Saturday, December 13, 2003



The field of agricultural biotechnology has stimulated an animated discussion in many countries of the world but the predominantly agricultural countries of Asia do not fall in this category. Information levels about biotechnology per se and about Ag- Biotechnology is poor and the subject is inadequately taught in colleges and most universities. Most administrators, policy makers, politicians, legislators, bar, and judiciary do not comprehend this technology.

The lack of comprehensible and credible information is leading to poor policy development, skewed priorities for public and private investment and lack of trained manpower. The lacuna in understanding is reflected in the way public polices are being framed. The regulatory process in place is careless and shoddy to the point of being dangerous. Protagonists of biotechnology in the decision-making bodies in government are determining the biotechnology agenda and plunging headlong into it without realizing that their inexperience and inadequacies can lead to disastrous consequences.

For an agricultural country like India, the adoption of an agricultural technology has to be done carefully, keeping the interests of farmers, especially, small farmers, in mind. Decision-making must be inclusive and participatory. Yet, agricultural biotechnology is being imposed from the top, with no consultations with any of the stakeholders and no transparency in the process.

The first ever GM crop in India, Monsanto’s Bt cotton is being cultivated and there is controversy about its performance and its suitability. The regulatory system is non –transparent and has been widely criticised, decision-making is ad hoc and arbitrary. In Asia the next five years are likely to see a series of face-offs between the scientific –administrative community and the public over this new technology. It would be prudent to develop a comprehensive understanding of the ground realities and to contribute to raising the level of information and awareness among stakeholders in India and other Asian nations.

It is therefore crucially important that unbiased and comprehensible information about biotechnology and its related social, ethical and economic concerns be made available to focus groups like students, teachers, government officials and policy makers, mass media, the bar and the judiciary, farmers and professionals. There is a great need for such information materials in regional languages for education in rural and semi-urban areas. Credible studies need to be done that measure public perceptions and attitudes to agricultural biotechnology. This exercise is necessary for India to craft its own ag-biotechnology agenda, suited to its needs.

Work needs to be done urgently on :

  • Improving understanding of agricultural biotechnology in India/ Asia
  • Producing information materials on gm technology and its applications
  • Holding public debates to elicit the public’s views and channel this into policy making
  • Assessing perceptions & attitudes to agbiotechnology among the major stakeholders

Friday, December 12, 2003



The chairperson of the Genetic Engineering Approval Committee (GEAC), the apex regulatory body for biotechnology products like GM crops, is not a person of the highest technical competence, as one would expect, but whichever bureaucrat happens to be posted as the Additional Secretary in the Ministry of Environment and Forests. The rest of the GEAC is not trained in the core area of bio safety assessment either. The mixture of bureaucrats and representatives of scientific bodies are there ex officio; almost no one brings the specific skills required by the job.

India must radically change the composition and functions of the bodies that are designated to manage GM technology otherwise, ignorance could lead to wrong decisions that could end up hurting Indian farmers and pose a danger to the environment of this country and the health of its people. The unbridled spread of the illegal Bt cotton, Navbharat 151 and the complete failure of the GEAC to control the situation even three years down the line, do not inspire confidence in its capabilities. The GEAC’s resolute refusal to engage with public concerns or provide any information on the handling and trial of GM crops is anachronistic in this day and age and raises suspicions about its motivations. The fact that GEAC authorised commercial cultivation of Monsanto’s Bt cotton even when there were no legally mandated State Level Committees or District Level Committees, in any of the six states, raises disquiet about its flagrant disregard of the law.

The GEAC should be a technically competent body, strong on Risk assessment and Risk Management of GM crops as also on Monitoring. At present members of the GEAC are not qualified to understand the process of Bio safety Assessment, Environmental Assessment or Environmental Impact Assessment, which are central to their functioning. This means that they are not qualified to interpret the data that is placed before them for evaluation. The regulatory structure must be competent and independent to inspire confidence. It should be able not just to assess Biosafety but also other aspects like social and economic impacts, particularly the impact on small farmers, of the introduction of a particular GM crop. In western nations these aspects may not have a central position but in the context of Indian agriculture, it is important to evaluate such impacts before taking a final decision.

