INSIGHT
This is not a critique of the GM tech-
Genetically Modified Mustard
and Indias Future
Pushpa M Bhargava
Genetically modified mustard, if
approved, will be the first such
food crop to be commercially
released in India. This will
open the floodgates for other
such crops making India one of
the largest users of genetically
modified crops in the world in
the next 10 to 12 years. Given that
its agriculture is largely in the
hands of multinational seed and
agrochemical companies, India
will end up bartering its freedom
for the benefit of a few and the
misery of the rest.
Pushpa M Bhargava (bhargava.pm@gmail.com)
is a nominee of the Supreme Court on the
Genetic Engineering Appraisal Committee
of the Ministry of Environment, Forest and
Climate Change and currently chairman of the
Southern Regional Centre of the Council for
Social Development.
40
G
enetic engineering (or modifica-
tion) technology is one of the
most powerful technologies in-
vented in the 20th century. It has made
drugs that were not available earlier,
such as human insulin, affordable. But
genetically modified (GM) crops pose
substantial risks to human, animal and
plant health, and to the environment
and biodiversity. These risks are ignored
by governments, especially by the United
States (US) government, as the techno-
logy can also benefit multinational cor-
porations (MNCs) and help acquire con-
trol of another countrys agriculture.
The Indian governments support to
GM-mustard ignores the scientific strength
of the opposition to it and merely makes
a show of following prescribed rules
and procedures.
Whosoever controls food production
around the world effectively controls the
world. To do so, one only needs to con-
trol production of seeds and agrochemi-
cals. For the latter, the system of intel-
lectual property rights (IPRs) applicable
to other chemical entities, which has
been in place for decades, is enough. To
control seed production, genetic engi-
neering or genetic modification has been
touted as the best possible approach
under the garb of providing an advan-
tage that no other technology would
appear to provide.
It is in this context that GM-mustard,
which is up for the Government of Indias
approval for commercial release, ac-
quires special significance. An approval
of GM-mustard(making it the first GM
food crop to be approved in India) would
open the window for other GM food
crops to rush in, eventually transferring
virtually our entire food production to
the largely US-controlled MNCs that have
the IPR for GM seeds and with whom we
would never be able to compete.
NOVEMBER 5, 2016
nology. It involves altering the genetic
make up of a living organisma micro-
organism, a plant or an animalin
such a way that it (and its progeny) is
able to perform a function that it was
unable to perform earlier. Thus, nor-
mally, a bacterium or yeast is incapable
of making human insulin, but a GM-bac-
terium or a GM-yeast in which the gene
for human insulin has been placed and
made to workthrough the process of
genetic engineeringwould produce
human insulin in commercially exploit-
able quantities.
There is, therefore, no problem in en-
couraging the use of this technology for
production of drugs such as human insulin
or human erythropoietinboth widely
usedas we can simply switch off the
production as and when we find that the
original objective is not being served.
But using this technology for producing
a GM plant is something else altogether.
For, once you release a plant in the envi-
ronment, it is virtually impossible to re-
call it, something you may want to do, if
it turns out to be deleterious to human,
animal or plant health, or harmful to the
environment or biodiversity. Water hya-
cinth and parthenium, which probably
came with the PL-480 wheat in the late
1950s and early 1960s are good examples.
Water hyacinth has choked our water-
bodies on innumerable occasions, and
parthenium (popularly known as Con-
gress grass) has led to allergy in a large
number of cases all over the country.
India has been, perhaps, the only de-
veloping country which has been aware
of the possible benefits and risks of ge-
netically modified organisms (GMOs)
from the time this technology, for which
Paul Berg shared the 1980 Nobel Prize
for Chemistry, was developed. The term
genetic engineering was used for the
first time in India (and, perhaps, for the
first time in the modern context, any-
where) in a syndicated article by me
which was also published in The Mother-
land of 11 March 1973. I used the possible
potential of this technology as an argu-
ment for setting up one of Indias most
prestigious laboratories, the Centre for
vol lI nos 44 & 45 EPW Economic & Political Weekly

Cellular and Molecular Biology (CCMB) at
Hyderabad in 1977. I also chaired the
first national committee on genetic engi-
neering and molecular biology in the 1980s.
K S N Prasad of CCMB was the first in
the country to be trained in this techno-
logy. Later, he produced Indias first GM
productShanvac-B, Shantha Biotechnics
Hepatitis B-Vaccine in CCMB. This brought
down the price of the vaccine more than
50-fold.
