NOTE: The Government of India and its apex GM regulatory body, the GEAC, have been alerted to the need to immediately confiscate and destroy all seed stocks of Bt brinjal, as well as making the crop developer solely liable for any contamination or leakage that occurs during the period of the Bt brinjal moratorium. Below the introductory e-mail is the letter to the GEAC on this issue from the Coalition for a GM-Free India.
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Subject: Immediate confiscation and destruction of Bt brinjal seed stock
From: Kavitha Kuruganti
To: This email address is being protected from spambots. You need JavaScript enabled to view it.
Cc: This email address is being protected from spambots. You need JavaScript enabled to view it.
Date: Thursday, 11 February, 2010, 16:08

Dear Dr Warrier,

Greetings!

On three occasions in the past few years, Bt Brinjal's crop developer Mahyco has been allowed to take up experimental seed production - on August 30th 2007, on January 31st 2008 and June 10th 2008.

In fact, a perusal of the ECI report in August 2007 or the 79th meeting of the GEAC does not show any express permission for seed production though this was allowed on August 30th 2007; Similarly, it is not clear where the January 31st 2008 permission emerged from, given that the 82nd GEAC meeting on 11th January 2008 does not reflect this decision.

Be that as it may, attached is a letter from representatives of many civil society groups requesting GEAC to immediately take stock of how much seed was produced (the minutes do not reflect the information on how many acres of production was permitted), what happened to the same, confiscate all such seed stock and planting material immediately and destroy the same in the presence of an independent observer.

We also demand that the GEAC immediately notify a liability clause on the crop developer that it will be solely liable (penalty, redressal and remediation clauses to be part of this) for any leakage or contamination that could happen during the moratorium period. This is the only way to prevent the kind of contamination and illegal cultivation that one has witnessed with the 2001 Bt Cotton illegal cultivation in Gujarat or the HT Cotton fiasco now.

We also demand that no open air trials be allowed during the moratorium period.

Thank you.

Kavitha
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To: Dr Ranjini Warrier,
Director and Member Secretary,
Genetic Engineering Approval Committee,
Ministry of Environment & Forests,
Paryavaran Bhawan, CGO Complex,
Lodhi Road, New Delhi 3.

February 11 2010

Dear Dr Warrier,

Sub: Immediate confiscation & destruction of all Bt Brinjal planting material & liability clause to be imposed on crop developer

Greetings! As the Government of India had imposed a moratorium on the release of Bt Brinjal, it becomes important and urgent to immediately confiscate all seed stock from the crop developer Mahyco and its consortium partners (UAS-Dharwad and TNAU-Coimbatore) immediately before any intentional or accidental leakage or contamination happens. Past experience with Bt Cotton and HT Cotton demonstrates very clearly that regulatory capabilities to take care of such untoward leakage and contamination is extremely low and the way to prevent it is immediate confiscation and destruction of all physical planting material (seeds, seedlings etc.).

Further, a notification or order be issued with a liability clause fixed on the crop developer that the crop developer will be held solely liable for any leakage or contamination during the period of moratorium. Such a liability should include penal clauses and redressal and remediation clauses too, as required. This should be done immediately.

Further, no open air trials should be permitted in the moratorium period to avoid any potential contamination.

These measures should be taken up also keeping in mind the industry strategy now seen in various parts of the world of "contaminate first, regulate or approve later".

Thank you.

Sincerely,

Sd/- by the signatories below.

Cc: Hon'ble Minister for Environment & Forests, Govt of India.

