Coalition writes to PM on how “conditional” approval to GM mustard is unfeasible

———- Forwarded message ———-
From: GM Free India <>
Date: 28 July 2017 at 16:58
Subject: “Conditional Approval” for environmental release of GM mustard


Shri Narendra Modi,

Prime Minister of India.


Dear Sir,

Sub: Recommendation of a regulatory body for ‘environmental release’ or commercial cultivation of GM mustard in India on certain conditions – Lack of accountability and feasibility related to implementation – reg.


From information obtained under the RTI Act, we have learnt that the Genetic Engineering Appraisal Committee (GEAC) and its sub-committee that undertook the safety appraisal of GM mustard are proposing that GM mustard should be allowed for commercial planting in India. This will be based on certain conditions which will be laid down. The regulators have ignored all the valid scientific evidence presented to it with regard to the lack of benefit and safety of GM mustard. The apex regulator GEAC appears to be couching its faulty and dangerous decision in the garb of laying down certain conditions for permission to commercialise GM mustard. A prominent national daily has also reported on the subject on July 27th 2017.[1]

This letter is to highlight the fact that this country has already witnessed a farcical “conditional approval” in the case of Bt cotton. There is no basis on which we can depend on either the pesticides regulators or gene technology regulators in this country to create and implement sound regulation that fulfils the very mandate of regulation. In the case of both “insecticides” (including herbicides) under the Insecticides Act 1968 as well as GMOs under the Environment Protection Act 1986 (and its 1989 Rules pertaining to gene technologies), the mandate of regulation is to protect citizens from the risks emerging out of these technologies, which are risks to their health and environment as well as socio-economic.

Bt cotton conditions not implemented and no one made accountable or liable for non-compliance – this had implications on farm livelihoods: On April 5th 2002, the apex  biotechnology regulator approved the “release into the environment” three Bt cotton hybrids of MAHYCO, subject to certain conditions (vide DO No. 10/14/2002-CS).

One of the conditions was: “(ii) Every field where Bt cotton is planted shall be fully surrounded by a belt of land called ‘refuge’ in which the same non-Bt cotton variety shall be sown. The size of the refuge belt should be such as to take at least five rows of non-Bt cotton or shall be 20% of total sown area whichever is more”. Numerous studies from academic institutions, civil society organisations, and private firms including a Ministry of Agriculture-commissioned-study have clearly shown that an overwhelming majority of Bt cotton farmers do not plant any refuge[2]. This condition has never been followed, yet no accountability has been fixed on anyone for this violation. Regulators have not been made liable for coming up with unscientific and unfeasible conditions either.

Scientists from the country’s premier cotton research institute, Central Institute for Cotton Research (CICR), Nagpur have recently published a paper in Current Science which details the totally unaccountable situation with regard to this condition (“Non Bt cotton seeds provided by seed companies in India – are they suitable as refuge for Bt cotton?”, Current Science, Vol.112 (10), 25thMay 2017)[3]. This study assessed the compliance levels of seed companies, and stated: it is clear that seed companies are violating the guidelines thereby putting the existing concept of refuge at serious risk. This is of course in addition to farmers not planting refuge seeds.

This is a clear example of how conditions laid down are only on paper, which in turn has led to serious problems related to resistance build-up in insects. Bollworm resistance to Bt technology affected the Bt cotton crop, leading to huge losses for farmers. In some states, such losses had to be compensated by the respective state governments using tax payers’ funds. The regulators who imposed the condition, and the seed companies who did not comply with the conditions have gotten away scot-free.

One more condition was: “(xi) MAHYCO will also continue to undertake studies on possible impacts on non-target insects and crops, and report back to GEAC annually”.

An RTI was filed to find out how this condition was complied with. GEAC replied thus: “As part of the renewal process for Bollgard Bt cotton in 2005 and 2007, Mahyco submitted the study reports to GEAC”. This reply clearly circumvents the actual request under RTI and shows neither annual reports nor any reports on possible impacts on non-target insects and crops. So far no accountability has been fixed on any regulators or the company for non-compliance.

Illegal Bt cotton and HT cotton cultivation in India: GEAC’s incapability with regard to regulating is amply demonstrated by the rampant illegal cultivation of Bt cotton in thousands of hectares in Gujarat, in 2001. This was even before Bt cotton was formally approved in 2002.[4]

Years later, illegal herbicide tolerant cotton is being grown in many parts of the country with regulators only discussing the matter[5] and sometimes denying the existence of illegal herbicide tolerant cotton cultivation. Neither was the illegal cultivation stopped nor was anyone held liable for breaking the law[6],[7],[8].

GEAC has routinely ignored complaints of violations of biosafety norms and guidelines: There have been several instances in the past when GEAC ignored complaints of violations of norms and guidelines. In 2008,  Gene Campaign presented evidence on violations in Bt rice field trials in Jharkhand[9]; in 2005 Centre for Sustainable Agriculture produced video evidence on violations in a Bt okra plot in Guntur in Andhra Pradesh which was subsequently reiterated by a state government report on the trial; in 2007 and 2008, the West Bengal government documented violations in Bt Okra trials in the state; in 2011, Greenpeace India along with a private TV channel showed violations with regard to a Monsanto GM maize seed production plot in Karnataka, and in 2015, the Coalition for a GM-Free India presented photographic evidence of violations of a GM mustard field trial plot in Bathinda (the same GM mustard which is being debated in the context of its ‘environmental release’). The GEAC has also ignored reports of its own Central Compliance Committee (CCC) team reports on GM maize and GM mustard field trial violations. If this is the standard of regulation, how safe is this “conditional approval” granted for  GM mustard?

Pesticide Regulators are equally incapable and unaccountable: This sad and unacceptable state of affairs is not limited to the GEAC. It is seen that in the case of chemical pesticides too, the regulatory mechanism under the Insecticides Act 1968 is grossly incapable of regulating the end-use of pesticides, or even the indiscriminate recommendations of chemical companies and even agricultural universities.[10]

For instance, it is illegal to use monocrotophos on vegetable crop in India. However, studies indicate residues of monocrotophos in vegetables, clearly demonstrating the inability of our regulators to control end-use of this chemical.[11]


Given the proven history of apathy and incapability of our regulators (both of GMOs and pesticides) to regulate in the interest of citizens and environment, and implement their own guidelines and norms, it is clear that the GEAC and its sub-committee have not taken this into account while granting “conditional approval” to GM mustard.

In the case of GM HT mustard, this is all the more unacceptable since this GM is completely unneeded in the first instance. In this context we write to you, to urge you to ensure that this GM mustard application is rejected in toto.



Kavitha Kuruganti

(0) 8880067772


Coalition for a GM-Free India



[2] page 49,


[4] [4] ;

[5] December 2009 meeting)

[6] (GEAC




[10] and

[11] and


RTI replies received, on Sub-Committee Recommendations related to GM mustard, and on Bt cotton Conditional approval can be accessed here:

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