The UNEP International Technical guidelines for safety in Biotechnology outline the following steps for identifying potential impacts and assessment of risks:

  • Identify potential adverse effects on human health and/or the environment
  • Estimate the likelihood of these adverse effects being realized
  • Evaluate the consequences should the risks materialize
  • Consider appropriate risk management strategies
  • Estimate the overall potential impacts that may be beneficial to human health or the environment.

In my view, it would be best to divide the regulatory function into two parts, one Advisory, the other Statutory.

Advisory Body

The Advisory body should have a broad based multidisciplinary membership that includes all relevant scientific disciplines, social scientists, environmentalists, civil society groups, members of farming and adivasi communities, representatives of panchayati raj institutions, and legal experts. A person of the highest technical calibre who has experience in the regulation of GM crops should head the GEAC.

Statutory Body

The statutory body should be an independent body staffed by people skilled in Bio safety Assessment, Environmental Assessment and Environmental Impact Assessment. This body should have overall responsibility for all aspects of risk assessment, risk management, risk communication leading up to decision-making about the safety of a GM crop for the environment, human and animal health and post release monitoring. It is important to ensure that there is no conflict of interest and rules should be framed in a clear and unambiguous manner so that it is not possible to stack the Agency with any particular kind of people.

The regulatory process should be transparent, accountable and technically competent. Data from field trials and the rationale for decision-making should be available to the public. A cost benefit and a risk benefit analysis should be conducted before decisions are taken and clear-cut channels should be created for the public to participate in the decision-making process and to voice concerns. There should be an annual review of the decisions taken on GM products and the rationale for these decisions. This review should be presented to Parliament.

Monday, November 17, 2003



Countries like India that have food security concerns and have small and marginal farmers practicing an integrated type of agriculture have specific problems for which they seek solutions. GM technology has been developed for the large land holding, mechanized agriculture of industrialized countries. There is little available in the GM arsenal today that is geared to address the problems of developing country agriculture. India could use a toxin free variety of the khesari dal (Lathyrus sativus) grown on marginal lands and consumed by the very poor. Consumption over time leads to a form of paralysis because of the poison but sometimes it’s the only food available. India could use salt tolerant and drought tolerant crop varieties that could grow on degraded lands or in arid areas where nothing much grows at present. This would help food production and bring money and food to marginal farmers living in difficult areas.

Instead of crop varieties aimed at alleviating hunger, GM technology at present offers just four major crops - soybean, corn (yellow corn used for animal feed and industrial use, not white corn used for food), cotton and canola. The most prevalent characteristic for which the crops are bred is herbicide tolerance followed by insect resistance, as with Bt cotton. There are no crop varieties, which have enhanced nutrition, high protein cereals for example, which would be needed in India and developing countries.

The herbicide tolerance trait in a crop variety bestows the ability to withstand application of herbicides in a field where herbicides are sprayed (often by airplanes) to control weeds. This trait is developed for the several thousand hectare farms in developed countries where aerial spraying is needed since it is not possible to control weeds otherwise. Of what use would an herbicide tolerant crop be in India? It would displace labour that today does the weeding in fields. This would mean loss of income for farm labour, especially women, and it would mean loss of fodder and nutritive leafy greens. What is weed in a rice or wheat crop is valued as vegetable by rural families (the highly nutritious chaulai and bathua saag). What is not edible goes to feed the livestock. Weeds support rural livelihoods and in our agricultural system we would be mad to introduce herbicide tolerant crops.

Let us take the two crops in question in India, Bt cotton and GM mustard. The economics of Bt cotton is unfavorable since the seed costs about four times as much as the other successful hybrids in the field (Rs. 1600, compared to Rs. 400). With the first Bt crop, the evidence is clear that pesticide savings do not make up the difference in seed price for the farmer. The small land holdings that are the bulk of cotton fields become even more uneconomic if farmers have to divert 20 per cent of their land as an insect refuge, as recommended by the GEAC. If there is no refuge, the insects will quickly develop resistance and the Bt cotton will fail. A fundamental problem with cotton is the crashing prices. Maharashtra, an important cotton area, has a monopoly pricing system because cotton prices have been plummeting these past few years, the situation exacerbated by the government’s ad hoc decision to import cotton, causing cotton prices to crash further. So what real life problem facing farmers will Bt cotton solve?

