To:                                                                                                               October 25, 2016
Shri Narendra Modi,
Prime Minister of India,
New Delhi 110001.
Dear Hon’ble Prime Minister,
Sub: GM Mustard – Request to reject commercial release
We write to you on behalf of Sarson Satyagraha – a broad platform of some of the largest farmers’ organizations, people’s movements, civil society organizations, experts and common citizens, which has come together with serious objections to the release of Genetically Modified (GM) Mustard. Today, on October 25th 2016, a protest was organized under the banner of Sarson Satyagraha against any possible GM mustard commercial cultivation approval and saw the participation of around 30 national level organizations and alliances like Bhartiya Kisan Union, Bhartiya Kisan Sangh, Swadeshi Jagran Manch, Alliance for Sustainable & Holistic Agriculture (ASHA), All India Kisan Sabha, Organic Farming Association of India, Confederation of Beekeeping Industry of India, Azadi Bachao Andolan, All-India Agricultural Workers’ Union, Right to Food Campaign etc. (Annexure 1). In terms of membership and involvement, these organizations represent a few crore Indian citizens, including farmers, agri workers, scientists, and all sections of the society.
Our urgent concern about GM mustard has brought us from 20 states to the national capital in this large mobilization. We are writing to you because this needs the attention of Government of India at the highest level, and we urge you to give your valuable personal attention. At the outset, Sarson Satyagraha is driven by our strong concern for the well-being of farmers, environment, food safety and consumer health. We believe that you share the same concerns. We also have several committed scientists and experts in our group and we have taken a scientific approach to assess the various dimensions of GM technology.
Therefore we are bringing to your notice our substantial objections below and urge you to ensure that the government takes the right decision on this issue. Each point here is substantiated by detailed information in Annexures.
The GM Mustard hybrid and its parental lines are Herbicide-Tolerant (HT) crops but the developer did not apply for its environmental release as a HT crop. Therefore, testing protocols were not designed as would be needed for an HT crop’s safety assessment. The bar gene which confers tolerance to glufosinate herbicide is an integral part of this hybrid development. In fact, an earlier GM Mustard hybrid using the same genes was developed by ProAgro (Bayer), and one of the chief objections raised by GEAC was that it was an HT crop. It is shocking that in the present case, the GEAC has not done its appraisal as it should have done for a HT crop. (See Annexure 2)
The argument by the developers – that though GM mustard has a herbicide-tolerance gene, it is not recommended for use as herbicide-tolerant crop – is a false distinction and meaningless in practice. The release of an HT crop would inevitably lead to heavy marketing and use of herbicides. After the release of glyphosate-resistant Roundup-ready crops in the US, herbicide use multiplied 10-fold from 15 million pounds to 159 million pounds. (ERRATUM: GLYPHOSATE USE MULTIPLIED 10-FOLD)
Serious concerns have been voiced against HT crops from scientists and experts, particularly in the Indian context. The Technical Expert Committee (TEC) appointed by the Supreme Court, in the 5-member report in 2013, devotes a section to the impact of HT crops (Extract enclosed: Annexure 3). The Committee made the following recommendation on HT crops.
“The TEC has examined the issues in relation to HT, particularly with regard to sustainability and the likely socioeconomic impact on major sections of rural society. On both these counts, based on the reasons presented in the section on Herbicide Tolerance, the conclusion of the TEC is that HT crops would most likely exert a highly adverse impact on sustainable agriculture, rural livelihoods, and environment. The TEC finds them completely unsuitable in the Indian context and recommends that field trials and HT crops not be allowed in India.”
In particular, this herbicide tolerant Mustard will be accompanied by the usage of Glufosinate herbicide with a patent held by Bayer, whose brands dominate the market. Heavy herbicide use is shown to have impact on health, and poisoning of fields, soil, water and food. A leading Association of over 30,000 medical professionals in Argentina has pointed to alarming increases in birth defects and cancer after herbicide-tolerant GM soya was introduced there. There are studies linking even low doses of herbicides with organ damage and cancer.
