'Call A Moratorium..'

Dr Manmohan Singh, 
Hon’ble Prime Minister of India, 
# 7, Race Course Road, 
New Delhi 

Dear Dr. Manmohan Singh

In July 2009, Dr Anbumani Ramadoss received a formal reply to his letter dated 2nd February 2009, from Mr Prithviraj Chauhan in his capacity as Minister of State in the PMO. (This letter is enclosed). Dr Ramadoss addressed his letter to you when he was Minister of Health and Family Welfare. 

We are understandably concerned at the contents of this letter. Its admitted source for much of the content is the organisation called International Service for the Acquisition of Agri-biotech Applications (ISAAA). This organisation is part of the marketing arm of the major international biotechnology companies and not a source of unbiased or peer-reviewed information. The information coming from the ISAAA is contested and rejected by many. Its stated objective is to promote GM crops, with India and other developing countries as the focus. Given this fact, it is not surprising that the letter is factually incorrect in virtually the whole of its content and is not science-based. We enclose a response to this letter addressed to you as our Prime Minister, endorsed by leading independent academic scientists of international standing. We urge you to please read it. 

This communication proves that significantly erroneous views are formally held by the PMO and several of your Cabinet colleagues about the supposed benefits of GM crops. These views have driven successive government policy, including the Congress Party policy on agriculture and the role of genetically engineered food crops. We therefore, must conclude that there has been a purposeful and systematic intent by the Regulators (GEAC, RCGM and DBT), to mislead you and former prime ministers about the truth of GM crops. We are furthermore, convinced by the evidence on record, of a blatant conflict of interest within the regulators and the committee charged with the appraisal of Bt brinjal called the Bt brinjal Expert Committee II (EC II). The evidence also shows that the appraisal process, minimal guidelines used and subsequent approval are fraudulent. Information just received under the RTI for example, squarely refutes the Regulators claim that the extensive reports from several States in India of allergenicity and specifically, animal deaths from toxic reactions attributed to grazing in Bt cotton fields, have no substance. This is a serious falsification of the true facts. No investigation of any depth, leave alone of scientific rigour, has been conducted to ascertain the safety of the Bt gene in Bt cotton and the reason for the animal deaths. We quite simply have not done the studies. Moreover, we do not have the means to test for allergenic reactions to Bt toxins. Unfortunately, the Minister of Agriculture, Mr Sharad Pawar even allegedly saw fit to bring inappropriate pressure on the Chairperson of the Committee and interfere with the regulatory process. It is deeply worrying that Monsanto is also in a position to influence the regulatory process in India. Monsanto has been indicted for and convicted of serious crimes for repeated fraudulent processes & procedures in safety-testing of GM crops, and is presently under investigation by the US Justice Department for antitrust law violations. These are a matter of record and will be furnished if you so wish, along with other evidence of impropriety by the Regulators. 

These are serious charges, Sir. We are fully conscious of the implications of our charge and are driven by the undeniable fact that India has a just one chance to get things right. The impacts of GM Crops are irreversible. The greatest single danger India faces today is the massive disinformation on GM crops. Wrong briefs and erroneous facts cannot produce sound public policy. Nor may we accept hurried approvals unsupported by the most comprehensive, stringent and rigorous adherence to safety protocols, in their processes & procedures. Independent testing in labs working to accredited international standards is the sine qua non of bio-safety regulation to address the unique risks that GM crops pose. Unfortunately, none of this is in place. We have upwards of 20 independent appraisals by world eminent scientists of Monsanto’s safety dossier/and or the Bt brinjal EC II Report. These reveal significant gaps in safety testing, cover-ups, & shoddy protocols. The greater charge must be levelled against the GM Regulators, who are responsible for the Nation’s bio-safety. They have not only defended these serious shortcomings, but have given overtly hasty approval to the commercialisation of Bt brinjal. 

GM crops thus far are NOT engineered for yield gain and to date, not a single GE plant offers this trait or any other trait. There is no one alive today who would otherwise have starved if there were no GM crops ever grown. In fact, there may be less food in a GM world than a conventional world because GM crops are suited to the inefficient production of ethanol which is subsidised by the US government. If those subsidies did not exist, there would be more food for people. You may rightly be anxious about where we will find the answer to yield increase in Indian agriculture and other developing countries and how may we meet the challenge of global food production and genuine food security through productive agriculture in the next 50 years? There is no need to worry: India has already endorsed the solution.

The IAASTD Report: We point you to the IAASTD Report (the International Assessment of Agricultural Knowledge, Science and Technology for Development), a UN and World Bank report that India ratified in 2008. These questions were considered methodically and holistically by the single largest research exercise in history. This report, published in January as Agriculture at a Crossroads, was produced under the International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD). It involved around 400 researchers and twice the number of peer-reviewers. The agricultural equivalent of the IPCC and modelled on it, it underwent two rounds of open international peer-review and was ratified overwhelmingly at the intergovernmental plenary in April 2008. 

