We understand from media reports today that the Chief Minister of Maharashtra has  forwarded citizens’  concerns and objections to the State Level Committee looking into the matter of NOCs for GM (Genetically Modified) crop field trials, and had ordered for suspension of trials till the objections are addressed.

As signatories, along with a cross section of other institutions and individuals in the field of consumer rights, farmer interests, environmental, social and governance issues, we would like to emphasize that the concerns touch all citizens.

We thank the CM for taking cognisance of these communications, and the concerns and objections expressed therein. We welcome the suspension of the NOC  for open air field trials. We now hope that all concerns and suggestions are looked into with utmost seriousness, rigour and sincerity, given existing and emerging global concerns about the impact of GM crops on citizens’ health, on  environmental sustainability, on India’s export trade as well as on farmers’ livelihoods and seed diversity, already seriously damaged.

We enclose a copy of our letter of 19th February sent to the Chief Minister for your information.

Thanking you,

Justice (Mrs)  Sujata  Manohar  –   Former Judge, Supreme Court of India, Chief Justice, Bombay & Kerala High Courts,   Former Member, National Human Rights Commission.

Mr V. Ranganathan – Former Chief Secretary, Government of Maharashtra

Mrs Dilnavaz Variava – Former Member, High Level Expert Committee on 25 Year Action Plan for Agriculture in Maharashtra,  Former Vice President, Bombay Natural History Society

Mr.Shailesh Gandhi – Former Central Information Commissioner

Indrani Malkani – Trustee & Secretary, V Citizens Action Network (VCAN)


19th February, 2015

The Hon’ble Chief Minister of Maharashtra,




Dear Sir,

Re: GM Crop Field Trials in Maharashtra

We are concerned by  clearances for  GM field trials in Maharashtra. GM field trials involve open air planting of organisms which are untested and new in Nature. A Supreme Court appointed Technical Expert Committee,  has recommended (in 2013) a ban on certain types of  GM crops and a MORATORIUM ON ALL FIELD TRIALS of food crops till certain conditions are met. A 31 member Parliamentary Standing Committee on Agriculture, which included BJP MPs, has also unanimously recommended (in 2012) a complete moratorium. The BJPs own manifesto has assured citizens of biosafety. Biosafety requires long term intergenerational  lab studies on rodents, BEFORE giving field trial NOCs. This has not been done. Almost no State Government has given NOCs for GM field trials, and there is no reason for Maharashtra to do so. There is a great deal of false hype by industry about GM crops’ benefits and safety.  Kindly urgently consider cancellation of  the NOCs given, on the basis of the following data, which can be substantiated from documents,  as GM is not in the interest of Maharashtra.

1.Several hundred peer reviewed scientific  studies have now begun showing the hazards of  GM  crops to health of humans, environment and agriculture, and have exposed industry’s claims of benefits. There is therefore need for caution,  not urgency, in  GM adoption and trials.

2.India will not be ‘left behind’ without GM  technology:  Most countries of the world, including 17 of the 20   most developed countries, are not growing GM crops. They find  the claimed benefits to be minimal and short term, and  that long term risks  far outweigh these. About  90% of GM area is in just 5 countries : USA, Brazil, Argentina, Canada and India. The first four, with their huge farms, grow mainly herbicide tolerant GM crops to save on labour. China plants about one third the GM crop area  as India, has cancelled all field trials of GM and banned GM food for its army. Are all these other countries foolish in their caution?

3.GM is not the best agricultural technology and closes better options : The  world’s largest study of agricultural science and technology, commissioned by the World Bank, FAO and other UN agencies, and undertaken by400 scientists from 50 countries  (IAASTD Report 2008), after 5 years of research, found that  agro-ecological methods practiced by small farmers, and not GM, were best for reducing hunger and poverty. Aggressive marketing of GM seeds rapidly replaces all other varieties, damaging both farmer innovation and seed diversity.

4. GM does not increase farmer incomes as claimed. Increased costs and debts make it risky  for rainfed farmers. It involves high debts due to high costs of seeds and fertilizers, and needs timely  irrigation.  Suicides of cotton farmers continue to be high even after Bt cotton. Though  no organic cotton farmers have committed suicide, Bt cotton is destroying organic exports.