Widespread use of HT crops has also resulted in creation of “super-weeds”. These weeds have affected 61.2 million acres in the US as documented in scientific publications. HT crops also affect the populations of honeybees and butterflies which are major pollinators.
Additionally, adoption of HT crops will drastically impact rural employment. This is a serious concern since the largest number of female workers in the Indian economy is engaged in agriculture, that too as agricultural labourers, where manual de-weeding is a major source of employment. Employment/livelihood generation and environmental sustainability should be the pillars of India’s agriculture policy, and HT crops militate against both. It is estimated that if GM mustard is adopted on even a low 25% of mustard cultivation area in India, this will result in an approximate employment loss of 4.25 crore person-days in rural areas. This is more than the total person-days of NREGS work generated in an entire year in Gujarat or Haryana, and comparable to large states like Bihar and Maharashtra. This is a very large employment loss and will have impact on major mustard growing states including Madhya Pradesh, Rajasthan and Haryana which are BJP-ruled states.
Therefore, GM Mustard needs to be rejected outright for being an HT crop.
The main basis on which this GMO is being considered for approval for commercial cultivation is that field trials showed overall average higher yield over “national check” Varuna by 28.4%, and if this GMO is commercialized, oil production will be enhanced and India’s edible oil import bill brought down. However, this is based on wrong claims and assumptions, as described below and backed by detailed evidence (See Annexure 4, here, here and here).
• DMH-11 was tested against low-performing varieties released many decades ago, whereas there exist other varieties and hybrids which give higher yields. The scientific guidelines for varietal testing require hybrids to be tested against hybrids and latest high performing comparators. Hundreds of public sector scientists put themselves through such assessment, whereas a risky transgenic variety has been allowed unscientific standards, that too breaking regulatory decisions.
• While the GM Mustard DMH-11 has shown a yield of 2626 kg/Ha in limited number of trials that were taken up for just 3 seasons, there are similar or better performing varieties and hybrids, both in public and private sector. This information can be corroborated by data from AICRPRP, as reflected in a Directorate of Rapeseed & Mustard Research RTI response. (Annexure 5)
• We have also shown significant inconsistency in the yield figures shown by the developer, compared to figures derived from raw data recorded during the same trials.
• Claiming that the testing of DU’s GM mustard and results obtained is mainly a proof of concept for heterotic yield advantage through the transgenic bar-barnase-barstar system is untenable, because at the most it can only be a test of pollination control through this system. Proof of concept of heterotic yield advantage will come only if both pollination control and yields are compared with the same hybrids developed in CMS systems.
As shown above, the claim of yield increase through GM mustard is false. Worldwide, experience shows that in the case of rapeseed which is of the same family as mustard, countries which grow non-GM rapeseed such as Germany, France, England and Czech Republic show yields much higher, almost double, compared to the ones which grow GM-rapeseeed such as Canada and U.S. (See Annexure 6). Thus, hybrids developed through Cytoplasmic Male Sterility (CMS) can give high yields without the problems entailed by GM mustard.
While India does face the challenge of high edible oil import, GM Mustard is not a solution to the problem. In fact, there are other promising ways to address them through technological, institutional and policy mechanisms.
The mustard hybrids already in the market over the past decade did not increase the production and yield in the country, or reduce the oil imports. The area of mustard cultivation has actually been decreasing because farmers are finding it unremunerative due to market and climatic factors. Ensuring better market prices for mustard will go a long way to increasing production. This then is linked to trade policies corrected to protect the markets for our producers where they are at present getting priced out due to cheap palmolein and other oil imports.
Further, there are other non-seed based agronomic approaches to increase yield such as the System of Mustard Intensification (SMI). Experiences from Rajasthan (DRMR), Madhya Pradesh (Dept of Agriculture) and Bihar (PRADAN/PRAN) show impressive yield increases (see Annexure 7).