Bt-cotton and Bt-brinjal
Bt-cotton which contains a gene for an
insecticidal protein from bacillus thurin-
giensis, a soil bacterium, was the first and
the last GM plant released in India for
commercial use. It was released in 2002
at a time when civil society was unaware
of the implications. The Department of
Biotechnology (DBT) (I had a role in the
setting up DBT and I was a member of the
first Scientific Advisory Committee) was
a key player in the release of Bt-cotton.
Unfortunately, I was unaware of its release.
In this context, it is important to note
that no GM plant has been released in India
for commercial cultivation in the last 14
years. Civil society groups have alleged
that both the Review Committee on Genetic
Modification (RCGM) of the DBT and the
Genetic Engineering Approval Commit-
tee (GEAC) of the Ministry of Environment,
Forest and Climate Change (MoEFCC), the
two key players in approving open (com-
mercial) release of a GMO, have many
members that have a conflict of interest.
It is noteworthy that the GEAC had
cleared the commercial release of Bt-brin-
jal developed by MahycoMonsanto Bio-
tech, in its meeting on 14 October 2009,
but the then Minister for Environment and
Forests, Jairam Ramesh, deferred any
decision on its release for the next three
to four months to allow time for civil so-
ciety, including affected groups such as
farmers, and interested scientists from
India and abroad, to go through the
biosafety dossier presented to the GEAC by
its promoters (MahycoMonsanto) and to
hold a public consultation in major cities.
This resulted in the announcement of
an indefinite moratorium on Bt-brinjals
open release. Rameshs statement (with
appendices) issued on this occasion (9 Feb-
ruary 2010) is one of the finest documents
Economic & Political Weekly EPW NOVEMBER 5, 2016
issued by any government in independent
India. It is noteworthy that he had the
courage to do so in spite of the immense
pressure on him by the then Prime Minister
Manmohan Singh and his government
to clear the open release of Bt-brinjal.
Ramesh paid the price for being scientific,
fair and courageous: he was transferred!
It is well-known that the United Progres-
sive Alliance government was under
pressure from the US government to
have Bt-brinjal cleared.
Neglected Biosafety Measures
I emphasise here four more points that
argue against the open release of GM-
crops, without adequate thought and
proper testing for biosafety which no
approved GM crop has gone through
anywhere.
(i) Success of Bt-cotton is overempha-
sised. First, Bt-cotton has failed in rain-
fed areas which represent two-thirds of
cotton growing areas in India; it has suc-
ceeded only in irrigated areas. Second,
when talking of success of Bt-cotton, a
hybrid is being compared with a variety.
Third, similar yields as with Bt-cotton
have been obtained with non-Bt-cotton
grown under specified conditions. Fourth,
in several places such as Gujarat, pests
have developed resistance to Bt-protein.
Fifth, in Rajasthan and some places in
Punjab, other harmful insects such as
mealy bug on which Bt-protein does not
work, have appeared. Sixth, several
thousand cattle died in Andhra Pradesh,
after foraging on remnants of Bt-cotton
plants. And lastly, a number of Bt-cotton
farmers committed suicide because of
bad yields and having to pay a high price
for the seeds.
(ii) Proponents of the GM crops say that
GM food has been consumed in the US
now for 16 years and not shown any
adverse impact. The fact is that concur-
rently with the consumption of such food
in the US, there has been an increase in
the incidence of gastrointestinal tract
disorders and cases of allergy. Although
it does not establish a cause and effect
relationship, it certainly makes it possi-
bleeven probable in view of some
30-odd reliable animal studies based on
GM food and that have been published in
respectable journals.
vol lI nos 44 & 45
INSIGHT
(iii) The GM crops and/or food are used
only in some 20 countries (out of nearly
200) around the world, the US accounting
for two-thirds of the useand Canada,
Argentina and Brazil being the other
main ones.
(iv) An appropriate and adequate testing
of a GM plant has never been done any-
where in the world before its open re-
lease. For example, it has not been tested
for chronic toxicity before its release in
the environment. Where other highly re-
sponsible scientists have done this test-
ing and showed notable adverse effects
of genetic modification, their results
have been mocked by those who sup-
ported the release.
It is against this background that the
case of GM-mustard developed by a team
led by Deepak Pental, former Vice Chan-
cellor of the Delhi University, should be
looked at. I consider Pental to be a good
scientist though, I believe, he has slipped
up in this case. Following my request to
the GEAC, he sent me eight volumes (total-
ling 3,126 pages) of his biosafety data on
GM-mustard and I have kept my boy-scout
promise to him that I shall not share it
with anyone else. But let me get back to
events as they occurred, in sequence.