GM mustard is a variety using the barnase –barstar-bar gene complex, an unstable gene construct with possible undesirable effects, to achieve male sterile lines that are used to make hybrid mustard varieties. In India we have good non-GM alternatives for making male sterile lines for hybrid production so the Proagro variety is of little use. Being a food crop, GM mustard will have to be examined very carefully. Even if there were to be benefits, they have to be weighed against the risks posed to human health and the environment. Sarson ka saag is a popular vegetable, mustard oil widely used in cooking is extracted by manual crushing which can leave organic (and genetic) matter in the oil and mustard oil cake is used as animal feed. Apart from this, mustard is a cross-pollinating crop and pollen with their foreign genes is bound to reach non-GM mustard and wild relatives. We do not know what impact this will have.

The most worrisome aspect about deciding whether GM crops are good or bad is the complete lack of information about how decisions are being made. Both GM crops belong to MNCs and given their track record, there is apprehension that influence is being ‘bought’ in scientific and regulatory agencies for favorable verdicts. The GEAC is a secretive insider club taking ad hoc decisions, resolutely refusing to acknowledge the public’s right to know. In such a climate, GM crops cannot be good for India.

Roundup Ready ( Herbicide Tolerant) Maize should not come to India

Notwithstanding the resounding failure of its Bt cotton, Monsanto has begun the process for introducing another genetically modified crop into India, its proprietary maize variety called Roundup Ready corn. The government’s Review Committee on Genetic Manipulation (RCGM) has given permission for Monsanto to bring in breeding material and start its work.

Roundup Ready corn is a herbicide tolerant maize variety which offers no advantages to the Indian farmer with respect to yield, no protection against disease, no ability to tolerate saline soils, no drought tolerance and no improvement in the quality of the grain, to mention a few of the reasons why new varieties are introduced. Monsanto’s herbicide tolerant maize is a variety which contains genes that will allow it to tolerate the poisons contained in the herbicide Roundup, which when sprayed, will kill all the other plants, which become weeds in the field. So after spraying Roundup in the field, the Roundup Ready variety will be the only vegetation left standing, everything else will die.

Roundup is an herbicide (a chemical used to kill weeds) which also belongs to Monsanto which until very recently held the patent on it. This means that the farmer has to buy the package, the Roundup Ready variety and its matched herbicide, Roundup, since one is dependent on the other. Herbicide tolerance is a clever strategy developed for the company, not the farmer. It allows Monsanto to make a double killing, first on the seed and then on the herbicide. Monsanto has succeeded in promoting its herbicide tolerant crops to the extent that globally, herbicide tolerance is the single most prevalent trait in the cultivation of GM crops, the other being insect resistance, that is Bt. In 2002, of the total acreage of GM crops, over 80 per cent was devoted to herbicide tolerant crops and the remaining to Bt crops.

Herbicide tolerance was developed as a trait in crops to address the problems of agriculture in industrial countries where landholdings run into a few thousand acres and where practically no labor is available for farm operations. With just two to five per cent of the population in farming, agriculture is largely mechanized. Weed control therefore cannot be done by hand. The preferred way of controlling weeds in these countries is by aerial spraying which is a wasteful and ecologically destructive method.

In developing countries, agricultural holdings are small and densely packed. Fields growing different crops neighbor one another and agricultural fields are set within or border natural ecosystems with natural biodiversity. So, if fields of other crops and even borders of natural vegetation or the forest edge flanked a field growing Monsanto’s Roundup Ready maize, then spraying the Roundup herbicide would affect the neighboring crops and natural vegetation (which do not have Monsanto’s Roundup resistant gene) and kill them. Surely this leap in GM technology cannot be considered desirable either from the point of view of farmers or the biodiversity.

Herbicide tolerance as a trait should actually not be allowed in India or other developing countries for important economic and health reasons. In these countries weeding is a source of many benefits to the rural community. A weed is only a plant that is growing at the wrong place at that time. It is not a useless plant. Weeding provides wage labor to agricultural labor, which is usually the land-less farmer. In addition, women mostly do the weeding, providing them with a direct, and often only, income source. Using the Roundup Ready approach will kill this source of income. So in India, rather than the chemical route of herbicide tolerant plants and the double deal for the company with the proprietary herbicide, the socio-economic interest of the community lies in manual weeding.

Even more importantly, the rural household consumes all the plants that are collected as weeds. Many of these are leafy greens like amaranth (the same plant which is contributing the protein gene for the efforts to make a protein rich GM potato), a rich source of vitamins and minerals. This highly nutritious source of food is available for free and goes into the cooking pot of poor rural families, one of the reasons why rural nutrition is far better than urban nutrition. What the family does not consume serves as fodder for the livestock maintained by the family as an additional source of income.

