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by Kavitha

Submission to Competition Commission of India, seeking to stop Bayer’s acquisition of Monsanto in India

4:48 pm in News by Kavitha

To:                                                                                           January 17th, 2018

The Secretary,

Competition Commission of India,

18-20, 7th Floor, Hindustan Times House,

Kasturba Gandhi Marg,

New Delhi 110001



Dear Madam/Sir,

Sub: Our objection to the proposed combination between Bayer AG and Monsanto Company – please disallow it – reg.

Greetings! We introduce ourselves as representatives of various organisations that work with farmers (farmer unions as well as farmers’ collectives), as well as citizens of India who have been doing our best to support sovereign and sustainable farm livelihoods.

We recognize, and are aware that big agri-business corporations use all the means at their disposal, whether it be IPR laws or technologies like hybrid and Genetic Use Restriction Technology (GURT) or market maneuvers like the proposed combination between Bayer and Monsanto, to ensure exclusive monopolistic markets. In their pursuit to do so, they will not hesitate to sue farmers or governments or other corporations in the national seed industry, as has been experienced in India as well as elsewhere. This has a direct bearing on the livelihoods of millions of our citizens, who are already teetering between life and death as the number of farm suicides in the country shows.

At the outset, we believe that the 15 day notice provided by the Commission for public participation in its inquiry process as per Section 20 of the Competition Act 2002, is too short for meaningful public participation, and therefore, urge you to extend the deadline provided.

Anti-people activities of these corporations:

It is not out of place to point out that both Bayer and Monsanto have long ignominious histories of anti-people activities. Monsanto, for instance, is known to have sued, fined and jailed farmers in countries of North America in the name of patent infringement.

CCI’s past findings on Monsanto:

CCI is already familiar with the practices adopted by corporations like Monsanto when it studied the subject of Bt cotton and royalty/licensing fees charges in the country, in 2006-07 as MRTPC (Monopolies and Restrictive Trade Practices Commission) with its interim order of 11/5/2006, and in the recent past as CCI, when the DG was asked to investigate further, after the Commission held that the conduct of Mahyco Monsanto Biotech Limited prima facie appears to be in violation of Section 4 of the Competition Act 2002. (

CCI should look at the cumulative picture:

The 3 mega-combinations in the agri-business sector including that of Dow and DuPont and ChemChina’s merger with Syngenta, in addition to Bayer’s acquisition of Monsanto, are going to result in a concentration of 60% of global market of proprietary seeds and agri-chemicals in the hands of 3 entities, which is effectively buying up competition.

Like in the case of Environment Impact Assessment where cumulative impact is assessed, the Competition Commission of India also should assess this case in the context of two other mega mergers/combinations and thereby, the cumulative adverse effect on competition.


Bayer and Monsanto are already the biggest players in the agro-chemical and seed technology markets. The point to be noted is that there could be a chain of linked products brought in, like herbicide tolerant GMOs, for instance, where along with seeds, an associated proprietary herbicide is also marketed by the same entity. This needs to be explored too, with additional information sought on GMO products in the pipeline for these companies.

CCI would be familiar with a new study released by University College, London (UCL) on World Food Day (October 16 2017) which concluded that a Combination between Bayer and Monsanto would reduce competition[1]. The research gave five main reasons why this would happen: (a) High market concentration (just 3 corporations would own and sell about 64% of the world’s pesticides/herbicides and 60% of the world’s patented seeds); (b) Entrenched market power (a large number of patents being held by Bayer and Monsanto); (c) Increased prices (due to collusive pricing between small set of market players) and reduced choices for farmers; (d) Locking farmers in (how farmers would be locked into a value chain of products including digital farming and other IT platforms) and (e) reduced competition and innovation. The study delineates how these mega-consolidation between major players will make farmers dependent and vulnerable to price hikes (which is indeed a reality world-over and in India too). The study clearly shows that asset selling or divestiture will not resolve the problem of competition diminishing, given the intense concentration of the markets related to seed, pesticides (insecticides, herbicides, seed treatment chemicals, fungicides etc., included) and GM-trait-selling.

CCI would also be aware of the latest developments with regard to European Commission’s investigations into the proposed combination where formal objections were filed by the European Commissioner for Competition, after very detailed investigations last year.

Why this Bayer Monsanto Combination is a matter of great concern:

The concern is with regard to (exorbitant) prices as well as (lack of) choices for farmers both in terms of seeds and pesticides. With competition effectively wiped out, farmers who do not have their own seeds saved will be dependent on these corporations and their cost of cultivation is likely to shoot up. This then has implications for indebtedness as well as farm suicides associated with increased debt burden due to increasing cost of cultivation, not supported by (unremunerative) markets.