A misleading argument has been around India already consuming imported GM oil, and this fact being the rationale for approving commercial cultivation within the country. We have strongly objected to the decisions to allow import of GM canola and GM soybean oil. These are untested products and lack of any scientific research on adverse impacts of such consumption cannot be construed to be proof of safety. Even so, the imported GM oil constitutes only around 10-11% of India’s edible oil consumption. In fact, imported GM canola oil is less than 2% of our total consumption. It is also apparent that if in-country cultivation is allowed, it is no longer about consumption of highly processed oils, but more consumption of transgenic mustard in more direct and unprocessed forms including seed, leaves and paste. Furthermore, an argument around consumption of imported oil cannot be an argument for allowing cultivation which brings with it other serious issues of impact on agriculture and environment, especially given that this is a herbicide tolerant crop. This will increase chemicalisation in our farms. This will have implications for livelihood security of farm women. There are many countries which allow import of GM oil but do not allow cultivation of GM rapeseed, for good reasons. There are only three countries that allow GM rapeseed cultivation in fact.
In the past one year, we have engaged very actively with the Genetic Engineering Appraisal Committee (GEAC) and the Ministry of Environment, Forests and Climate Change, raising all our concerns about GM Mustard and seeking more information. Some of us also made a detailed presentation in person at a meeting of the GEAC on July 18th, 2016. We are very disappointed that despite the serious engagement from our side, we have not received till date any substantive response from GEAC to all the issues that we have raised.
Ignoring the serious concerns raised by so many scientists, farmer organizations and citizens, the Genetic Engineering Appraisal Committee (GEAC) has moved ahead with the application for commercialization of GM Mustard. The AFES report of the sub-committee was put out on the website for public comment for a very inadequate period of 30 days until October 5th. Despite the orders of Central Information Commission and earlier orders of the Supreme Court, the Biosafety dossier was not published but made available in a very limited and impractical manner that required senior scientists and experts to come personally to Delhi to examine it, and even prohibited them from making any copies for further study. The hasty processes adopted by the sub-committee without all areas of expertise required for appraisal are now apparent.
Serious instances of conflict of interest have been pointed out by us to the Ministry, with a scientist from the crop-developer team involved in R&D, testing and also a member of GEAC, the head of RCGM also being a board member of a biotech industry consortium, etc.
We brought to the notice of GEAC many serious flaws in the R&D and testing of GM mustard which we believe disqualify this application from being considered for commercialization. These include the facts that the yield testing was not done with the standard comparators, and that the combined effects of toxic herbicides and GM have not been studied by assessing this GM mustard as an HT crop. Furthermore, an RTI response shows that ICAR’s Directorate of Rapeseed and Mustard Research has not conducted any trial and the data received by DU/NDDB staff was passed to DRMR for onward transmission to DUSC/GEAC.
A key reason for the 2010 moratorium on Bt Brinjal by the government was the inadequacy of testing protocol. However, GM mustard did not go through even the testing that Bt brinjal underwent, though HT mustard should actually have been put through more comprehensive testing than even Bt brinjal because it is grown on larger areas and consumed in numerous more ways. GM mustard did not undergo chronic health safety testing. Only one sub-chronic toxicity study has been taken up, and no animal feeding studies. No risk assessment in the context of cold pressed oils was performed.
All this underlines our demand for independent scrutiny of the data before decision-making.
Serious concerns exist about the impact on honeybees and hence honey production. Around 5 lakh beekeeper families exist in India, producing 90,000 metric tons of honey, out of which 35,000 metric tons is exported, with an estimated value of Rs.350 crores. Around 60% of the honey produced is mustard honey. The testing of impact on all pollinators including honeybees is very inadequate. Further, it is not tested as Herbicide-Tolerant crop with the expected herbicide use. The Confederation of Beekeeping Industry of India has strongly opposed GM Mustard and is a key member of Sarson Satyagraha.