The last thing that rural India needs is Monsanto’s herbicide tolerant maize or any other herbicide tolerant crop for that matter. If GM technology is to be used in India, it should be directed at the real needs of Indian farmers, on crops like legumes, oilseeds and fodder and traits like drought tolerance and salinity tolerance.

The myth of GM Potato

The Secretary, Department of Biotechnology has been making statements that a GM potato variety would be available in India within six months. Curiously, the Genetic Engineering Approval committee (GEAC) has not even received an application to consider approval for the GM potato in question.

First, the GM potato is quite far away from commercial release. Its promoters appear to be jumping the gun deliberately, in order to pressure the agencies for its release on a human suffering angle. The emotional button for Bt cotton was the farmer suicides in Andhra Pradesh and the need to give them a cotton variety that would slash the heavy expenditure on pesticides and by inference, stop them killing themselves due to debt burdens. We know now that the Bt cotton practically failed in almost all locations it was grown. The emotional button being pressed for GM potato is malnutrioned children susceptible to blindness and how this potato will solve all of that and bring smiles to their well fed little faces. What is not explained is how the potato supposedly with enriched protein will cure night blindness, which is brought about by vitamin A deficiency. Curing night blindness has been entrusted to Golden Rice whenever it sees the light of day, not potato.

In fact the premature announcement made a specific reference to the fact that as soon as the potato was cleared, it would be given free to millions of schoolchildren across the country. This is even more worrisome than the fact that at the moment the GM potato is only an experiment, not a product. If the GM potato is improved to the extent that the protein content rises significantly, and it is judged to be safe, we could discuss its merits then. At the moment it will do nothing for schoolchildren except expose them to an untested food, which could have harmful effects. Potatoes belong to the botanical family Solanacea, the same family as the poisonous nightshade, a family known to have many plant toxins.

This talk of feeding GM potatoes to schoolchildren is unacceptable adventurism. If there is such an urgent need to save these children, food supplements can be added to their school meals. This will be a safer and more certain path to nutritional enhancement than rushing untested GM potatoes to them. Nutritional enhancement by food supplements is easy to do in schools and has an established tradition. It is difficult to make the case for GM potatoes as a preferred route for enhanced dietary protein, compared for example to pulses or soya blended wheat flour.

As it stands today, even the science done on GM potato is inadequate and we are talking about an incompletely tested product. One thing is clear to everyone that the increase in protein in the GM potato is negligible and will make no real difference nutritionally. Scientists working at the Central Potato Research Institute have emphasized this. What has not been brought out is the fact that this GM potato might not even pan out, not in 2005, not ever. We do not know yet because the appropriate experiments have not been done to test whether this transgenic potato is stable or not.

All the experiments on the GM potato so far have been done only on the vegetative cycle, which means we do not know how the variety behaves when it is sexually reproduced (flowering and setting seed). At present we cannot say anything about the stability of the transgenic potato in the long run since studies on gene insertion have been done only in one vegetative generation, not in several sexual generations, as it should be.

Potato is mostly vegetatively propagated in India, which means potatoes are cut up into pieces and serve as ‘seed’ for sowing the next crop. The little pieces grow into bigger potatoes and when they are large enough, the crop is harvested and so it goes from crop to crop. During the potato cultivation process in the plains, no flowering takes place, no seed is set and there is no “next generation” as is, for example, the case with wheat and rice.

Before any judgment can be passed on the value of the GM potato, studies need to be conducted to evaluate the stability of the gene from one generation to the next generation, to ensure that the amaranth protein gene is actually integrated into the genetic material of the potato. If this is not the case and if the gene is only temporarily lodged somewhere, the protein expression in the potato will be unstable; it may vary in amounts from potato to potato and from crop cycle to crop cycle. It may even disappear altogether. Such an unstable variety cannot be given to farmers.

Does Bt Basmati make sense?

Basmati Rice and Darjeeling tea are perhaps India’s most easily identifiable premium products in the area of food. Basmati is highly prized rice, its markets are growing and it is a high end, expensive product in the international market. Like Champagne wine and truffles from France, international consumers treat it as a special, luxury food. So does it make any sense at all to breed a genetically modified (GM) Basmati, that too a Bt Basmati, along the lines of Bt Cotton? The Basmati traders would appear to have far more sense than the government of India and its scientific establishment in this respect. RS Sheshadri of United Riceland, the largest Basmati exporter to Europe, has said in the Economic Times that “Anything connected with GM is the kiss of death for Basmati.”

