In a prayer meeting followed by pledge-taking at Rajghat, many organisations and individuals joined hands to launch Sarson Satyagraha against the entry of GM mustard in India, on July 31st 2015. The following is their letter to Prakash Javadekar, MoEFCC.

July 31, 2015

To:

Mr. Prakash Javadekar

Minister for Environment, Forests & Climate Change,

Government of India.

Dear Sir:

Re: Genetically Modified (GM) mustard of Delhi University – halt the R&D and further progress immediately – reg.

We have learnt from various media reports that Genetically Modified (GM) mustard developed by the Delhi University has completed Biosafety Research Level (BRL-II) trials recently and that the developers are now seeking to apply for permission for commercial cultivation. We have been able to gather information only indirectly about this GM mustard, as no data has been made available in the public domain. RTI queries are being refused/stonewalled.  This demonstrates intent by the regulators and the Ministry to hide biosafety data. This action is in violation of the both the Constitution and the Supreme Court order that all biosafety data including dossiers be made public.

We write to you to share our deep disquiet and serious concern about this GM crop (a detailed Briefing Paper is attached). While we are raising issues pertaining to GM mustard in particular, that disquiet also includes large-scale field trials of GM corn and the general secrecy shrouding regulation of GMOs in India.

As you are aware, GM crops are a highly contested and controversial technology. It is imprecise, unpredictable, irreversible and unsafe. There is no consensus on the biosafety of GM crops. There is ever-emerging evidence to show various adverse impacts from GMOs in our environment. While studies funded by the biotech industry may show no problems, many peer reviewed independent scientific studies have raised significant issues of safety. In India the regulators rely only on self -assessment by the crop developer. This is scientifically unacceptable.

A moratorium was imposed on Bt brinjal in 2010, based in part on the fact that scientific appraisals by independent scientists of the dossier of Mahyco-Monsanto found significant biosafety flaws and even cover-up.  The moratorium was endorsed by your party. In addition, your party had promised in its election manifesto that GM crop technology will not be used in the country without extensive research and independent evaluation.

However, events in the past one year surrounding field trial approvals of GM crops and processes (or lack thereof)  followed by the GEAC has given room for considerable disquiet  among concerned citizens, scientists, farmers and other segments in society.

GM mustard is a genetically modified hybrid mustard (Brassica juncea) (DMH 11).  It contains alien genes like the bar gene, which is the trait for herbicide tolerance and functions as a marker gene, and the barstar, barnase complex which is a GURT (Genetic Use Restriction Technology) i.e. male sterility and restorer genes respectively.

The claim of the promoters is that the GM mustard will increase yields by 25-30%.  This is untrue as there is no event in it to improve yield; the yield is due to the hybrid trait. Similar false claims were made in the case of Bt cotton too, and after 13 years of its commercial cultivation in India, we know the reality of Bt cotton not even decreasing the use of pesticides in cotton cultivation.

What the promoters of GM mustard are also silent on is that yield increase is possible through non-GM hybrids already in the market, or more importantly, through agro-ecological innovations like “System of Mustard Intensification”. What is unscientific is that GM mustard has not been tested against such alternatives, but only against a national check like Varuna. This GMO is essentially to facilitate seed production by seed companies. This technology is not for the farmer, the consumer or the nation.

The bar gene which confers herbicide resistance, also used as a marker gene, makes this GMO a herbicide tolerant (HT) crop. This is being obscured by the crop developer, ostensibly because agency after agency/Committee in India has recommended a ban on HT crops in the country; this aspect should not be overlooked by the regulator. It is unclear how this GMO has reached this stage of R&D without this aspect being addressed.

HT crops have been proven to be an unsustainable agri-technology. The empirical evidence is clear: no yield gains, numerous resistant super weeds on huge swathes of agricultural lands where these are grown (Canada, the US and Argentina for example), huge increases in use of herbicides and many adverse health impacts.

This HT crop will leave its adverse impacts on insect pollinators like honeybee as scientific evidence from elsewhere shows. This could have devastating consequences for Indian agriculture in general, in addition to affecting mustard growers. The decrease in honey bees in GM mustard will itself lead to decrease in yields, thereby negating the “claimed” advantage of this crop.

India is the centre of diversity for Indian mustard and to opt for GM technology in crops for which we are the Centre of Origin and/or Diversity is a misadventure that India should not undertake. The Technical Expert Committee (TEC) of the Supreme Court, the Parliament Standing Committee (PSC) on Agriculture and the Swaminathan Task Force on Application of Agricultural Biotechnology have strongly and unequivocally recommended that GM research or commercialisation should not be allowed in crops for which India is  the Centre of Origin/Diversity.

Therefore, this event invites a bar on three grounds, which no regulator may overlook:

1.      Mustard DMH 11 is a GURT and barred from seed registration under the Indian PPVFRA.

2.      India is a centre of origin/diversity of mustard. Contamination from GM mustard is inevitable. GM crops in centres of origin or diversity have been barred by the TEC/PSC and the Swaminathan Task Force.

3.      The SC-appointed TEC has recommended a ban on HT crops. The concerns with HT crops are shared by the Swaminathan Task Force too.

Mustard is not only an oilseed but an important edible food crop in India – therefore it has to be treated as such and all tests carried out for its use as a direct vegetable crop. It also has considerable use in Ayurveda, and this was one of the reasons why Bt brinjal was placed under an indefinite moratorium. Mustard oil has deep cultural significance for the people of north, north western and north eastern India. It is used extensively in home remedies and for infants and the ailing.

