Complaint regarding coercion of state govts for No Objection Certificates for field Trials ; HTBt cotton environmental release and notified field trial sites (Decisions taken in GEAC’s 149th meeting)

from: GM Free India <>
Abhilasha Singh Mathuriya <>,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
date: 6 Jun 2023, 10:00
subject: Complaint regarding coercion of state govts for No Objection Certificates for field Trials ; HTBt cotton environmental release and notified field trial sites (Decisions taken in GEAC’s 149th meeting)


Shri Bhupender Yadav,

Hon’ble Minister for Environment, Forest & Climate Change,

Government of India.


Sub: Decisions in the 149th meeting of GEAC – Coercion of state governments for NOCs for field trials – Bollgard II Roundup Ready Flex cotton environmental release – Notified Field Trial Sites in 42 different locations across states – reg.


Dear Sir,


We write to you to draw your urgent attention to three important matters pertaining to gene technologies in our food systems, on which the regulatory body GEAC is moving ahead, without some basic issues being addressed.


  1. Coercion of State Governments for NOCs for field trials – Over the years, the GEAC has tried very hard to dismantle a system that is part of the regulatory regime in India – that of getting No Objection Certificates before field trials take place. In fact, NOCs logically should be extended to testing after “environmental release” too, as in the case of GM HT mustard. Without this NOC system and in the absence of commercial seed sales with licensing kicking in, state governments are being bypassed in the case of GM mustard planting.


In various meetings, GEAC has already recorded in its Minutes that Agriculture is a State Subject, and state governments’ involvement is essential for compliance monitoring and therefore, the NOC system has to be followed. However, it is also seen that attempts have been made by re-visiting the NOC system multiple times, under pressure from the biotech industry. Event Selection Trials have been exempted from the NOC system already. Even in the case of numerous state governments which have already announced explicitly in some policy or the other that they are against GM crop field trials, GEAC continues to approve trials – the applicant is asked to obtain NOC and come back for a formal permission letter. It is unclear why GEAC should provide approvals in the first instance when state governments have clearly taken a policy decision not to allow deliberate release of any kind of GMOs in their states.


In the latest instance, we find that in the 149th meeting of GEAC which took place on 17th May 2023, when state governments like Telangana and Gujarat have declined to provide NOCs, GEAC is forcing them to provide reasons or break their silence. Why should a statutory regulator be pressurising state governments in this manner? It has also been recorded that some activities will be taken up with state governments “to enable informed decision-making by state governments”. This is a biased lobbying approach that a supposedly-neutral regulatory body is taking up. This is not the mandate of the GEAC and it is highly objectionable that such decisions are being taken, to pressurise state governments. We demand that GEAC should stop coercing state governments, and demean the capabilities within the states.


  1. “Notified Field Trial Sites” in 42 locations across India – DBT and ICAR have been recorded to have come up with 42 different locations as Notified Field Trial Sites, and once again it is being minuted that state governments’ views and comments will not be sought if the proposed trial is at a NFTS. This is a dangerous proposal. The Sopory Committee which looked into Bikaneri Bt cotton contamination inferred that  Monsanto’s proprietary genetic material may have gotten into Bikaneri cotton in an agricultural university. Moreover, such institutes are usually the locations where gene banks are maintained. Importantly, why should trials in NFTS not have NOC for each season and why should this system be bypassed, or why should a proposal for a one-time clearance for 5 years be obtained from the state government? In a country where field trial locations have already proven to be leakage sites for unapproved seeds, why is the statutory regulatory body trying to bypass state governments and looking for hasty ways to taking up trials? While the ICAR might have a financial interest in earning revenue by doing trials for the biotech industry even at the expense of public interest, why is the regulator GEAC falling in line?


  1. Roundup Ready Flex Cotton: We have noted the progress that Mahyco’s RRF Cotton is making inexorably towards commercial cultivation approval from the regulators. It is strange that the regulatory regime allows for voluntary withdrawal of dossiers and re-submission again after some years by the applicants. We are aware of the fact that GEAC constituted a Sub-Committee under Dr Sanjay Kumar Mishra in July 2022 in its 145th meeting. We have also noted that this Sub-Committee gave its report in December 2022. We have further noted that this report is not in the public domain on the GEAC website, unsurprisingly.


  1. The Supreme Court-appointed committee of independent technical experts has recommended a ban on any HT crops for India. Several other high level official committees have also made a similar recommendation as GEAC is well-aware. The Supreme Court is looking into this matter, as you know.
  2. There is more scientific evidence on the adverse impacts of Glyphosate now than ever before/than 2008 when the first BRL-1 trials took place of this RRF cotton. Bayer-Monsanto have had to pay out billions of dollars to affected litigants in the USA as you are well aware. More than two lakh citizens have asked the Government of India to ban Glyphosate in the country. These issues are also part of Supreme Court litigation, as you might be aware.
  3. The overall failure of GM cotton in India is also well-documented, and the published articles (attached here) of cotton experts like Dr Keshav Kranthi can be cited in support of the fact that overall chemical usage has increased in cotton cultivation in India, while yields have stagnated. Losses by cotton farmers due to pest infestation and due to resistant target pests is something that farmers and state governments are contending with, season after season.
  4. The Indian statutory regulatory regime does not even have guidelines and protocols for testing of HT crops.
  5. On the other hand, legally, GEAC is not empowered to set up Sub-Committees for regulatory decision-making.
  6. There are no liability and redressal regimes that are in place in the Indian regulatory regime, and the EPA liability regime is not something that is meaningful in the context of adverse impacts from GM crops in general and HT crops in particular.
  7. We are also familiar with the biotech industry strategy of illegally introducing GMOs such as RRF cotton first and then getting approval later after a fait accompli is delivered. We strongly object to the lack of regulatory action and capabilities on this front. For years we have been asking GEAC to take strong action to tackle HT cotton, which were not addressed.


In such a situation, to just decide that the crop developer should revise their dossier and re-submit the same is not a pro-citizen decision at all. We object strongly to the GEAC and Government of India proceeding forward towards approval of environmental release and commercial cultivation of Herbicide Tolerant cotton.





Kavitha Kuruganti for Coalition for a GM-Free India


Residence:# 302, Santhome Apartments, 33/1, 1st A Cross, Indiranagar I Stage, Bangalore 560 038
Phone: +91-8880067772


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  1. Hon’ble Chief Ministers in states/UTs in India
  2. GEAC Secretariat

Coalition for a GM-free India 

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