As the Prime Minister, you have rightly emphasized organic agriculture as a priority through the Paramparagat Krishi Vikas Yojana, declaration of Sikkim as a fully organic state, and initiatives promoting organic farming in several states including the North East. This would make agriculture more sustainable and move towards higher income for farmers by reducing costs. Promotion of GM crops is completely incompatible with this approach. GM crops would increase chemical usage and make farmers dependent on purchasing company seed and other inputs from market. Moreover, this will have a serious impact on the marketing of organic produce because contamination with GM crops is a major concern. The non-GM status of Indian food crops has given an advantage to exports of Indian produce to European and other countries. Allowing GM food crops will remove this advantage.
Similar is the complete disregard of the impact of GM mustard on Ayurveda, though mustard is extensively used in Ayurveda. You would kindly recall that you had stated that your Government is fully committed to promotion of Ayurveda and traditional systems of medicine. However, the testing and clearance of safety of GM mustard neglects this.
Yesterday, in the Supreme Court hearing, Government was reported to have said that GM mustard will be approved only after the Court’s nod. However, it is clear from all available evidence that the government should not wait for the Court, but outright reject the GM mustard application. In fact, it is the government which is providing misleading arguments and coming in the way of the Court taking a concrete decision in favour of social justice, sustainability and scientific integrity.
We request you to recall that the BJP Election Manifesto had a commitment to the Indian public that “GM foods will not be allowed without full scientific evaluation on the long term effects on soil production and biological impact on consumers”. This is indeed a case where full scientific evaluation did not happen, and no long term effects studied.
It is worth noting that cutting across party lines governing different states, governments are rejecting the transgenic option. You would recall the rejection of Bt brinjal too, including by Gujarat under your Chief Ministership.
No state government in India is favouring GM mustard, while many important mustard states have taken a firm stand against commercial approval of GM Mustard; even states that are mainly into mustard consumption are against this HT mustard. States were also against GM mustard field trials. It is not practically feasible to say that the Centre can approve GM mustard for its safety and the states can choose to disallow it. The consequences however will be borne by the states. As a government that professes to stand for cooperative federalism, the Government of India should not go through with GM mustard approval in the face of objections from states.
It is also not appropriate to argue that the government will release it and farmers can decide whether to adopt it. The irreversible nature of GM technology and the problems with HT technology mean that the policy-makers cannot abdicate their role of responsible decision-making. An inherently unsafe technology needs comprehensive and rigorous regulation and that is the only raison d’etre of any regulatory function in the first instance.
All major farmer organizations are raising a strong voice against GM Mustard which they don’t see as a beneficial technology in either short or long term, carrying all the risks described above, and opening the door for many other GM food crops. In view of all the substantive objections that we have put forward on GM Mustard and GM food crops, we demand that the Government of India should reject GM Mustard. We urge you to take this decision as Prime Minister, in the interests of farmers, consumers and environment, and ultimately in the national interest.
Yours Sincerely,
Annexure 1
1. All India Agricultural Workers Union
2. All India Kisan Sabha (AIKS)
3. All India Trade Union Congress (AITUC)
4. Alliance for Sustainable & Holistic Agriculture (ASHA)
5. Azadi Bachao Andolan
