Urgent MoEFCC intervention demanded to stop illegal entry of Bt brinjal from Bangladesh

To:                                                                                                           December 2nd 2014

Shri Prakash Javadekar,

Hon’ble Minister for Environment, Forests and Climate Change,

Government of India.

Dear Sir,

Sub: Immediate intervention sought from your Ministry on illegal transboundary entry of Bt brinjal into India from Bangladesh – reg.

Namaste! This is to bring to your kind attention fresh concerns with GMOs and threat to our food, farming and environment from them. The latest threat originates from the reported smuggling of Bt Brinjal into India from its cultivation in farmers’ fields in Bangladesh (Ref.: http://www.hindustantimes.com/india-news/after-terror-bangladesh-sends-bt-seeds-into-india/article1-1284368.aspx).

The appraisal of Bt brinjal in India, both the process undertaken by the erstwhile Minister of the MoEF, Shri Jairam Ramesh which included public consultations, as well as the scientific risk assessment of Bt brinjal, fulfilled the CBD requirements and compliance process under the CPB (Cartagena Protocol on Biosafety to which both India and Bangladesh are signatories). Furthermore, the hard scientific risk assessment of the raw data of Bt brinjal was carried out by leading, independent international scientists in GMO risk assessment whose work is well-published in the scientific literature. They included eminent scientists who have informed the CBD process of GMO risk assessment and continue to do so. The Bt brinjal bio-safety dossier, a self-assessed undertaking by Mahyco-Monsanto was found to be fraudulent in that studies claimed to have been done were not done, and conclusions of safety drawn unfounded. It was also a cover-up with significant gaps in analyses and risk assessment protocols. Perhaps more worryingly, it demonstrated without doubt, an on-going incapability and /or unwillingness on the part of our own regulators to scrutinise with rigour and impartiality the bio-safety of Bt brinjal.

The approval of the Bt brinjal dossier and the fact that it continues to remain unjustifiably on the Indian regulatory record despite the indefinite moratorium imposed by Jairam Ramesh, constitutes a major flaw in the Indian process of the regulation and risk assessment of GMOs. It has consequently contributed in no small measure to the subsequent approval of Bt brinjal in Bangladesh, in that it allowed Mahyco-Monsanto to pursue their dark objectives for the commercialisation of Bt brinjal in the sub-continent and through a country with little bio-safety experience, using the Indian regulatory approval as a justification and launching platform.  Bt brinjal is unsafe and will not benefit the people and farmers of Bangladesh. It will also contaminate wild and native varieties in the region including India, because of porous borders, that is the centre of origin/domestication of Brinjal.

Bt Brinjal provides a fitting case of non-compliance under the CPB and reason to be brought to the notice of its Compliance Committee pointing out where Bangladesh has failed to meet its obligations under the Protocol and the threat that it represents to India. The main points are:

  • Article 17 of the Cartagena Protocol on Biosafety requires Parties to prevent or minimize the risks of unintentional transboundary movements of genetically engineered organisms. The current trend of an increasing spread of these organisms outside of the managed settings for which they were approved threatens to enhance the potential for unintentional transboundary movements.
  • There is a risk that we will not be able to recover the original biodiversity, as the dynamics of wild and cultivated native varieties will be altered. We cannot rely solely on gene banks, as they are able to preserve only a very small percentage of the genetic diversity present within centres of origin and of genetic diversity.
  • From a regulatory point of view, spatio-temporal control of genetically engineered organisms is necessary. It is a fundamental precondition for any risk assessment because no reliable predictions can be made concerning the consequences of artificially transformed organisms once they are released or escape into wider environments and become part of open-ended evolutionary processes.
  • Finally, the precautionary principle can only be implemented if genetically engineered organisms can be retrieved from the environment in case of emergency. This becomes impossible once transgenes move and accumulate in wild and landrace varieties as they will do in India, which has the greatest brinjal germplasm in the world and because this is now reportedly a commercialised crop in Bangladesh.

