———- Forwarded message ———-
From: GM Free India <indiagmfree@gmail.com>
Date: 19 June 2017 at 15:03
Subject: GM mustard decision-making
To: drhrshvardhan@gmail.comps2mefcc@gov.inpsmos-mef@nic.inmustard.mef@gov.in



Dr Harsh Vardhan,

MoEFCC, Govt of India.



Dear Sir,


Sub: GM mustard decision-making – reg.


We introduce ourselves to you as a large national coalition that has been struggling to keep India GMO-Free, so that lasting, sustainable, farmer-controlled solutions can be established and promoted in India’s food and farming systems.


We have had the opportunity of interacting with Late Shri Anil Madhav Dave, including on May 17th 2017, a day before he passed away, on this matter. He was of the view that India needs a cohesive policy on the matter and that there is no need for this controversy to erupt crop by crop. He personally was of the view that GM mustard should not be approved. His predecessor Shri Prakash Javadekar went on record in a specially-organised press conference in February 2016 that GM mustard will not be imposed on the public against their wishes (https://www.youtube.com/watch?v=Rylm4eyUgC8). He also said that no decision that jeopardises public health would be taken.

As you would be aware, a large number of citizens, including eminent experts and farmers’ leaders, have already written to the government of India asking for GM mustard proposal to be rejected; further, state governments do not want any commercialization of a GM food crop like GM mustard.


We read in media reports that you are planning to have a consultation with some invitees before you take a decision on the matter. While we welcome this, we would like to point out that consultative processes are meaningful only if data is shared in the public domain first and responses to various valid questions raised so far are answered with scientific evidence. You might kindly recall the consultations organised on Bt brinjal in 2009-2010 – here, the full biosafety dossier was first published on the regulators’ website, followed by written feedback collected extensively. This was then followed by consultations in eight cities where thousands of people participated. The then Union Environment Minister also wrote to state governments explicitly seeking their views and analysis on the matter.


Coming to GM mustard, the ‘Reply’ of the Regulators/Union of India in the Supreme Court has a clear admission that there is no yield superiority that is being claimed for this hybrid-making technology against India’s non-GMO hybrids and leading varieties. Government also admitted that there are no traits for yield in any of the 3 transgenes inserted to create GM mustard. These admissions were forced out of our regulators in the face of solid scientific facts presented to them. Therefore, the conclusion that follows from these admissions may no longer be contested, i.e., hybrid GM mustard will not lead to higher yields and decline in edible oil imports.


We would like to remind you, Sir, that this GM mustard is a herbicide tolerant crop, and such HT crops being introduced in India with the hope that our regulators will be able to enforce any restrictions to be imposed on herbicide usage is utterly foolish. The great failure to regulate, of both our GM regulators and pesticides’ regulators, is crystal clear by now from the variety of illegalities that we see all around us when it comes to pesticide usage and GM crop cultivation and GM food sales.


The unsustainability and other problems with regard to HT crops are empirically proven. The health hazards are known and predictable. No risk assessment has been taken up of GM mustard as a HT crop, as you know. Glufosinate, the herbicide connected with GM mustard, for which Bayer holds a patent in India, is an acknowledged neurotoxin. From all available information, it’s abundantly clear that this GM mustard failed the very first requirement of proving its need, and should have been dropped at that early stage; nor is it safe, nor beneficial.


  1. We write to you to urge you to take up meaningful and serious consultation processes on the matter, by having widespread consultations with the public in general and not just a set of handpicked “stakeholders”. This is also to communicate that we would like to be part of such meaningful consultations.
  1. We also urge you to re-look at the BJP’s manifesto commitments and stick to the promises made therein.
  1. We ask you to get state government views and independent experts’ analyses of full biosafety data before you take a final decision.
  1. We made a presentation to the GEAC in a specially convened meeting and despite valuable scientific evidence and arguments presented to the regulators, have found our queries and questions unanswered to this day. The regulators chose to function in a biased, opaque and unscientific manner in this matter. We now seek your time, as a group that has studied the subject in minute detail including poring over some raw data for some tests, to make a presentation to bring you the TRUTH of GM mustard – we are convinced that the proponents, crop developers and the regulators will not bring such material to you nor share with you how fraudulent the testing, appraisal and clearance processes were.
  1. There is no scientific, ethical and socio-economic justification for this mustard. From all available information, it is clear that this GM mustard is neither safe, nor beneficial nor needed. We urge you to reject this application in toto, keeping in mind the present and future interest of our Nation.




Sridhar Radhakrishnan,

Co-Convenor of Coalition for a GM-Free India

Mob: 9995358205

Coalition for a GM-free India 

Website: www.indiagminfo.org, email : indiagmfree@gmail.com,  Facebook page – GM Watch India