Governments Strategy
First, I do not understand on what basis
the RCGM, to which Pentals application
seeking open release was first submitted
in accordance with the law of the coun-
try, cleared the GM-mustard from the
biosafety point of view and forwarded
the application to the GEAC.
From here onwardsas all the evi-
dence suggeststhere have been two
streams of operation. In the first stream,
the Prime Minister, the environment
minister, the chairperson of the GEAC,
and all others involved officially, had
already taken a decision to approve the
GM-mustard, irrespective of any other
consideration and in defiance of all scien-
tific evidence that may be against it. So,
there have been newspaper reports from
time to time saying that the GEAC has ap-
proved Pentals GM-mustard when it actu-
ally had not. The MoEFCCand it goes to
the credit of the ministryat least on
one occasion, contradicted such a press
report, but such reports continued to
41
INSIGHT
appear in one form or another. For ex-
ample, the MoEFCC minister Anil Madhav
Dave, said, you will get to know about our
view on GM-mustard very soon (Das and
Bharadwaj 2016). The report continues,
Environment Minister, Anil Madhav
Dave, said India would also come up
with other GM food as its population
increases and available land shrinks.
And, Allowing GM-mustard is seen as
critical to Prime Minister Narendra Modis
goal of attaining self-sufficiency in edible
oil. Practically speaking, attaining self-
sufficiency in edible oil cannot bear any
direct relationship to GM-mustard, even
if it produces 30% more oil, as men-
tioned in Reuters report.
Even though the Bharatiya Janata Party
(BJP) government has been hell-bent on
permitting the open release of GM-mustard
if only to please the US and the US-
based MNCs involvedit has wisely seen
no harm in trying to appear fair.
Conflict of Interest
The GEAC is aware that many of its reput-
ed members have a conflict of interest
like the RCGMwhich is to the advantage
of the government. So a subcommittee of
seven memberswith at least three hav-
ing a clear conflict of interestchaired by
the vice-chairman of the GEAC, is appoint-
ed to look at Pentals GM-mustard data and
conclusions. The subcommittee, as ex-
pected, clears the GM-mustard uncondi-
tionally after some four meetings lasting
at most few hours each, during which the
subcommittee is supposed to have had a
careful look at least 3,126 pages of data,
experimental details and related material.
So, as far as most of the members of GEAC
are concerned, the entire data has been
carefully looked at by an expert commit-
tee, and the committee has declared Pen-
tals GM-mustard safe for human and ani-
mal health and for environment and bio-
diversity. What else can anyone want to
check or comment upon?
But, in our governments reckoning,
people can be contrary at times for no
reason! Serious and knowledgeable civil
society representatives, led by Kavitha
Kuruganti of the Alliance for Sustainable
and Holistic Agriculture (ASHA), who
were well aware of the functioning of
both the RCGM and GEAC, know from past
42
experience what the report of the sub-
committee would say and were, therefore,
far from satisfied. To quell their fears
and make them feel that their views and
concerns would be taken care of by the
subcommittee and GEAC, the following
eight forming the group1 (which we
would call KKG) led by Kavitha Kuruganti
were invited to make a presentation of
their concerns, queries and questions,
over two-hoursthe period they had
asked forat a special meeting of the
GEAC on 18 July convened at the instance
of the chairperson of GEAC, Amita Prasad,
additional secretary in the MoEFCC.
In my opinion, the KKG collectively did
an incredible job of scientific analysis on
the basis of the scanty information on
GM-mustard available to it. The group
had almost certainly spent, individually
and collectively, much more time on pre-
paring its comments than the subcom-
mittee probably did on looking at and
analysing the entire data. There were no
comments by anyone after the presenta-
tion on 18 July as, perhaps, most members
of the GEAC knew that no substantial
action was likely to be taken on the com-
ments of the KKG and the decision had
already been taken by the government to
approve the GM-mustard. What happened
subsequently confirmed that the 18 July
meeting was meant only to satisfy what
has been termed as the anti-GM lobby.
It was a politicaland not a scientific
move to neutralise what has been per-
ceived by the pro-GM MoEFCC as the
anti-GM-mustard lobby.
At the next, 130th meeting of the GEAC
on 11 August (a one-page note ostensibly
summarising what was said by the KKG on
18 July, prepared by S R Rao of DBT, was
circulated to the GEAC members, not for
discussion, but for information. It was sup-
posed to be discussed by the subcommittee.