5.GM will notincrease yield or India’s food security, as claimed :  Over 150 Indian scientists have stated that GM does not increase  food security. In USA, in fact, food insecurity is higher after GM crops than before(15% in 2011 versus 12% in 1995).  Millions go hungry, despite huge surpluses of food stocks.GM cannot solve this. The Union of Concerned Scientists, USA, after studying 13 years of GM yields, found  GM yields were not significantly higher than non GM, and sometimes lower. Other studies, too, report this. In contrast, an 80% increase from agro-ecological  projects in 57 countries has been reported by the UN’s Rapporteur on Food.

6. GM does not reduce pesticide use as claimed:  Insecticide use on the target pest can initially go down, but secondary pests and herbicide resistant weeds increase pesticide use in a few years. In India, insecticide use on cotton declined for the bollworm but has increased for other pests. In USA, the use of pesticides (insecticide and herbicide)is considerably higher after GM than before. GM crops, 99% of which contain a pesticide producing and/or a herbicide tolerating  trait, are an extension of the chemical based agriculture which is contributing to sickness, soil and water contamination, global warming etc. The largest GM seed companies are also the  largest manufacturers of pesticides, and wish to sell both !Herbicide used with GM is suspected to be the cause of a massive decline in agriculturally useful insects.

7. GM has adverse impacts on trade as consumers and countries reject GM and seek organic. There was only 3 % growth p.a. in GM area in the last few years, whereas  demand for organic produce is growing at an estimated 10% to 25% pa. India has the world’s largest number of organic farmers, but GM will irreversibly destroy our organic  export opportunities.

8. Unpredictability and irreversibility demand caution in GM experimentation: As it involves release of living organisms, GM trait spread cannot be contained or reversed once grown in open fields, due to pollen carried by wind and insects, and admixture of GM and non GM  seed. Demand for non-GM seed grew by 80% in USA in 2013,but farmers found GM  re-sprouting.

9. Herbicides promoted with GM increased resistant weeds to 61 million acres of US farmland, in 2012(from 40 million acres in 2011 and 32 million acres in 2010).

10. Adverse health impacts of GM food, like tobacco, take long to appear.GM food is not labeled, and thus not monitored in USA, but warnings are emerging from scientists and doctors.

RECOMMENDATIONS ON GM FIELD TRIALS BY THE SUPREME COURT APPOINTED TECHNICAL EXPERT COMMITTEE (TEC) IN ITS FINAL REPORT (2013), SHOULD BE STRICTLY FOLLOWED. More than 250 eminent Indian scientists, of independent credentials, had asked the former PM to implement immediately and completely the TEC recommendations , which include  :

1. A moratorium on field trials of  Bt food crops“ until there is more definitive information from sufficient number of long term studies …as to the long terms safety of Bt in food crops.” Bt crops produce a toxin which kills  insects, and cannot be washed off. There is no scientific agreement about its safety for humans. The TEC said:  “Nowhere are Bt transgenics being widely consumed in large amounts for any major  food crop …The TEC could find no compelling reason for India to be the first to do so”.

2. A ban on Herbicide Tolerant GM crops which are the main GM crops designed to withstand spraying of toxic herbicides where manual weeding is not economically possible. It will destroy employment for millions of rural poor, especially women, apart from the hazards it creates.

3. A ban on  those crops for which India is a centre of origin and diversity, as this constitutes a priceless genetic resource. This includes rice, brinjal and chick peas which are cleared for trial.

4. Proper biosafety  testing in labs BEFORE  field trials: The  TEC  has specified that “There is need to include chronic and trans-generational toxicity testing in feeding studies of rodents based on the fact that food is consumed over the entire lifetime and that nutritional stress can also lead to adverse or unintended effects over long- term exposure. The sensitive stages of reproduction also need to be included”. Presently lab trials on rodents are done by the applicant  and are not long term or intergenerational, as advised by the TEC.  The present approvals are given on90  day trials  – which is equivalent to a human age of 12 years –and far too short for cancer, organ damage and other chronic toxicity impacts  to manifest.