Given the fact that there is fearsome resistance to GM foods in Europe and in other pockets of the world, is it an intelligent act to ‘taint’ your Basmati with the GM label, that too the Bt label? The Bt gene belongs to Monsanto, the company that is the most visible target of the anti-GM lobby and for the GM protestors on the streets, symbolic of all that is wrong with GM crops. Monsanto’s Bt approach is not only collapsing in parts of the world, it has also been criticized as unsustainable. And the Indian scientific establishment wants to deliver its much sought after Basmati as a target of protest and rejection, to the anti-GM group that is increasingly determining consumer preference in the European and other selected markets!

Basmati rice is an up market product; eaten largely by that section that is willing and able to spend money on expensive foods. It is precisely this section, which is usually better educated, has surplus money and no food security concerns, that is quite strongly opposed to GM crops. It is this section that is both promoting and consuming organic and natural foods by preference. Not surprisingly, the demand for brown, unpolished Basmati is growing in this elite consumer section of Europe.

So whom is the Bt Basmati targeted at? Who are supposed to be the consumers of this premium rice with the “kiss of death” GM tag? If the argument is that GM is not an issue in the Middle East, the other large market for Basmati, and here Bt rice would be acceptable, then that is an untenable argument. Once India is producing GM basmati rice, the concern in the European market will quite legitimately be whether any ‘non-GM basmati’ designated for them and that they are buying isn’t contaminated by GM basmati? This leads us to the question of labeling and identity preservation of GM and non-GM crops.

Segregation of GM and non-GM basmati (or for that matter any crop) is going to be next to impossible to maintain under Indian agricultural conditions, and this will entail large costs. Even if this were to be done, at the first hint of GM and non-GM mixing, which is bound to happen, consignments to Europe and other GM sensitized markets will be rejected and India will lose the assured market she today has for Basmati. Has anyone thought any of this through? Have all those votaries of introducing disease resistance through the patented Bt route (now seen collapsing around our ears in the failure of India’s first GM/Bt cotton harvest) thought of what will happen to farmers who grow Basmati and who command assured prices, when their harvests find no buyers?

This idea of Bt Basmati is every bit as crazy as the idea to introduce the Golden Rice technology into Basmati rice. Work on Golden Rice is being done with the goal of increasing the nutritional status of the poor, rice dependent populations of the world who usually have nothing more than plain rice as their only food. Since rice is nutritionally a poor cereal, it is thought that adding iron and vitamin A to it by genetic modification would increase the nutritional quality of rice.

The Golden Rice project may or may not materialize ultimately but to think that people who buy basmati at Rs 40 a kg are likely to be in need of nutritional fortification is about as absurd a theory as any. Are these the people threatened by night blindness that golden basmati rice is supposed to be helping? Should the diminishing agricultural research budget of India be frittered away on nonsensical notions of the golden basmati rice kind? Or should it be targeted at solving problems that real farmers have in real fields?

When will our science planners get it? Basmati rice is an expensive, premium product, which is doing well enough on its own without the scientific establishment trying to queer the pitch every step of the way. Every grain of Basmati rice is likely to find a market today. It will not if we ruin the legend and perception of Basmati in the international market. Can anyone think of GM truffles? Premium wine makers have outright rejected the notion of GM doctored wines that were designed to cut out the hangover and were supposed to be ‘healthier’. Premium products like special wines, truffles and Basmati rice need to be handled in a special, premium way. The aura of specialty has to be maintained in order to keep the consumer captivated, and the market vibrant and growing! The approach of Bt Basmati rice and Golden Basmati Rice are about as wrong as you can get to achieve these goals.

Monday, July 21, 2003


Suman Sahai

The current thrust of GM research and application in India is ad hoc and arbitrary. There does not seem to be a visible purpose behind the decisions taken other than the mere availability of this or the other variety. This availability is extremely restricted and the choice can be made only from the four crops that were bred to address the problems faced by large farmers in industrial countries and the two principal traits that are available. The crops are cotton, soybean, corn and canola and the traits are herbicide tolerance and insect resistance as in the case of Bt . The Indian research program, which is developing GM crops, is poorly focussed and driven by the genes available in the repertoire of companies like Monsanto rather than the need to solve the problems of Indian agriculture. So heavy is the dependence on proprietary genes that almost half the Indian research programs are using versions of Monsanto’s Cry1 (Cry1Ab; Cry1Ac) gene, spread over a variety of crops.