The Note and Follow-up
I found that Raos note had 12 points
all inadequately coveredwith more than
90% of the major and important issues
raised by the KKG on the 18 July, totally
ignored. Therefore, on the 24 August, I
sent the following letter to Amita Prasad.
Dear Dr Prasad,
At the last (130th) GEAC meeting held on 11th
August 2016, Dr S R Rao of the Department of
NOVEMBER 5, 2016
Biotechnology gave us a list of 12 issues (An-
nexure 1) that, in his opinion, were presented
by the team led by Ms Kavitha Kuruganti
during the two-hour special meeting of GEAC
on 18th July 2016, regarding GM-mustard.
While I greatly appreciated Dr Raos efforts
to summarise the two-hour presentation in
less than a page, I felt that Dr Rao had not
covered all the important implications of
the presentation by the above team, and
that many important points mentioned by
the team were not included in the 12 points
listed by Dr S R Rao which are recalled in
Annexure 1. I, therefore, went through the
material given to the members of the GEAC
by Ms Kavitha Kuruganti, and also had a con-
sultation with her and Shri Kapil Shah who
was a member of her team. With the help of
Ms. Kavitha Kuruganti and Shri Kapil Shah, I
prepared two documents. The first one (An-
nexure 2) is a point-by-point commentary on
the 12-point summary of Dr S R Rao. The sec-
ond one (Annexure 3) is a list of important
points presented by Ms. Kavitha Kurugantis
team but not covered at all by Dr Rao.
I would appreciate it very much if the GEAC
office will consider circulating this letter to
all the members of the GEAC.
As the above letter was not circulated
by Prasad to members of the GEAC, I did
so on 6 September, following which, on
7 September, it was also circulated to
the GEAC members by the GEAC office,
apparently at the instructions of Prasad.
It is interesting that no member of the
GEAC has responded to it till now. And,
as predicted, no action whatsoever has
been taken on any of serious points
raised by the KKG.
At the meeting of the GEAC held on 11
August, a brief summary of what was
purported to be the proceedings of the
subcommitteethat is, an assessment
of Pentals GM-mustard for food and
environment safetywas circulated. The
five-page summary was titled, Report
on Environmental Release of Genetically
Engineered Mustard Hybrid DMH-11 and
Use of Parental Events for Development
of New Generation Hybrids. It is impor-
tant to note that only a summaryand
not the entire documentwas circulated,
and even then, no time was allotted for
reading or discussing it, at the meeting
of the GEAC.
I assumed that the full report of the sub-
committee will be made available to the
members of GEAC later, and that there
would be enough time available for the
members to go through it and then discuss
it. This never happened, just as no action
vol lI nos 44 & 45 EPW Economic & Political Weekly

was taken on the points raised by the KKG
at the special meeting of the GEAC on 18
July, that were also listed in my letter of 23
August to the chairperson of GEAC. After
all, the decision to permit open release of
GM-mustard had already been taken.
Report on Ministrys Website
Since the environmental minister had
reassured Kuruganti and her colleagues
at an earlier meeting that the views of
civil society would be sought before a final
decision was taken about the open release
of GM-mustard, the ministry put on its
website a document titled Assessment of
Food and Environmental Safety (AFES)
for Environmental Release of Genetically
Engineered Mustard (Brassica guncea)
hybrid DMH-11 and use of parental events
(Varuna bn3.6 and EH2 modbs 2.99) for
development of new generation hybrids.
This was supposed to be the report of the
subcommittee, a summary of which was
circulated at the 130th meeting of the
GEAC on 11 August. It was very embarrass-
ing for me to say as a nominee of the
Supreme Court on GEAC that I had not seen
the report when I was asked by the media
on 5 and 6 September about my opinion of
the report. As it was supposed to be the
report of a subcommittee appointed by
the GEAC, the members of GEAC had the
first right to see and comment on it.
Incidentally, it seems quite possible
even probablethat the subcommittee
did not write the report. Such a report
would generally have the names of its
members, the dates on which the meet-
ings of the subcommittee were held, ac-
knowledgement of those who helped, and
signatures of the subcommittee members.
The report has none of these; it is not
even mentioned as to whose report it is!
As stated earlier, the subcommittee had
just four meetings. For a seven-member
group to go through at least 3,126 pages
of data contained in eight large volumes
and write a 133 page report complete
with references, in such a short time, is a
virtually impossible task.