The “IAASTD” sees no role for GM crops in developing countries. It makes it clear that the road map for agriculture for the next 50 years must be through localised solutions, combining scientific research with traditional knowledge in partnership with farmers and consumers. The Report calls for a systematic redirection of investment, funding, research and policy focus toward these alternative technologies, such as agro-ecological agriculture, and the needs of small-farmers. ‘Business as usual’ will inevitably result in food and fuel needs exceeding global ability to meet them. However, this isn’t a food shortage problem. The problem historically and presently is caused by social barriers and because of the model of industrial agriculture (external input intensive) for which most GE products are designed. In fact, more GE is more ‘business as usual’.

The urgent question is why this timely report which we have ratified has been comprehensively ignored in formulating India’s official policy for a road map for agriculture and food security? The Union of Concerned Scientists too makes unequivocal analyses of the solutions. “It makes little sense to support genetic engineering at the expense of technologies that have proven to substantially increase yields, especially in developing countries… these include modern, conventional plant breeding methods, sustainable and organic farming and other sophisticated farming practices that do not require farmers to pay significant upfront costs…” 

The critical requirement is to protect our farmers, crops and livestock from biotechnology corporations through their patenting of the germplasm of both plants and animals. This will result in the undoubted colonisation and industrialisation of Indian farming. National food security also critically means safe food. GM crops will lead to a collapse of our food security, subjecting us to an impossible future because it will be both unsustainable and unsafe.

It would be a profound disservice to our Country if Bt brinjal were allowed to be released. We therefore, respectfully request you to call a moratorium on all field testing of GM Crops and Bt brinjal and an independent nationwide review of Bt cotton. We also require a fundamental reassessment of agriculture policy, redirecting investment in alternative biotechnologies in line with the IAASTD. 

We remain,
Respectfully yours,

• Dr Lalith Nath: Epidemiologist: Retd. Dean, Centre of Community Medicine, AIMS Delhi
• Admiral R.H. Tahiliani (Former Navy Chief and Chairman Transparency International) 
• Dr. CS Pandav : Prof and Head, (c/o) Dept of Community Medicine, AIMS, New Delhi
• Aruna Roy: Social Activist, MKSS
• Mahesh Bhatt: Writer and Filmmaker
• Prof U R Ananthamurthy: formerly Vice Chancellor, M G University, Kottayam, Kerala. Jnanapeeth Award for Literature; Padma Bhushan
• Lalita Ramdas: President YAKSI, Hyderabad, (YAKSI works with Adivasi communities on Rights’-based issues); CNDP; (Coalition for Nuclear Disarmament and Peace).
• Dr Rajesh Kumar: Prof & Head, School of Public Health, Post Graduate Institute of Medical Education and Research
• Dr. Anant Phadke: Co-convenor, Jan Aarogya Abhiyan, Maharashtra
• Dr. Thelma Narayan: Centre for Public Health and Equity ( SOCHARA) Bangalore Governing Body Member of National Health Systems Resource Centre, New Delhi
• Dr. Ravi Narayan: Centre for Public Health and Equity, ( SOCHARA) Bangalore, Governing Body Member of Public Health Foundation of India 
• Dr Vandana Shiva: Founder, Navdanya, Chair International commission on the Future of Food: Director Research Foundation for Science, Technology and Ecology
• Admiral Laxminarayanan Ramdas: (Retd) Chief of Naval Staff: Magsaysay Award for Peace; Member, National Co-ordination Committee of the CNDP (Coalition for Nuclear Disarmament and Peace)
• Mira Shiva: Initiative for Health Equity & Society; Third World Network
• Alex Hankey PhD: Dean, Academic Studies Institute of Ayurveda Integrative Medicine Executive Editor, Journal of Ayurveda and Integrative Medicine, Bangalore 
• Madhu Bhaduri: Former Indian Ambassador to Mexico
• Teesta Setalvad: Lawyer: Founder, Citizens for Justice and Peace; Editor, Communalism Combat)
• Jagdeep S. Chhokar: Professor, IIM Ahmedabad
• Dr Sagari R Ramdas, MS Animal Breeding and Genetics (BVsc &AH): Director , Anthra, India 
• Kamini Jaiswal: Advocate, Supreme Court
• Kavitha Kuruganti: Kheti Virasat Mission, Punjab
• Dr Ramanjaneyulu: Agriculture Extension Scientist : Ex. Director, Centre for Sustainable Agriculture (CSA). 
• Aruna Rodrigues: Sunray Harvesters: Lead Petitioner, PIL (in Supreme Court)
• Prashant Bhushan: Advocate, Supreme Court

Enclosed:

• Letter from eminent Academic Scientists to the Honourable Prime Minister of India
• Letter from Shri Prithviraj Chauhan to Shri A Ramadoss