Coalition for a GM-Free India
7th May 2012
Smt. Jayanthi Natarajan
The H’ble Minister, MoSEF (Independent Charge)
Government of India.
SUBJECT: YOUR STATEMENT IN PARLIAMENT ON 27 MARCH 2012: ‘DELAY IN NOCS FOR GM CROPS TRIALS’
Dear Madam Minister,
Greetings from the Coalition for GM-Free India.
In your statement in the Rajya Sabha on 27 March 2012, you stated that “the GEAC has been approached by the Seed Industries, Ministry of Agriculture and Review Committee on Genetic Manipulation (RCGM) to reconsider its decision on the need of NOC from the State Government prior to the conduct of GM crop field trial.” Consequently, the GEAC has apparently decided to make presentations to State governments to withdraw their bans on field trials1.
We must point out that in the present circumstances where these GMOs remain untested, this action to promote open field trials by the GEAC if carried out, would be contrary to its mandate under the EPA and consequently illegal. It forsakes the absolute requirement of independence and objectivity in a regulator, as required by law, to instead become a lobbying body to advance the cause of the biotech Industry. Furthermore, to lobby formally at the behest of the seed industry as explicitly admitted in your statement would then prove the serious charge of a blatant conflict of interest in your Regulator and particularly in the present climate of corruption may well raise serious questions.
Should such corporate influence in the decision making process lead in the future to farmers’ losses and even suicides, the consequences can be imagined. After a decade of escalating indebtedness and suicides, and the deliberate elimination of low priced non Bt seeds from the market, Bt cotton has been declared definitely unfit in rain-fed Vidharba by the Maharashtra Ministry of Agriculture. How was Bt cotton approved for rain-fed regions by the Regulators? Responsibility must be fixed for the extreme farmer distress that has followed and the record number of farmer suicides in Vidharba, because the link with Bt cotton is undeniable. This is stated and emphasised given the background that the only Biosafety Dossier prepared till date is of Bt brinjal and that has been comprehensively critiqued in several of its aspects and found to be fraudulent. The essential risk assessment protocols and key testing were not done, but were only claimed to have been done. As a result, open field trials of all crops are now clearly unsafe and contravene the EPA. In addition, surely you must also consider the reasons for the Bt brinjal moratorium and their implications for bio-safety, including the need for stringent, independent testing.
On what basis therefore, is the GEAC deciding to woo State Governments to their point of view? Given their own culpability in approving unsafe open field trials, which are also routinely in breach of biosafety rules, lacking elementary precaution leave alone rigour and oversight, it is ironic that the reasons being put forward for such an approach to State governments is their “lack of awareness on highly technical issues associated with biotechnology and biosafety measures.” Apart from being surprisingly condescending, it has to be said that on the contrary, that the States that have thus far imposed bans have done so acknowledging the uncertainties of GE technology and arising directly from this uncertainty, they thus also recognise the pivotal importance of the precautionary principle enshrined in India’s constitution and upheld in law. There is no gainsaying the fact that GMOs are a powerful, novel and unproven technology, which was commercialised a mere 20 years ago and whose impacts are irreversible. State governments are demonstrating a remarkable acuity of judgment and farsightedness in order to protect their crops and still rich seed diversity in the national interest, in marked contrast to the breach of these principles and the caution and precaution that are obligatory requirements in the apex Regulator.
With regard to the RCGM, it has to be said that this regulatory body that is essentially instructed by the DBT (in the Ministry of Science and Technology) has exhibited an appalling mind-set over the years as a blatant vendor of GM crops and has gone so far as to foster and openly promote PPP (public-private- partnerships) between our public sector agri institutions (supported by the ICAR), and the biotech Industry. By agreeing to such agreements, the former have comprehensively abandoned their mandate to India’s farmers. Their recommendation to cancel the requirement for NOCs is a serious error of judgment and self-revealing. Given that agriculture is a State subject, the decision to require NOCs by the former MoEF Shri Jairam Ramesh was in reality a formality, but a well judged and directed instruction to the GEAC. We would urge you to uphold this principle, which will send the right message of support from the Centre to State governments in their exemplary action on barring field trials.
We therefore, respectfully urge you to bar any move by the GEAC to promote field trials in various States, by mounting what would be tantamount to a road-show on behalf of Monsanto and the Industry. In the year that India is hosting the CBD, this would be a comprehensively wrong message to send out. On the other hand, we further request that the GEAC in a principled initiative halts all field trials given the current situation where a host of bio-safety issues remain unresolved.
With best wishes
Coalition for a GM-Free India
email : firstname.lastname@example.org
Ph : 09995358205
Ms Sonia Gandhi, Chairperson, National Advisory Council, New Delhi
Sri Basudeb Acharya MP, Chairperson, Parliamentary Standing Committee, Agriculture
Sri M F Farooqui, Chairman, GEAC
Prof M S Swaminathan ( Special Invitee in GEAC as per Supreme Court Order)
Prof Pushpa M Bharghava ( Special Invitee in GEAC as per Supreme Court Order )
Chief Ministers of all States.
Agriculture Ministers of all States