It is clear that Bt brinjal seeds from Bangladesh will enter India illegally through porous borders as well as deliberate acts of mischief. We are deeply concerned that for India this will represent an extremely serious biosecurity threat on several dimensions related to brinjal bio-safety: the threat to India’s brinjal foundational seed stock and therefore, seed security, the health threat through brinjal varieties becoming toxic without remedy, and the threat to small-scale farming, farmer security and inability to have access to safe seed. It is not an overstatement to express the potential fallout of the commercialisation of Bt brinjal in Bangladesh as a form of agri-bio-terrorism over which we will have no control.

This Bt brinjal in Bangladesh is the same Genetically Modified brinjal developed by Monsanto and Mahyco with a modified bacterial chimeric toxin gene in it, which was rejected in our country by the Government of India. After the failure of getting this risky Bt Brinjal released in India, Monsanto-Mahyco and their American collaborators have tried to push this in the Philippines. However, a Court verdict there has put a stop to open air field trials of Bt brinjal there. Since then, the attention of the GM industry has shifted to Bangladesh. Media reports indicate that the commercial approval for Bt brinjal in Bangladesh has been hasty, with no fresh evidence of safety after lack of safety has been shown in India, and has failed farmers who tried it out massively in the first season. All this has led to a growing opposition to Bt Brinjal in Bangladesh.

While public opposition to Bt Brinjal is building up in Bangladesh it is also essential that India as a neighbouring country, as the Centre of Origin and Diversity of Brinjal with Eastern India showing a wealth of such diversity to this day, should safeguard our seed and food supply chains in addition to our diversity from possible transboundary transfer of this Genetically Modified crop. You would also recall that Bt cotton has made its entry into India first through illegal proliferation and the GM industry is known to have deployed this strategy of contamination to get faster approvals, in the past. This is the context in which we believe that the Indian government has to now take swift action.

One of the main factors that compelled the Government of India take a decision to put commercial release of Bt Brinjal was the fact that we are a centre of origin and diversity of Brinjal and that a rich diversity exists to this day in cultivation, in farmers’ fields. The Convention on Biological Diversity (CBD) to which both India and Bangladesh are parties to, recommends that all measures should be put in place to protect centres of origin and diversity of crops. The Cartegena Protocol on Biosafety, an instrument of the CBD, specifically created for safeguarding biodiversity, including human health, from either intentional or unintentional transboundary movement of Living Modified Organisms or products thereof, also highlights the need for all parties to take adequate measures to prevent any damage from this inherently risky technology.

Article 11 of the protocol requires any party that is intending to release LMOs in the domestic market which may be subject to transboundary movement, as in the case of this Bt Brinjal in Bangladesh, to inform all parties about it through the respective Biosafety Clearence House and that there shall be accuracy in the information provided. It also has a provision for other parties who might be impacted to seek further clarifications from the party who plans to place in the market (commercialise) a LMO.

Article 17 of the Protocol which addresses the concerns around unintentional transboundary movement of LMOs also requires the party, in this case Bangladesh, to inform those parties to who there is a potential threat of unintentional transboundary movement.

Given that there is an imminent threat of contamination of our food and seed supply chains as well as our agro biodiversity from the commercial release of Bt Brinjal in Bangladesh and to also prevent any development like in the case of Bt cotton way back in 2001 when its illegal proliferation could not, and would not be contained by regulators here, it is urgent that:

a. Your Ministry takes all measures to stop any illegal including unintentional transfer of Bt Brinjal or seeds of it through our borders with Bangladesh. There should be proper mechanism to implement this to immediate effect all along the India-Bangladesh borders.

b. Your Ministry ensures that India officially shares all its analysis on Bt brinjal, the basis for its moratorium decision and urges Bangladesh not to continue cultivation of this GM food crop.

c. India also explores all options at the CBP level to ensure that Bangladesh puts into place all measures and mechanisms that would ensure that our diversity here is protected from any transboundary movement of this GM food crop.

d. Since India-Bangladesh border is porous, we demand ban on import/transfer of crops, fruits, seeds/food of Brinjal and related species/genus/family which have remotest possibility of contamination directly or indirectly through Bt Brinjal.