6. Bharat Beej Swaraj Manch
7. Bhartiya Kisan Sangh (BKS)
8. Bhartiya Kisan Union (BKU)
9. Biodynamic Association of India
10. Coalition for a GM-Free India
11. Confederation of Beekeeping Industry of India
12. Greenpeace India
13. Hind Mazdoor Sabha (HMS)
14. India For Safe Food campaign
15. Indian Coordination Committee for Farmers’ Movements (ICCFM)
16. Jai Kisan Andolan (JKA)
17. Jan Swasthya Abhiyan (JSA)
18. Kisan Ekta
19. Kisan Maha Panchayat
20. Kisan Sangharsh Samiti (KSS)
21. MAKAAM (Mahila Kisan Adhikaar Manch)
22. National Alliance for People’s Movements (NAPM)
23. New Trade Union Initiative (NTUI)
24. Organic Farming Association of India (OFAI)
25. Right to Food Campaign (RTFC)
26. Samajwadi Samagam
28. Save Our Rice Campaign
29. Swadeshi Jagran Manch (SJM)
30. Swaraj Abhiyan
Andhra Pradesh & Telangana:
Mahila Raithula Hakkula Vedika
Nelamma Mahila Raithula Sahakara Sangham
Pragathi Organic Farmers’ Cooperative
Rythu Swarajya Vedika
Sahaja Aharam Cooperative Federation
GM-Free Bihar Movement
Jeevit Maati Kisan Samiti, Kedia
Khadya Nyay Abhiyan
Various other organisations which are local or national organisations based out of Delhi
The Goa Foundation
Asal organic Shop
Bharatiya Kisan Sangh-Gujarat
Daxin Gujarat Sajiv Kheti Mandal
Gujarat Khedut Samaj
JATAN: A Mission for Organic Farming
Kutch Sajiv Kheti Manch
Madhya Gujarat Sajiv Kheti Mandal
Organic Trade Link
Paryavaran Suraksha Samiti
Ramkrushna Trust
Sabarkantha Sajiv Kheti Mandal
Saurashtra Sajiv Kheti Abhiyan
Shantigram Nirman Mandal
Uttar Gujarat Sajiv Kheti Manch
Bhartiya Kisan Sangh Haryana
Bhartiya Kisan Union (Haryana)
‘Dr Surinder Dalal Keet Saksharata Mission’
Kudarti Kheti Abhiyaan
Swaraj Abhiyan
Swashaasan Mission
Himachal Pradesh:
Himalay Niti Abhiyan
Lok Vigyan Kendra
Paryavaran evam Jan Vikas Sanghatan
Rural Technology Development Centre
Youth for Development
Bhoomi Network
Desi Krushikara Balaga, Haveri
Karnataka Alliance for Safe Food
Karnataka Rajya Raitha Sangha (KRRS)
Malnad Rice Growers Association, Banavasi
Millet Growers Association, Madhugiri
Nesara Farmers’ Market
Sanjeevini Savayava Krushikara Balaga, Dharwad
Sharana Muddanna Savayava Krushikara Balaga, Davanagere
SWARAJ Sanghatane
Haritha Sena
Jaiva Karshaka Samiti
Kerala Paristhithi Aikya Vedika
Madhya Pradesh:
Beej Swaraj Abhiyan
Lok Jagriti Manch
MP Kisan Sangharsh Samiti
Amhi Amchya Arogyasathi
Apeksha Homeo Society
Chetna Samaj Sewa Mandal
GM-Free Maharashtra network
Gramin Yuwa Pragatik Mandal
Kisan Mitra Network
Kalpavriksh, Pune
Nagpur Bijotsav group
Naisargik Sheti Beej Company
Sanwad, Rawala
Sashwat Sheti Parishad
Sawitri Mahila Mandal
Vanvadi Agro-ecological Regeneration Assocation
Vasundhara Jaivik Kisan Sanstha, Maharashtra
Vidarbha Farmers Study Group
Basudha, Odisha
Birupakshya Krushak Sanghatan
Kandhamal Parompariko Chasi Sangathano
Matrubhoomi Organic Farmers Cooperative
Nabanirman Krushak Sanghatana
Paschim Odisha Krushak Sanghatan Samanvay Samithi
Pondicherry Organic Farmers’ Association
Bhartiya Kisan Sangh, Punjab
Bhartiya Kisan Union Ekta Sidhupur
Environmental Health Action Group
Hitkaari Kheti
Kheti Virasat Mission
Kudrat Manav Kendrit Lok Lehar
Kudrati Kisan Haat, Ludhiana
Rajiv Dixit Bharat Chetna Manch
Vatavaran Atey Samaj Bachao Morcha
Women Action for Ecology
Hanuman Van Vikas Samiti
Kisan Sewa Samiti Mahasangh
Mazdoor Kisan Shakti Sanghatan
Swaraj University
Vagad Mazdoor Kisan Sanghatan
Yuva Mandal
Tamil Nadu:
Peoples Livelihood Association
Tamil Nadu Organic Farmers Federation
Thalanmai Uzhavar Iyakkam
Thamizhaga Vyavasayigal Sangham
Vanagam – Nammalvar Ecological Agriculture Research and Training Center
Safe Food Alliance
Uttar Pradesh:
Bhartiya Kisan Union
Gorakhpur Environment Action group
Beej Bachao Andolan, Uttarakhand
Chintan, Uttarakhand
Mahila Umang, Uttarakhand
West Bengal:
Forum for GM-Free West Bengal
Gona Udyog
EarthCare Books
Kisan Swaraj Samiti
Mahatma Gandhi Gramodyog Sewa Sansthan
Annexure 3: Extract on HT crops from SC TEC 5-member report
HT in the Indian context 