If India is to be seen as a responsible nation capable of adopting a complex technology like GM technology, the science administrators will have to demonstrate far greater competence than they are doing at present. The research agenda will have to be decided after a needs assessment exercise so that research is being done on crops and traits relevant to India. A competent system of bio safety testing must be introduced, with well-established, scientifically sensitive procedures to test for risks to the environment and human and animal health. The appalling regulatory system in place for monitoring and oversight will have to be discarded and replaced with one which is technically competent, transparent, accountable and sensitive to public concerns.

For a country of India’s size and calibre, it is insupportable that the apex regulatory body, the Genetic Engineering Approval Committee (GEAC), is headed, not by a scientist of the highest technical competence, but by whichever IAS officer happens to be posted as the additional secretary in the Ministry of Environment and Forests ! In the last few months, three bureaucrats have come and gone as chairperson. The rest of the GEAC is equally bureaucratic, consisting of official positions (joint secretary….this ministry or the other ..), rather than knowledgeable people.

Setting our agenda

There must be a consultative, participatory process involving a wide range of scientists, social scientists and competent civil society organisations to deliberate on the GM issues that face the nation and the path we should take. The adoption of agricultural biotechnology can have far reaching implications for the health and welfare of an agriculture dependent country. There are serious socio-economic concerns and concerns about the impact of agri-biotechnology on the environment and human and animal health. These complex and controversial technologies cannot continue to be administered by a handful of people lacking relevant skills and technical competence to assess biotechnology. It is a disconcerting fact that the larger academic and scientific community including the Academies of Science are not included in biotechnology policy development, which is being determined, almost exclusively by a small group of people in the Department of Biotechnology.

Priorities for the development of agricultural biotechnologies must be based on indigenous needs. Yet the Indian establishment is satisfied copying the concepts and structures of regulatory and oversight systems straight from the industrial countries, without any effort to incorporate developing country perspectives and sensitivities. The research priorities in agricultural biotechnology are based on what the industrial countries have developed, and very little has been done to evolve an indigenous set of priorities based on the needs of small farmers and local agricultural production systems. Amidst this confusion, a variety of biotechnologies and their products are being commercialised by regulatory agencies in this country.

A targeted and informed biotechnology policy may help to solve some of our agricultural problems. However, if policy is ad hoc and ill informed, as is the case now, it could end up hurting rather than helping farmers. With such a high stake in agricultural technologies and the need for agricultural development, India can ill afford to be careless or irresponsible in bringing about biotechnology intervention in agricultural development.

Ability to handle GM technology

In India, the commercial approval granted to Bt cotton, is a good example to demonstrate what can go wrong when ad hoc, ill informed decisions substitute for a sound policy framework.

India permitted commercial release of its first ever GM crop, Bt cotton, in the year 2002-2003. The Bt cotton varieties belonging to Mahyco-Monsanto are reported to have fared poorly in most of the locations where they were grown. The decision to approve these Bt cotton varieties was widely criticised at the time, by civil society groups like Gene Campaign because the varieties were known to be poor performers with respect to yield but the agencies went ahead, refusing to acknowledge the public’s concerns. When the Bt cotton harvest came in, first the government made statements that the harvest was very promising, then it admitted poor performance and has now asked for a state-wise review to assess the reasons for the poor performance.

As all this unfolded, an illegal variety of Bt cotton, Navbharat 151, which was detected over three years ago, continues to be planted season after season in several variations, making a mockery of the regulatory system’s ability to take any action. In fact, producing illegal Bt cotton varieties has turned into something of a cottage industry in Gujarat and seeds of this unauthorised variety are being sold in Punjab, Haryana, Tamil Nadu and probably elsewhere too, cocking a snook at the GEAC and making it look very inadequate indeed.