Looking forward to your urgent action.


Rajesh Krishnan,

Convenor, Coalition for a GM-Free India



  1. Afsar Jafri, Focus on the Global South, Delhi
  2. Ajay Mahajan, Vividhara, Dehradun/Delhi
  3. Ajeet Kelkar, Organic Farming Expert, Indore, Madhya Pradesh
  4. AK Malhotra, SAI (Save Animals Initiative) Sanctuary Trust, South Kodagu District, Karnataka
  5. Ananthasayanan, Safe Food Alliance, Chennai
  6. Aneel Hegde, General Secretary, All India Shetkari Khet Mazdoor Panchayat (HMS)
  7. Anil K Singh, SANSAD, New Delhi
  8. Anjaneya A.N,  Sharana Muddanna Savayava Krushikara Sangha, Kumbalur, Karnataka
  9. Annakili, Kalanjium Unorganised Women Workers Union,,Vellore, Tamilnadu
  10. Arun, Co-ordinator, Dharmapuri Dist.Organic Farmers Association, Tamilnadu
  11. Aruna Rodrigues, Lead Petitioner in GMO PIL in the Supreme Court, Sunray Harvesters, Mhow
  12. Asha Kumari K.P, President, Honneru Balaga-Consumer Council, Mysore
  13. Ashalatha, Rythu Swarajya Vedika, Telangana and Andhra Pradesh
  14. Ashish Gupta, IFOAM Asia – Delhi and PGSOC – Goa
  15. Ashish Kothari, Kalpavriksh, Pune
  16. Balaji Shankar, Tharchaarbu Iyakkam, Tamil Nadu
  17. Bharat Mansata, Vanvadi Agro-ecological Regeneration Association, Dist Raigad, Maharashtra
  18. Beej Swaraj Abhiyan, Madhya Pradesh
  19. Chandra, Women Education and Economic Trust, Thirupattur, Tamilnadu
  20. Channabasappa Kombli, Krishi Pandit Awardee, Karnataka
  21. Chellamuthu, Uzhavar Uzhaipalar Katchi, Chennai
  22. D S Variava, Managing Trustee, The Sahayak Trust, Maharashtra
  23. D V Sreedhar, Goodnews India Foundation
  24. Dalit Adivasi Maha Panchayat, Sindhi, Madhya Pradesh
  25. Debjeet Sarangi, Living Farms, Odisha
  26. Dr Amar Singh Azad, Center for Environmental Health Research & Action, Punjab
  27. Dr Arun Dike, Indore Biotech, Indore
  28. Dr Ashok Bang and Niranjana Maru, Chetana Vikas, Wardha
  29. Dr Claude Alvares, Organic Farming Association of India (OFAI), Goa
  30. Dr Debal Deb, Centre for Inter-Disciplinary Studies, Kolkata
  31. Dr Devinder Sharma, agriculture policy analyst, Chandigarh
  32. Dr G Sivaraman, Poovulagin Nanbargal
  33. Dr G K Menon, Agriculture Scientist, Indore, Madhya Pradesh
  34. Dr G P I Singh, Vice Chancellor and public health expert, Adesh University, Punjab
  35. Dr G S Kaushal, Retd. Director Agriculture, Govt of Madhya Pradesh, Bhopal
  36. Dr K Ramakrishnappa, Former Director, Dept of Horticulture, Karnataka
  37. Dr K C Raghu, Former Editor, Food and Nutrition Magazine, Bangalore
  38. Dr Nitya Ghotge, Anthra, Pune
  39. Dr Ponnammal Natarajan, Retd Dean, Anna University
  40. Dr Prakash HR, Retd Scientist, Dept Of Agriculture, Karnataka
  41. Dr Prema H.S, Dietician, Varenya Nutrition Concepts, Bangalore
  42. Dr Priti Joshi, National Organization for Community Welfare, Wardha
  43. Dr R N Basu, Retd. VC, Calcutta University & Formerly Chair, WB State Agriculture Commission