There appears to be a fundamental incompatibility between greatly increased intensity as well as persistence of usage of one or two herbicides as a feature of HT technology, and sustainabiiity of weed management in the Indian context. Comparison between USA where evolved glyphosate resistant weeds have arisen, and Canada where they have not, shows that on average HT canola is grown on a particular cropping field in only one year in four in Canada (Duke and Powies, 2009), whereas in the USA, glyphosate has been successively applied for several years together. The deployment of glyphosate in Canada has therefore been under conditions of far lower selection pressure for emergence of glyphosate resistance than in USA. In the case of India, the availability of land is very much less than USA and Canada, so there is much less room for control of deployment. In fact if HT traits (single or stacked) are applied in Indian agriculture, then one can expect that compliance to recommendations for sustainability such as rotation of crops and herbicide treatments is likely to be low as there is already a tendency among Indian farmers, especially small-scale farmers to overapply pesticides (e.g. Andow, 2010: Bt-brinjal, Finding 6, p13). Use of herbicides on HT crops in India is likely to be driven more by considerations such as performance of the herbicide, convenience, and differences in economics of different HT treatments even if these are small, rather than compliance to conditions for reducing selection pressure for evolution of resistant weeds. All of these would contribute to lowering the sustainability of HT crops. 
Another consideration in the Indian context is a socioeconomic one wherein a significant part of the large agricultural workforce, particularly landless labourers is employed for manual labour in the fields including tilling and weeding operations. The small average size of agricultural land holdings makes this realistic whereas HT traits have greater impact in large scale agriculture systems where tilling and manual weeding require greater investment and there is limited availability of manual labour. Introduction of HT crops would be likely to reduce access to employment for some of the vulnerable sections of rural society. While it is true that in some areas of India there is shortage of agricultural labour and the introduction of HT crops may benefit this section of farmers (at least in the short term), the overall impact that HT crops would have in terms of reducing jobs for agricultural labour in the fields is likely to be more significant. 
The major concern with HT approaches is the excessive reliance on increased amounts of one or two herbicides which results in strong selective pressure for the emergence of herbicide resistant weeds and’ a negative impact on sustainabiiity. The benefits of HT crops in the Indian context may be short term and variable. In addition they are likely to be accompanied by negative socioeconomic consequences as wel! as on the environment There are alternatives to HT and it is likely that integrated weed management approaches (not stacking) as part of a basket of technologies would be more appropriate in the Indian context.
6. The second largest number of applications were for HT crops. The TEC has examined the issues in relation to HT, particularly with regard to sustainability and the likely socioeconomic impact on major sections of rural society. On both these counts, based on the reasons presented in the section on Herbicide Tolerance, the conclusion of the TEC is that HT crops would most likely exert a highly adverse impact over time on sustainable agriculture, rural livelihoods, and environment. The TEC finds them completely unsuitable in the Indian context.
6. page 71, lines 3-5:”… exert a highly adverse impact over time on sustainable agriculture, rural livelihoods, and environment. The TEC finds them completely unsuitable in the Indian context.”
Corrected:”… exert a highly adverse impact on sustainable agriculture, rural livelihoods, and environment. The TEC finds them completely unsuitable in the Indian context and recommends that field trials and release of HT crops ‘   not be allowed in India.”
Annexure 6: Yields of GM- and non-GM adopting countries, of Rapeseed
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