1.    Afsar H Jafri, Focus on the Global South-India, New Delhi
2.    Arun Ambatipudi, Chetna Organic Farmers Association, Hyderabad
3.    Arun V, The Forest Way, Tiruvannamalai
4.    Aruna Kalahasti, Bhoomi Network, Bangalore
5.    Bharat Mansata, Vision Acre/Van Vadi, Maharashtra
6.    C R Jayaprakash, Nilgiris Wildlife & Environmental Association, Coimbatore
7.    C.Elumalai, Rural People’s Sangam, Tiruvannamalai
8.    David Amalanadane, Pharmacist, Tamil Nadu
9.    Deepika Kundaji, organic farmer and seed saver, Auroville
10.    Dilnavaz Variava, Sahayak Trust, Mumbai
11.    Dr G Sivaraman, Safe Food Alliance, Tamil Nadu
12.    Dr G V Ramanjaneyulu, Centre for Sustainable Agriculture, Hyderabad
13.    Dr John Devavaram, Resource Center for Participatory Development Studies, Madurai
14.    Dr Mira Shiva, Initiative for Health, Equity & Society and All India Drug Action Network
15.    Dr Parveen Amanullah, social activist, Patna
16.    Dr Radha Gopalan, Rishi Valley Education Centre, Madanapalle, Andhra Pradesh
17.    Dr Ramadhar (IAS), Former Chair, Bihar State Farmers’ Commission, Patna
18.    Dr Shreeram Padmadeo, Biotechnologist, Patna University
19.    Dr Sundaramurthy Thimmaiah, Agriculture scientist, Coimbatore
20.    Ganadhalu Srikanta, Journalist, Bangalore
21.    George Kutty, Bangalore Film Society
22.    Jagannath Chatterjee, Living Farms, Orissa
23.    Kapil Shah, Jatan Trust, Vadodara
24.    Kavitha Kuruganti, Kheti Virasat Mission, Punjab
25.    Kiran Kumar Vissa, Association for India’s Development (AID-India), Hyderabad
26.    Krishna Prasad, Sahaja Samruddha, Karnataka
27.    Kumar Vaidyalingam, GREDS, Cuddalore
28.    Lakshmi Devi Nair, Consumer, Bangalore
29.    Lavanya Devdas, AID-Bangalore
30.    M S Kombe, Dharamitra, Wardha
31.    M Shajudeen, Green Youth Foundation, Coimbatore
32.    Madhusudan Venkatesh, concerned citizen, Bangalore
33.    Nayani Nasa, Youth for Safe Food, New Delhi
34.    Nidhi Kaushik, CECOEDECON, Rajasthan
35.    Nirali Shah, Ahmedabad
36.    Pankaj Bhushan, GM-Free Bihar Movement
37.    Prakash H R, ARTIC, Srikakulam, Andhra Pradesh
38.    Preeti Patil, Vidya Varadhi Trust, Mumbai
39.    R Santhanam, Tamil Nadu
40.    Ramasubramanian, SAMANVAYA, Chennai
41.    Samprati Gada, Interior Designer, Mumbai
42.    Sandhya Nair, concerned citizen
43.    Sangita Sharma, Annadana Soil & Seed Savers Network, Bangalore
44.    Selva Ganapathy, AID-Delhi, New Delhi
45.    Selvam Ramasamy, Tamil Nadu Organic Farmers’ Association, Tamil Nadu
46.    Sheelu Francis, Tamil Nadu Women’s Collective, Chennai
47.    Shrawan Singhal, PhD Student, Austin, USA
48.    Shyam Ghate, CAPCON, Thane
49.    Suma Josson, Independent film maker, Mumbai
50.    Suresh Gupta, Environment expert, Muzaffarpur
51.    T P Raghunath, Pondicherry Science Forum
52.    Tejal V. and Vishweshwar Mathur, concerned citizens, Mumbai
53.    Usha S, Thanal, Trivandrum
54.    Utkarsh Sinha, Centre for Contemporary Studies & Research, Lucknow
55.    Vanaja Ramprasad, Green Foundation, Karnataka
56.    Vijay Karthik, IT professional, Bangalore
57.    Vinita Mansata, EarthCare Books, Kolkata
58.    Yudhvir Singh, Convenor, Coordination Committee of Indian Farmers’ Movement, Delhi