To:

Sh. Gurmeet Singh Khudian,

Hon’ble Minister for Agriculture,

Government of Punjab.

Dear Sir,

Greetings! From the Minutes of the 155th Meeting of the Genetic Engineering Appraisal Committee (dated 9th June 2025) available online (http://geacindia.gov.in/Uploads/MoMPublished/MoMPublishedOn20250626171230.pdf), it is apparent that Bayer, a notorious MNC known for its toxic products, has obtained a No Objection Certificate from Punjab Government for GM maize trials. This letter is to express our serious objections to the same.

1. ONLY PAU/PUNJAB GOVT ISSUED NOC FROM 11 STATES APPLIED – HOW & ON WHAT BASIS:

While Bayer (earlier, Monsanto) applied for penultimate stage trials for HT Maize (Event called NK603) and insect tolerant Bt Maize (Event called Event MON8903) in multiple locations of eleven states including Haryana, Gujarat, Telangana, Andhra Pradesh, Rajasthan, Maharashtra, Madhya Pradesh, Bihar and Tamil Nadu), PAU Ludhiana is the only one which seemed to have responded positively. Against this backdrop, Punjab Govt/PAU have to show what is the additional safety information that they hold than any other state which makes the Punjab State Government give NOCs. Government of Punjab reportedly issued NOCs vide letter dated 29.05.2025, as per GEAC’s 155th meeting minutes (9/6/2025).

2. CONFINED FIELD TRIALS’ VIOLATIONS CAUGHT WITH PHOTOGRAPHIC EVIDENCE IN PAU TRIAL IN THE PAST

PAU’s track record on conducting “confined” field trials in compliance of the statutory guidelines meant for such trials is poor. In the past, civil society groups have shown with photographic evidence such violations, with regard to HT Mustard trial, for example. (https://indiagminfo.org/coalition-letter-urging-geac-to-take-action-on-serious-biosafety-violations/). No action had been taken to fix liability for such violations, however.

3. PUNJAB GOVT. HAD ISSUED ORDERS PROHIBITING GLYPHOSATE USAGE

Glyphosate is a deadly herbicide with a large body of scientific literature pointing to its negative impacts on human health and environment (a 2021 paper authored by Indian scientists from a public sector institute is available here: https://www.sciencedirect.com/science/article/pii/S2667010021001281#cebibl1). In fact, Punjab government had issued prohibitory orders on the use of glyphosate in the state, given that the Union Government was not acting in the interests of ordinary citizens. If such is the case, how can PAU experiment with herbicide-tolerant maize that has been modified to withstand the application of glyphosate, which is in itself against the legally-approved label claim for glyphosate in India’s pesticides regulatory regime?

4. PUNJAB IS ALREADY REELING UNDER A MAJOR ENVIRONMENTAL HEALTH CRISIS – HT CROPS WILL BE THE LAST STRAW

Punjab, more than any other state, has to be extremely cautious about hazardous technologies like HT and Bt GM technologies, given that they actually increase the usage of deadly agro-chemicals which impact both farmers and consumers. Given the acute environmental health crisis in Punjab, any use of more chemicals will be disastrous for the state. In such a situation, why should Govt of Punjab be issuing an NOC for a notorious MNC like Bayer / Monsanto to do trials in the state agriculture university?

5. IS THIS A DECISION OF THE POLITICAL LEADERSHIP, OR OF SOME BUREAUCRAT?

In the case of GM HT Mustard, in a seminar organised by the Hon’ble Speaker of the Punjab Legislative Assembly on 16th January 2023, it became clear that the PAU Vice Chancellor had not even sought the permission of the state government when he took up GM mustard cultivation for trials in the campus of the university. It needs to be ascertained whether the NOC has been issued by the state government with the full knowledge of the political leadership in the state or not.

This one NOC of Punjab Govt will cause a national repercussion now, given that the results from just one or two locations will be shown for an application by Bayer for commercial cultivation permission to these unsafe GM crops, as has happened in the past with HT mustard. Moreover, field trials themselves are a potential hazard because even though they are called “confined”, contamination from field trials has been documented again and again.

The matter of herbicide tolerant crops in India is sub-judice in the case of GM HT Mustard, and is pending the implementation of Hon’ble Supreme Court’s July 2024 orders in the case of other crops. In such a situation, Punjab government going headlong into GM maize trials is anti-people and anti-Nature. 

Sincerely,

Kavitha Kuruganti

Co-Convenor,

Coalition for a GM-Free India

Ph: 8880067772