It is, therefore likely that the report
has been largely written by Pental or
someone from the Department of Bio-
technology or Environment! It is also
quite possible that the report does not
represent the views of all the members
Economic & Political Weekly EPW NOVEMBER 5, 2016
of the subcommittee. It may have been
written by one, pro-GM and pro-govern-
ment member of the subcommittee;
therefore, it does not have the names. As
the decision to approve the GM-mustard
was taken before the subcommittee was
appointed, nothing that would argue
against this decision could be permitted
by the government. As already men-
tioned, a number of members of GEAC
(thus of the subcommittee) have a con-
flict of interest, and others (exceptions
granted) may not, for various reasons,
want to oppose the government.
It is interesting that the minutes of the
130th meeting of GEAC held on 11 August,
say, GEAC reviewed this (the AFES report
that is on the MoEFCCs website) and
suggested that the report may be placed
on the website for a period of 30 days.
What has been particularly alarming is
the impunity with which the MoEFCC has
defied the orders of the Central Informa-
tion Commission to make all the biosafety
data publicso much so that the Infor-
mation Commissioner, Sridhar Acharyu-
lu, had to send a show cause notice to the
MoEFCC on 12 August for not following
the orders of the commission. So the
data, which alone in most cases can settle
scientific or technical issues, has not been
put in the public domain. The notice on
the ministrys website says that if you
want to have a look at the data you may
call (but no telephone number is given)
and, by prior appointment, visit the
ministry where you may have a look at
the data, but not copy it. Imagine anyone
from outside Delhi spending time and
money to come to Delhi to get the infor-
mation on such conditions. Further, the
submission to the MoEFCC in response to
what has been put on the website must
follow a format that has been prescribed.
You may not ask any questions outside of
that format and outside the areas defined
by the report. And the time given was
one month (until 5 October 2016).
Conclusions
I have submitted some 25 questions and
queries in response to the report on
the ministrys website. I do not believe
anyone (including me) will get a reply.
At the end of a reasonable period after
5 October 2016, a statement would be
vol lI nos 44 & 45
INSIGHT
issued by the ministry that the subcom-
mittee and GEAC have carefully looked
at all the comments, queries and ques-
tions, and recommends that permission
be granted for open (environmental) re-
lease of Pentals GM-mustard. Is this not
a sign of a dictatorial regime? What may
happen after that, I dare say, is unpre-
dictable. Many states like Kerala, Tamil
Nadu, Uttarakhand, Rajasthan, Madhya
Pradesh, Chhattisgarh, Bihar, West Bengal,
Odisha, Andhra Pradesh and Telangana
have said that they will not permit GM-
crops. Further, the BJP is being constantly
reminded that in its election manifesto,
it had aligned itself strongly with the
anti-GMO lobby. And to throw more
spanners in the work, an influential
farmers union affiliated to the Rashtriya
Swayamsevak Sangh has been opposing
GM-crops for many years.
What is sure is that if GM-mustard is
approved, and the approval becomes ef-
fective, the floodgates for other GM-
crops would open and India may emerge
as the largest user of GM-crops in the
world in the next 10 to 12 years with its
agriculture largely in the hands of multi-
national seed and agrochemical produc-
ing companiesthat is, by proxy, in the
hands of the US. We would have then
bartered our freedom for advantage to a
few and misery for the rest.
In a way, GM-mustard holds the key to
our futureunless all concerned directly
such as farmers, come together and
lodge a massive protest as happened
with Bt brinjal in 200910.
Note
1 (1) Kavitha Kuruganti, (2) Rajesh Krishnan
(co-convener, coalition for a GM-free India, and
an organic farmer), (3) Debal Deb (ecologist),
(4) Sharad Pawar (Breeder and Fellow, Nation-
al Academy of Agricultural Sciences), (5) Kapil
Shah (National Secretary, Organic Farming
Association of India), (6) Rampal Jat (presi-
dent, Kisan Mahapanchayat), (7) Yudhvir Singh
(convener, Indian Coordination Committee of
Farmers Movements), and (8) Ananthoo (Safe
Food Alliance).
ReferenceS
Bhargava, P M (1973): Fantastic Strides in Bio-
chemistry, The Motherland, p 5, 11 March,
New Delhi.
Das, N Krishna and Mayank Bharadwaj (2016): In-
terviewIndia Soon to Make GM Mustard
Stance Public, Develop More Varieties, Reu-
ters, 2 September, http://af.reuters.com/arti-
cle/commoditiesNews/idAFL3N1BD2KJ.
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