were parental lines swapped in the regulatory system continuing with the same hybrid name, without informing the apex regulatory body?
  8. Why is GM mustard testing limited essentially to 3 years and 8 locations, while the entire AICRP system, even for non-GM lines puts cultivars through 5-7 years of trials? How is one year of pollen flow study in one location done by the crop developers themselves reliable?
  9. How will contamination be prevented of non-GM cultivars and mustard diversity that exists in the country, and what is the liability regime in place when choices are violated due to contamination?
  10. What are the mechanisms in place to uphold state governments’ policy choice of disallowing GM mustard in their respective states so that unapproved spread of GM mustard does not take place?
  11. Why was population genetics data not been submitted as part of appraisal including of realistic scenarios of non-GM mustard fields around GM mustard?
  12. Why were no long terms independent tests taken up and why was testing on GM mustard (despite mustard being grown on a larger area, consumed in more direct ways, having more livelihoods dependent on it) not even as much as on Bt brinjal, which itself was rejected because of inadequate testing and safety conclusions?


Along with all the above questions, one more question is to be asked of NAAS: Why is NAAS acting as a PR agent of the biotech industry and at whose behest?