  1. A.     India’s Parliamentary Standing Committee on Agriculture had also recommended halting field trials. They studied, over two and a half years, the Indian experiences with Bt cotton. Their unanimous report, in 2012, was by 31 Parliamentarians across parties, included the BJP.
  2. B.      The BJP’s manifesto states that “GM foods will not be allowed without full scientific evaluation on the long term effects on soil, production and biological impacts on consumers The UPA’s clearance of GM trials was widely resented. The BJP may please  honour its promises.

GM FIELD TRIALS, UNLIKE OTHER EXPERIMENTS,  ARE NOT CONTROLLABLE  AND REVERSIBLE. Contamination does occur, and with serious consequences for trade, foreign exchange earnings and farmers. They can contaminate food, seeds, and environment. Farmers in USA in 2006 suffered over $ 1 billion loss due to contamination by GM rice, ‘destroyed’ after field trials, as Europe immediately cancelled imports. The same happened when GM trial wheat, supposedly destroyed, re-appeared after several  years  in US fields in 2013 and 2014. Farmers suffered due to order cancellations by Japan, Korea etc.  India’s position as the largest exporter of organic cotton has already been damaged due to Bt cotton contamination and non-availability of non Bt seed, but GM seed companies, reportedly earned royalties/fees of over Rs 1500 crores in India from cotton alone. Hence the unrelenting persuasion for GM field trials of other crops and wooing of our agricultural establishment with research grants, foreign trips etc.

Possible contamination of germplasm stored at the Universities not only   threatens our national genetic wealth, but also the rights of farmers,  to whom  our rich banks of germ-plasm rightfully belong, as they have helped create the extant varieties. A contamination incident investigated by the Ministry of Agriculture’s Sopory Committee found that it might have happened during field trials inside the Agriculture University (Dharwad, in this case).

TRANSPARENCY WHEN DECIDING ON GM FIELD TRIALS, IS ESSENTIAL AS IT AFFECTS EVERYONE. The present clearances have been based on the secret deliberations of a small committee, none of whom were biosafety experts,  without transparency and without publicly inviting inputs. Consumers, farmers and future generations  have rights which are put at risk by GM field trials done without following the well considered recommendations of the TEC.  Other States in India  have not  permitted GM field trials and  with good reason.


(1) The TEC Final Report recommendations be followed scrupulously on all counts.

(2) No GM field trials be presently undertaken in Maharashtra

(3)Crops in ongoing field trials be kindly destroyed immediately, to avoid any contamination

We have faith that you will consider our request seriously, call for in-depth discussion on biosafety concerns and a public discussion on GM field trials, as it affects all our citizens.

Thanking you  


1. (Ms) Armaity S. Desai

Former Chairperson, University Grants Commission, New Delhi.

Former Director, Tata Institute of Social Sciences, Mumbai

2. Dr. Asad Rahmani

Director, Bombay Natural History Society

3. Justice (Mrs)  Sujata  Manohar 

Former Judge, Supreme Court of India, Chief Justice, Bombay & Kerala High Courts

Former Member, National Human Rights Commission.

4. Mr. Hoshang Billimoria

Former President, Council for Fair Business Practices

5. Mr.Shailesh Gandhi

Former Central Information Commissioner

6. Mr Julio Ribeiro

Former Commissioner of Police, Mumbai

7. Dr Geeta Balakrishnan

Principal, College of Social Work, Nirmala Niketan

8. Mrs Indrani Malkani

Trustee & Secretary, V Citizens Action Network (VCAN)

 9. Mr. Gerson da Cunha

Convenor, AGNI (Action for Good Governance & Networking in India)

 10. Mrs Dilnavaz Variava

Former Member, High Level Expert Committee on 25 Year Action Plan for Agriculture in Maharashtra and Former Vice President, Bombay Natural History Society

11. Dr. Sharad Nimbalkar

Former Vice Chancellor, Dr Panjabrao Deshmukh Krishi Vidyapeeth, Akola

12. Mr V. Ranganathan

Former Chief Secretary, Government of Maharashtra