We are not aware of any biosafety studies that have been conducted, which addresses all these issues, including the implications of the certain contamination of all our diverse varieties and wild species. Indeed these should already have been carried out before large-scale field trials were conducted, put in the public domain, open for healthy debate. More importantly, policy directives given by various committees some of which have been accepted by the government are being flouted again and again in regulatory decision-making. While this is bad enough, we also find that biosafety conditions for trials are unscientific and violations left unaddressed without any liability fixed on the crop developers or regulators for such violations.  The latest such violation from the field trial of GM mustard in Bathinda, Punjab, was documented and sent to the GEAC vide letter dated 16th June, 2015 (http://indiagminfo.org/?p=870 ), without any response as usual.

States like Rajasthan and Madhya Pradesh, where majority of mustard is grown in the country, and the state of West Bengal, which accounts for almost 50% of consumption of mustard oil, said no even to field trials in the past. This puts an added question mark as to how approval was given for these trials.

Keeping in view the various scientific, technical, regulatory, socio-cultural issues, and the fact that the need for this GM mustard has not been established, we urge you to immediately step in and halt any further processing of the GM mustard application. This is an application that should have been rejected long ago. In addition, we urge you to ensure:

• Transparency in the GM regulatory system and processes, starting with making public all data on this GM mustard and other crops under advanced stages of field trials.
• Independent investigation into possible contamination from the trial sites (recently, evidence was provided to the regulators on the violations of biosafety conditions imposed for open air field trials) and action against the developer and the regulator for regulatory lapses leading to contamination of our seed and food supply.

We look forward to a positive response in the national interest.

Sincerely,

On behalf of Sarson Satyagraha,

Kavitha Kuruganti – +91 9393001550

Umendra Dutt – +91 9872682161

Vijay Pratap – +91 99107 70263

 

CC: Shri Narendra Modi, Prime Minister, Government of India.

Attachment: Briefing paper on GM mustard of Delhi University

 

Sd/-:

1. Padma Bhushan Dr Pushpa Bhargava
2. Padma Bhushan Dr Inderjit Kaur
3. Padma Bhushan Shri Ghulam Sheikh
4. Padma Shri Dr Daljit Singh
5. Padma Shri Rambahadur Rai, Senior Journalist
6. Padma Shri Dr Norma Alvares, environmental lawyer
7. Padma Shri Janak Palta McGilligan, Indore, Madhya Pradesh
8. Padma Shri B Sugathakumari, Poet, Writer and Social Activist
9. Padma Shri G Sankar, Architect, Habitat Technology Group
10. Rajinder Singh, Magsaysay awardee
11. Rashida Bee and Champadevi Shukla, Goldman Prize winners, Bhopal
12. PV Rajagopal, Ekta Parishad
13. Anupam Mishra, Gandhi Peace Foundation
14. Surendra Koulagi, Freedom Fighter, Jamnalal Bajaj awardee, Melkote, Karnataka
15. Laxman Singh, Indira Priyadarshini awardee, Rajasthan
16. Justice (retd) K Chandru, Chennai
17. Dr Devinder Sharma, Author and Agriculture Policy Analyst
18. Dr Vandana Shiva, Environmental activist
19. Dr Arun Kumar, Economist, Jawaharlal Nehru University
20. Dr Atul Mehta, Plant Breeder and Cytogeneticist, AAU, Anand
21. Dr Mira Shiva, Health activist, Delhi
22. Dr Sudhirendar Sharma, Ecologist, Delhi
23. Dr Claude Alvares, Goa Foundation
24. Dr Debal Deb, Ecologist, Centre for Inter Disciplinary Studies
25. Dr Ponnammal Natarajan, (retd) Dean, Anna University
26. Dr Sudarshan Iyengar, Economist, Former Vice Chancellor, Gujarat Vidyapith, Ahmedabad
27. Dr Minoo Parabiya, formerly Head of Bio Sciences Dept, South Gujarat University, Surat
28. Dr K R Natarajan, Retd. Professor of Biochemistry, AU, TN
29. Dr A R Vasavi, Former Senior Fellow, Nehru Memorial Library; Infosys Award Winner
30. Prof M K Prasad, Pro VC (Retd), Calicut University
31. Dr V S Vijayan, Chairperson, Salim Ali Foundation and Former Chairperson, Kerala State Biodiversity Board; Founder Director SACON (a Centre of Excellence of GoI)
32. Sanjay Parekh, Senior Advocate
33. Basavaraj Patil, Rashtriya Swabhiman Andolan
34. Vijay Pratap, SADED, Delhi
35. Sarvadaman Patel, President, Organic Farming Association of India
36. Vimal bhai, Matu Jan Sanghathan, Uttarakhand
37. Shalini Bhutani, Campaign for Conservation of Biodiversity
38. Prabhakar Kelkar, Bhartiya Kisan Sangh
39. Hemant Goswami, social activist, Chandigarh
40. Tha. Vellaiyan, President, Tamil Nadu Traders Federations’ Association
41. Nandita Das, Award winning actress
42. Rabbi Shergill, well known Singer
43. Kapil Shah, Jatan Trust, Gujarat
44. Ananthoo, Safe Food Alliance, Chennai
45. Abhishek Joshi, Rural Ecology Policy Analyst
46. Umendra Dutt, Kheti Virasat Mission, Punjab
47. Rachna Arora, Public Awareness on GM Foods
48. Sachidanand Bharati, Environmentalist, Garhwal
49. Kanchi Kohli, Campaign for Conservation of Biodiversity
50. Krupakara Senani – Wild life photographer and documentary film maker
51. G.S. Jayadev, Social Worker, Chamarajanagar
52. Prasanna, Desi, Karnataka
53. Prof. Siddaramaiah SG, Poet and Former Chairperson, Kannada Book Academy
54. Nagesh Hegade, Senior Journalist and Environmentalist
55. Manas Arvind, Clean Food Activist
56. Ritu Mathur, Organic Farming Consultant