Shri Arun Kumar Mehta,


Genetic Engineering Appraisal Committee (GEAC),

Ministry for Environment, Forest & Climate Change,

Indira Paryavaran Bhawan, Jor Bagh,

New Delhi – 110001

November 14th, 2018

Subject: Our objections against GEAC’s decisions on GM mustard and Bt brinjal in its 136th meeting

Dear Sir,

Namaste. We in the Coalition for a GM-Free India got to see the minutes uploaded on the website of the Ministry, of the 136th meeting of GEAC held on September 20th 2018, and are writing to express our objections and concerns on some of the decisions taken in this meeting.

  1. GM Mustard Trials: Trials are being recommended on an area of 5 acres each (albeit with non-GM mustard plots also included), which is essentially “creeping commercialisation”, and a clear strategy to present citizens with a  fait accompli. This is being done even though many unanswered concerns remain with regard to GM mustard, which is a herbicide tolerant crop. What is also objectionable is that these are supposed to be “field demonstration studies” – it is unclear what this new kind of field trial is, that GEAC has come up with. Why should impact assessment be a ‘demonstration’ by the crop developer?

Open air field trials are deliberate releases of GMOs into the environment. There are several risks associated with such releases, pertaining to both biological contamination as well as deliberate leakage of seeds. There are numerous instances of such contamination from around the world (including the one for GM rice in US, as a result of a single field trial, which led to export losses of hundreds of millions of dollars; and rice is a closed pollinating crop), as well as in India. Such open ‘field demonstrations’ as are being planned for GM mustard clearly seem to be a deliberate attempt to cause contamination and leak GM mustard seeds. This is completely unacceptable and an unconscionable act on the part of the GEAC. Because the ‘field demonstrations’ are being done on such a large scale, contamination will be virtually certain. Given that our complaint on field trial violations in Bathinda with photographic evidence was not even acknowledged by GEAC, leave aside addressing it, our concerns are justified. Earlier instances  where GEAC demonstrated a carefree attitude to monitoring contamination and field trials have been described here –

  1. Trials without state government’s prior informed consent: In the GEAC’s 136th meeting minutes, it is clearly recorded that the regulatory body is encouraging the applicant to “suitably inform” the state governments of Delhi and Punjab, rather than seek an NOC, for conducting “field demonstration studies” (on the grounds that the earlier NOC of 2015 should suffice), which is a wrong measure from the regulator.  They are doing so knowing fully well that the Delhi government had written to the Centre expressing its concerns about GM mustard, and that there is now a new government in Punjab.

This is shocking as it violates the regulatory norm of getting a No Objection Certificate from a state government, especially given that more evidence exists now of the lack of safety of GM mustard than was the case in 2015. The GEAC by changing its stance from ‘seeking appraisal’ of the state governments on GM field demonstration studies to ‘informing’ is acting as a promoter for GM mustard illegally making it obligatory for states to undertake trial and therefore make room for commercialisation when in fact agriculture is a state subject. It is clear this is being done since state governments are opposed to GM mustard and other GM crops.

  1. GEAC’s unscientific and narrow impact assessment: While the GEAC mentions in its minutes about earlier trials because of which studies on soil micro-flora are being exempted now – what it does not mention is that there has been a failure to produce the full GM mustard biosafety dossier in the public domain and to take up independent scientific scrutiny. It is such independent scrutiny that led to serious flaws being recognised in the approval of Bt cotton and Bt brinjal. Due to such independent analysis, it is clear now that GEAC ignored negative impacts on health of animals consuming Bt cotton & Bt brinjal which could be observed from promoter’s own data; several other similar irregularities were highlighted in Supreme Court Technical Expert Committee report.

GEAC deciding to ask the crop developer to take up one or two additional tests (which it had already recommended in any case), while it was asked by the MoEFCC to do a review of its earlier decision is unacceptable. Even here, between the earlier meeting and this meeting, one more study has been dropped which shows how ad-hoc the assessment of GEAC is.

