Coalition for a GM-Free India

October 5, 2016

Shri Narendra Modi,
Prime Minister of India,
New Delhi.
cc: GEAC, Ministry of Environment Forests and Climate Change

Dear Sir,

Greetings! This is with regard to GM HT (Genetically Modified Herbicide Tolerant) Mustard that the Government of India seems keen to approve for commercial cultivation. If approved this will become the first GM food crop coming into farmers’ fields and our food chain for more direct ways of consumption. A large body of valid, evidence-based questions have already been raised on the very need for this GM mustard, and the scientific deception that was used in its R&D and testing. It is worth noting that this becomes a matter of probity and integrity as more than 100 crores of public funds were used for this GM mustard. It is not clear why this investment was made, nor why the application was processed given that it is a herbicide tolerant crop, which is a particularly dangerous GMO. Its adverse impacts have shown up in countries that have adopted it. In India, the unacceptable adverse impacts would be greater and more direct, including on poor rural women who find employment in manual de-weeding.

Evidence has also been presented to show that the regulators’ safety assessment (apart from the R&D and safety studies conducted by the crop developer to fulfill the requirements) is unscientific, hasty and importantly, did not have required independence or areas of expertise. The concomitant risk assessment document (called AFES) was not prepared by the sub-committee of the GEAC but by someone else. This document has been put out for public feedback without even being reviewed by GEAC.

Numerous letters, emails, faxes have been sent to the Ministry about the unscientific, hasty and opaque processes being adopted, making a farce of science and public participation. However, this did not evoke any meaningful response from the regulators whose job is to protect citizens from the risks of modern biotechnology. Without access to the biosafety data and adequate time for a well-analysed and considered feedback, we refuse to participate in a farcical processes.

If science is respected and followed rigorously, including through processes of independent scientific review, would GM Mustard get approved? We believe that it would not, and this is the reason why the regulators are hiding the biosafety dossier from public scrutiny.
We write to you to ensure that scientific integrity is not compromised in any way in the name of swadeshi public sector GMO and unfounded benefit claims.

We urge you to ensure that decision-making on this GM mustard (and any GM crop) is scientific and participatory, giving adequate time for all stakeholders to participate meaningfully and with free and easy access to complete data in the public domain. An independent scrutiny that follows this is the only way your good self would appreciate why there is opposition to GMOs. Science will speak for itself then.

If the risk assessment regime is robust, if the assessment conducted on GM mustard was sound and conclusions drawn are reliable, the crop developers and regulators should have nothing to hide from the public. It is therefore very important that the government run thorough processes to convince itself and citizens of the need and safety of GM mustard. At the same time it also needs to be open to taking NO for an answer if that is how the citizens feel about GMOs in our farms and food.

The citizens, farmers, consumers have serious concerns about GM crops, and the government has the responsibility of addressing their concerns. The essential first steps for that are to make all the data public, seek independent scrutiny providing sufficient time, and hold public consultations with farmer organizations, independent experts from all relevant domains, and citizen groups. We demand no less from the Government of India.

Sridhar Radhakrishnan
Co-Convener, Coalition for aGM Free India
(Mob : 09995358205, email :