  44. Dr Ramesh B Thakare, Geneticist, Nagpur
  45. Dr Sadhu Ram Sharma, Former Cane Commissioner, MP
  46. Dr Sanjeev Kulkarni, Baala Balaga, Dharwad
  47. Dr Satpude, Former Dean, Agriculture College, Khandwa, MP
  48. Dr Shroff, Agriculture Scientist, Indore, MP
  49. Dr T K Bose, Formerly Member, State Agriculture Commission, West Bengal
  50. Dr T S Channesh, Formerly Scientist, KVK, UAS Chintamani
  51. Dr Tushar Chakraborty, molecular biologist, Kolkata
  52. Dr V S Vijayan, formerly Chair of Kerala State Biodiversity Board
  53. Dr V T Sundaramurthy, Formerly Project Coordinator, All India Coordinated Cotton Improvement Project (ICAR), Coimbatore
  54. Dr Venkatesh Krishnamoorthy, Chairman and Founder, NU Hospitals, Bangalore
  55. Ekta Jaju, Switch ON (Environment Conservation Society), Kolkata
  56. Gautam Singh, Chandigarh
  57. Gopi Krishna, Greenpeace India, Bangalore
  58. Hemant Goswami, Citizen Voice, Chandigarh
  59. Ilias KP, Jaiva Karshaka Samithy, Kerala
  60. Ishwar Chander Tripathi, Bhartiya Kisan Union, Madhya Pradesh
  61. Jagadeesh Koppa, Senior Journalist, Dharwad
  62. Jagannathan, Nalla Keerai, Thiuvellore
  63. Jaya Iyer, KHANA (KHAdya Nyaya Abhiyaan), Delhi
  64. Jayant Verma, Hamara Beej Abhiyan, Madhya Pradesh
  65. K Sethuraman, concerned citizen, Tamil Nadu
  66. K Jagadeesan, Advisor, Federation of Tamil Nadu Rice Mill Owners’ Association
  67. Kanwarjeet Singh, Mumbai
  68. Kapil Shah, JATAN, Vadodara, Gujarat
  69. Karpagam, organic farmer, Point Return, Maduranthagam
  70. Kavitha Kuruganti, Alliance for Sustainable & Holistic Agriculture (ASHA), Bangalore
  71. Kisan Swaraj Samity, West Bengal State Committee
  72. Kodihalli Chandrashekar, President, Karnataka Rajya Raitha Sangha (KRRS)
  73. Kuppusamy, Kollathur Organic Farmers Association, Tamil Nadu
  74. Laxman Singh Moonia, Lok Jagriti Manch, Jhabua, MP
  75. Lingamadaiah, Farmer Breeder, Channapatna, Karnataka
  76. Nagesh Hegde, Senior Journalist, Bangalore
  77. Nalla Gounder, Freelance Journalist
  78. Nityanand Jayaraman, The Other Media, Chennai
  79. N R Shetty, Sahaja Organics, Bangalore
  80. Prof G S Jayadeva, Social Worker, Chamarajanagar
  81. Prof Shubh Prem Brar, Vatavaran Kendra, Bathinda
  82. P Srinivas, SOIL, Bangalore
  83. Pamayan, Thalaanmai Uzhavar Iyakam, Tamil Nadu
  84. Panduranga Hegde, Environmentalist, Karnataka
  85. Pankaj Bhushan, GM Free Bihar Movement, Muzzaffarpur
  86. Ponnuthai, Kalnjium Women Farmer’s Association, Thirunelveli, Tamilnadu
  87. Praveen N, Desi Seed Producers Company Ltd, Bangalore
  88. Priya, Archana, Kavitha Ramakrishnan, The Magic Bean, Chennai
  89. Rachna Arora, Public Awareness on GM Foods/India For Safe Food, Gurgaon
  90. Radhika Rammohan, Restore, Chennai
  91. Raghuram RP, Sreenivasa Guttal, Sridhar S, Venugopal A, Dr Srinidhi V:   Purnapramathi-A Center for Integrated Learning, Bangalore
  92. Rajeev Natarajan, Ritambara