The testing of GM mustard has clearly been inadequate and data from the limited testing shows that GM mustard is neither effective nor safe. GEAC’s assessment has not been accompanied by a Needs and Alternatives Assessment which needs to be an immediate step rather than going with the flawed demonstration trials. This is worrisome as GM mustard is a herbicide tolerant crop and there is evidence of the toxicity of glufosinate. Our detailed response on how GEAC is neglecting critical concerns around GM mustard and how its so-called review process of the GM mustard clearance it gave in 2017 is farcical and facetious is available here: . GEAC is once again showing that they do not assess biosafety thoroughly, under the influence of the crop developers/applicants. By first approving and now giving a go-ahead for field demonstrations, GEAC is once again making its incapability of being a proper regulator of GM crops evident.

It has been acknowledged by the respondents in their Supreme Court Affidavit, that Herbicide Tolerant hybrid DMH 11 is not a superior hybrid-making GMO technology that outperforms Non-GMO hybrid-making technologies. Given this admission, there is no justification for DMH 11. Higher yields in (Non-GMO) mustard varieties are also demonstrated in well- tested trials (over several years by the DRMR).  Therefore, the further claim that DMH 11 will reduce imports of edible oil-seed of Rs 16,000 crores/annum defies all semblance of logic. It is shocking the extent to which the GEAC is willing to go, and quite brazenly, to push this GM mustard. Please scrap HT hybrid DMH 11 immediately.

Given all the above, we demand that GEAC stop any further processing of the GM mustard commercialisation application.

  1. On Bt brinjal: In this 136th meeting, GEAC also took up the “request” made by Mahyco, to consider large scale environmental release / demonstration of Bt brinjal by Mahyco. Once again, what is “large scale environmental release”, or “demonstration” or “request” in the context of thorough impact assessment which is the responsibility of an appraisal committee? It is seen that while the crop developer is requesting permission for large scale environmental release, the GEAC, acting as a promoter that is keen to approve GM crops more than the crop developer itself, is writing to the Secretary-DARE to “direct IIHR” to undertake independent scientific study of Bt brinjal in Bangladesh! Numerous well known independent scientists had analysed the biosafety data of Bt brinjal which led to the indefinite moratorium placed on this GM food crop by Government of India in February 2010. In all these years, not a single additional test has been undertaken by Mahyco to prove the biosafety of Bt brinjal after the lack of safety had been exposed in 2009.

We are also attaching as an annexure extracts from the analysis of Bt brinjal dossier by the Supreme Court TEC as well as several independent scientists, as a ready reminder to GEAC.

The Government of India’s moratorium decision note, as articulated by the then Environment Minister, recorded that the moratorium will last “till such time independent scientific studies establish, to the satisfaction of both the public and professionals, the safety of the product from the point of view of its long-term impact on human health and environment, including the rich genetic wealth existing in brinjal in our country. A moratorium implies rejection of this particular case of release for the time being; it does not, in any way, mean conditional acceptance. This should be clearly understood.” No long-term studies on human health and environment have been conducted nor can they be conducted from Bangladesh’s costly irreversible experiment. In fact, Bangladesh has flouted its own condition of asking for compulsory labelling, and has landed itself in the same position as other GM-hasty countries, where post-release monitoring and studies are very challenging now. We object to GEAC relying on Bangladesh’s shoddy (even worse than India’s) regulatory system for GM crops which itself approved Mahyco’s flawed Bt brinjal based on a dossier of tests done in India and not Bangladesh!

GEAC should also learn from the Bt cotton experience in India, which gives ample evidence of post commercial release effects of Bt crops, ( where it is now evident on record that it has been a big failure leading to –

  • Increase in use of fertilizers and pesticides

  • Reduction in farmer income and increase in cost to farmers

  • Stagnation in yields

Given all the above, we urge GEAC not to act as a promoter of GM technology, and not to continue with its regulatory mis-adventures. We demand that GEAC scrap the Bt brinjal dossier completely and not entertain any more correspondence on the same from Mahyco.


Kavitha Kuruganti,

Coalition for a GM-Free India

Phone: +91-8880067772

Address – # 302, Santhome Apartments, 33/1, 1st A Cross, Indiranagar I

Stage, Bangalore 560 038 


 GEAC 136th meeting response

Several analyses are present at : and