Also cause for concern is the gung ho attitude to transgenic technology on the part of science administrators, specially those in the Department of Biotechnology. The decision-makers exhibit a keen, if misplaced desire to join the ‘GM Club’ and belong to a supposedly elite community that dabbles in high-tech research. This desire to do what the developed countries are doing has led to research agendas picked from the west and introduction of crops developed for industrial agriculture. Decisions are not taken on the basis of indigenous needs but on what line of copy cat research will most quickly show some results. Tragically, funds are being diverted to these areas at the cost of research on other important branches of agriculture like classical agronomy, water management and systems based agricultural research.

The economics of Bt cotton cultivation

Field studies conducted by various agencies including Gene Campaign and the Andhra Pradesh State Agricultural department show that the economics of cultivating Bt cotton is clearly not in favour of farmers. The seed is about four times more expensive than good local hybrids. The difference in the price of seed is approximately Rs. 1200 per (450 gm) bag, which is needed to plant an acre. As against this, savings on pesticide were meagre, averaging Rs. 217 per acre because spraying had to be done to control other pests chiefly pink bollworm, which is a significant cotton pest in India. The Bt toxin does not affect pink bollworm.

As Table 1 shows, the investment per acre is much higher for Bt cotton than for non-Bt cotton varieties. The Bt cotton farmer had to invest on average, Rs. 983 more per acre than his non-Bt counterpart.

Table 1: Comparative Investment in Bt. and non-Bt. cotton in Rs./acre


Non-Bt. cotton

Bt. cotton





2,800 (1500 - 4000)

2,800 (1500 - 4000)


1,533 (600 - 2500)

1,316 (500 - 2200)




(Gene Campaign, 2003)

Yield /acre of Bt cotton was lower than non-Bt cotton and the cotton was of poorer quality thus fetching a lower price per quintal. Added to this was the higher investment in Bt cotton fields. The net result was significantly poor results from Bt cotton which are reflected in the data on comparative incomes, in Table 2.

Table 2: Comparative income from Bt. and non-Bt. Cotton

Farm Type

Non-Bt. Cotton

Bt. Cotton

Farmers (%)

Income/acre (Rs.)

Net Profit /acre (Rs.)

Farmers ( %)

Income (Rs.)

Net Profit/ acre (Rs.)

Low Yielding







Medium Yielding







High Yielding







(Gene Campaign, 2003)

Net profit from Bt cotton was lower per acre compared to non-Bt cotton in all types of fields (low to high yielding). In fact, 60 % of the farmers cultivating Bt cotton were not even able to recover their investment and incurred losses averaging Rs. 79 per acre.

Regulators violate the law

One of the most shocking revelations of the field study conducted by Gene Campaign was the fact that neither State Level nor District Level Committees had been set up in areas where Bt cotton was being commercially grown. This is a breach of law and a direct violation of the prescribed rules for the manufacture, use, import, export and storage of hazardous micro-organisms and genetically engineered organisms and cells, under the Environment Protection Act, 1989. This deliberate violation of the law by the regulators themselves does not help to build confidence in their ability to administer this new technology with any degree of responsibility. It also sends the wrong signals that rules do not have to be adhered to.

Investing in GM products but not in monitoring them

Whereas agriculture research, product development and marketing receive substantial budgetary support, regulatory, monitoring and evaluation systems are not well funded. This neglect has led to weak and ineffectual regulatory systems. Given the lack of funds, research establishments in India tend to rely increasingly on the companies (whose products are to be tested) to pick up the tab for the monitoring and evaluation exercise. This introduction of the vested interest into what should be a transparent and unbiased process is decidedly undesirable and unethical and will lead to decisions in favour of the companies, not farmers.

Apart from the meagre resources for comprehensive monitoring and evaluation, India also lacks skilled manpower with experience in biosafety, risk assessment and risk management. Before such skills can be built up, the science administrators are pushing for the adoption of GM crops and food propelled by a mixture of external pressure and hasty zeal. This reckless disregard for the crisis that could emerge from a combination of resource constraints, developmental needs and the ecological vulnerability of regions, that are the centres of origin and diversity of major crop plants, is unnerving.

Protecting Centres of Origin and diversity

Centres of origin of crop plants and areas of diversity merit special attention and must be treated with extreme caution. Genetic contamination of germplasm found in centres of origin is a risk that cannot be taken since the consequences of something going wrong would be very grave indeed and the impact on global food security would be incalculable. India is a centre of origin for many crop plants , most importantly rice.