  93. Rajinder Bhagel, Ex MLA, Organic Farmer, Sonkach, Madhya Pradesh
  94. Ramasubramanian, Samanvaya Consulting, Chennai
  95. Ramaswamy Selvam, Tamil Nadu Organic Farmers Federation
  96. Ramesh Chandran, Anantha, Coimbatore
  97. Ramesh Chaudhary, Madhyanchal Forum, Bhopal, MP
  98. Ranjan Ghosh, Jan Chetna Manch, Jharkhand
  99. Rathinasamy, President, Thamilaga Vivsayegal Sangam, Erode dist., Tamil Nadu
  100. Ravi Kelkar, Organic Farming Expert, Indore, Madhya Pradesh
  101. Right to Food Campaign, Madhya Pradesh
  102. Rina Gill, Former Deputy Director, Policy and Planning, UNICEF New York
  103. S G Siddaramaiah, Writer, Bangalore
  104. Sainik Raj, Desi Krushikara Balaga, Haveri
  105. Sangeetha Sriram, Restore Gardens, Chennai
  106. Saroj Mohanty, Paschim Odisha Krushak Samanvay Samithy, Sambalpur
  107. Satish Bonthu, Organic Depot, Chennai
  108. Shalini Bhutani, Legal Research and Policy Analyst, New Delhi
  109. Shamika Mone, Convenor for South Asia, Intercontinental Network of Organic Farming Organisations (INOFO)
  110. Shankar Guru, Farmer Breeder, Madralli, T.Narasipura, Mysore
  111. Shankara Langati, Gene Saviour awardee, Khanapur, Belgaum
  112. Sheelu Francis,  Women’s Collective, Chennai, Tamilnadu
  113. Shivayogi Makari, Secretary, Desi Cotton Growers Association, Gadag
  114. Somasundaram Narendran, Tamil Nadu
  115. Soumik Banerjee, SWALA, Godda, Jharkhand
  116. Sreedevi Lakshmikutty, Urban Leaves, Mumbai
  117. Sundararajan, Poovulagin Nanbargal, Chennai
  118. Sundari, Tamilnadu Resource Team, Chennai, Tamilnadu
  119. Suresh Lakshmipathy, Tula India, Chennai
  120. Syed Ghani Khan, Gene Saviour awardee, Kirugavalu, Mandya
  121. Tanmay Joshi, GM-Free Maharashtra, Pune
  122. Tejal V, concerned citizen, Mumbai
  123. Tejashri Kamble, Koradwahu Gat, Pune
  124. Thirumalai, Nalla Sandhai, Thiruvellore
  125. Uma Shankari, Rashtriya Raithu Seva Samithi, P. Kothakota, Chittoor dt. AP
  126. Umendra Dutt, Kheti Virasat Mission, Punjab
  127. Usha S, Thanal, Kerala
  128. Vaiyapuri, President, Iykiya Vivasayegal Sangam, Thalaivasal, Salem Dist., TN
  129. Vasant Futane, SAMVAD, Amravati district, Maharashtra
  130. Vinita Mansata, Earthcare Books, Kolkata
  131. Vishal V Ghodke, Naturesgram, Thane


And, following farmers from Hingalganj Block of North 24 Parganas, West Bengal

132 Bishnupada Mridha 140 Susanta Mandal 148 Nirmal Gayen 156 Madhab Mondal
133 Sahadeb Gayen 141 Dipu Gayen 149 Mantu Mondal 157 Gopikanta Mondal
134 Parul Mondal 142 Sajal Baiday 150 Sita Sardar 158 Binay Mondal
135 Hiranmay Biswas 143 Aparna Halder 151 Dinabandhu Mistri 159 Binay Naskar
136 Basudeb Gayen 144 Manashi Samanta 152 Nirad Jaddar 160 Sukdeb Mondal
137 Prakash Mondal 145 Shama Mondal 153 Sujit Mondal 161 Kamalesh Mondal
138 Pampa Kayal 146 Kamalesh Sarkar 154 Sabita Mondal 162 Ardhendu Mondal
139 Goutam Biswas 147 Sumangal Mondal 155 Dhiran Mondal  






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