There is sufficient scientific evidence to show that gene flow among rice varieties is substantial. Wild relatives of rice cross with cultivated rice and many of these wild relatives are known weeds. It is also known that ‘intermediate’ forms between wild and cultivated rice are found in regions of high genetic diversity. Gene transfer from GM rice to wild relatives is therefore going to happen. If transgenes enhance the weediness of a weedy relative or create new weeds, the weed problem in rice cultivation would exacerbate several fold.

Until there is a reasonable amount of data about the likely environmental impact of gene transfer from GM rice, in this major centre of diversity, it would be prudent not to release transgenic rice in India. According to a World Bank briefing paper on rice, no studies have been done on gene flow and its impact on wild and cultivated rice germplasm and there is no sound empirical data to make any assessments. As a major centre of rice diversity, India must invoke the precautionary principle, in its own interest and the interest of global food security.

The caution exercised by Mexico with respect to corn, for which it is a centre of origin and diversity, is a good example for India to follow. Mexico which had placed a ban on growing transgenic corn, brought another ban which included even research on transgenic corn, when the contamination with GM corn was detected in ordinary, non-GM corn fields in 2001.

Why the herbicide tolerance trait should be banned in India

Traits that India needs for its agriculture should be understood through a needs assessment exercise but drought tolerance and increased nitrogen fixation will certainly be high on the list. Equally, some traits will be considered highly undesirable. Prominent among these is herbicide tolerance, a trait that should be banned in India. This technology based on a proprietary herbicide claims its goal is to “reduce drudgery” on the farm. This claim has little to do with rural reality in most parts of the developing world. In India weeding is an assured avenue for earning casual wages in rural areas, especially for women. Sometimes it is the only source of wages. What is harvested in the form of weeds fulfils two important nutritional roles. The plants that constitute weeds in fields are largely nutritious leafy greens, which are a valued source of nutrition in the family’s diet. What is not consumed by the family, serves as fodder for livestock that rural families maintain as additional income sources.

ADD FOTO- Any agricultural field showing natural vegetation around/ front of it, to show how closely the crop and the medicinal plants are found , to make the point that spraying herbicides may protect the crop but will destroy the vegetation.

Many of these so-called weeds are actually medicinal plants, of great value to rural and adivasi communities and their tradition of indigenous healing practices. According to the WHO, 70% of India is dependent on the indigenous systems of medicine for its health care needs. This system is dependent on the local flora in each area, which the local vaids and hakims use to make their medicines. Senior vaids and hakims who are members of the Medicinal Plant Board of India have been pleading for less destructive agricultural practices since this leads to incalculable harm to local medicinal flora. The trait herbicide tolerance delivers double profits for the company that owns the technology, first through the sale of expensive proprietary seeds and then through the exclusive use of proprietary herbicides. All it does for farm men and women in India is destroy the basis of added nutrition, affordable health care and an income source. That is why it must be banned.

Incorporating Equity in Intellectual Property Rights systems

Agriculture biotechnology is a sector where patent activity is very high. The current regimes of intellectual property rights (IPR) are a serious impediment to the transfer of technology to developing countries. Most of the basic technologies of genetic modification are patented and the larger companies own these patents. These companies are reluctant to license them to developing country organisations at an affordable cost. On their part, developing countries are at a disadvantage when negotiating license terms from patent holders, not having learnt to bargain and being vulnerable to pressures. An important aspect of India’s GM policy will have to be the incorporation of equity in IPR systems.

The claim for equity derives from the fact that when a transgenic variety is created, there are many more players involved than is acknowledged in the patent. A number of plant varieties are used in the breeding of a GM variety. These include land races, varieties bred by farmers and those bred by public research institutions. That is the reason why patents, that seek to appropriate the entire variety for contributing a minor share, are iniquitous and unjust. In the creation of a new plant variety, the first 80 to 90 steps are contributed by farming communities, the rest by scientists. Equity and justice demand that an IPR regime acknowledge Farmers Rights along with Breeders’ Rights. This is what the Indian law on plant variety protection, the Plant Variety Protection and Farmers Rights Act, 2001, attempts to do. The law acknowledges that farmers are also breeders. It has provisions that if farmer varieties are used in the breeding of other varieties, a certain amount of money will have to be paid for the use of these varieties, into a National Gene Fund, which will be used by farmers. The Indian law has also banned the use of the GURT (Terminator) technologies because this would totally negate the rights of farmers by denying them access to seeds in the creation of which they have played a significant role.