The lack of choices will also have serious environmental ramifications for the country, with monocropping being the result of such a situation of lack of competition. Lack of choices for farmers will also mean lack of choices for consumers. Increased cost of cultivation for farmers could also translate into increased food prices for consumers.

It is also apparent that the lobbying power of these mega-corporations will be such that farmers’ interests are not likely to prevail when it comes to individual instances of serious losses or violations with regard to anti-competition rules. State governments in particular, who bear the brunt of such losses incurred by farmers, are neither empowered nor made responsible in any such scenario, even though Agriculture is a State subject as per the Constitution of India. This is of course unfair and unconstitutional.


  1. At several locations, Bayer justifies this combination and tries to assure the regulator that competition will not be adversely affected, by citing its divestment deals related to Glufosinate Ammonium (herbicides) and certain transgenic technology traits, with BASF. It is apparent that the CCI should be able to study all the details of such an agreement between BASF and Bayer before it can take a call on implications for this Bayer Monsanto combination too. It is also apparent that the Competition Commission has to run a similar process for public consultation, before taking a final view on the BASF-Bayer agreement implications.

Needless to say, the same applies for Monsanto’s sale of its cotton seed business to Tierra Agrotech Private Limited.

  1. As mentioned already, this combination’s potential adverse effect on competition has to be assessed in cumulative fashion, by studying this along with other (mega) combinations taking place.
  2. Form IV clearly shows that these two entities certainly have a significant overlap in the vegetable seeds market and the subsequent explanations in Section VIII of Form IV notwithstanding, this would have a significant adverse impact on competition, and thereby choices for farmers, affordability of products, and their profitability (livelihoods).
  3. Form IV does not provide all details required to make a comprehensive assessment about potential adverse effect on competition. For instance, CCI has to also consider parameters other than current market shares for different crop segments, like patents and any data exclusivity held by these two entities and their combined entity. Unless this is done specifically for those proprietary products which are giving them the largest market segments, nothing significant can be concluded from the submission made by these companies on effect on “nature and extent of innovation”.
  4. In certain markets like transgenic technological traits, it is important to study what is in the regulatory pipeline with India’s Genetic Engineering Appraisal Committee (GEAC) and Review Committee on Genetic Manipulation (RCGM), since the advantage in that market segment comes from IPRs as well as being the first-one-in to fulfill biosafety requirements. In that sense, it is not just about products already in the market, but in the regulatory pipeline.
  5. It is also noted that the current market shares do not clearly specific if the percentage cited is in terms of volumes or value. This information might be important to decipher actual competition in the market. CCI has to ask details of the same.
  6. While parties such as Bayer submit information to the Competition Commission as though there is a wide choice available to consumers (who are farmers in this case) between competing products, it is apparent that MNCs have more attractive “junkets” and other aggressive marketing to offer to their distributors and retailers when it comes to promotion of sales of their products. These include trips to more exotic destinations, compared to what other companies have to offer. This also has a bearing on choices and competition.
  7. Market for Non Selective Herbicides in India: It is noted that data in Form IV pertains to 2015, whereas there has been a significant jump in the recent past in use of non-selective herbicides, aided by a large scale increase in illegal herbicide tolerant GM cotton, accompanied by large scale use of corresponding herbicide, once again in an unapproved/illegal fashion. This is a case for investigation for CCI, with or without the proposed combination. Therefore, the reporting of Monsanto’s market share of 20-25% in this segment has to be re-looked at.
  8. Market for licensing of traits and technology in Cotton (upstream market): CCI has already investigated twice into Monsanto’s (transgenic) traits and technology business in cotton and found it indulging in anti-competition behaviour. As Bayer acknowledges rightly in its Form IV submission to CCI, the proposed combination “merely leads to change of control from Monsanto to Bayer regarding Monsanto’s Bollgard II technology”! It is widely reported that it was the MNC seed lobby that stopped the Government of India’s notification with regard to regulation of licensing agreements, and therefore, it is incorrect for Bayer to say that the regulation significantly limits the commercial freedom of any owner of Bollgard II technology (the proposed regulation itself has been stymied successfully).

10. Downstream Market for Sale of Cotton Seeds: In terms of the downstream market of sale of cotton seeds, Bayer’s 0-5% has to be read along with Mahyco’s 0-5%, given the equity holding of Monsanto in Mahyco. Also, given the adverse developments with many licensees with regard to the downstream market for the production and sale of GM cotton seeds, the market share in this segment could increase substantially for Bayer now. It is not out of place to draw the attention of the CCI to a recent letter written by an Indian seed companies’ association with regard to this matter:

11. Downstream Market for sale of rice seeds: Data pertains to 2015 and not the latest year (2017). Further, in assessing any AAEC here, Mahyco’s share in the market should also be considered. With or without the combination proposal, it is worthwhile for the CCI to investigate into the huge share of 40-45% in the rice hybrid seeds segment for Bayer and implications for competition.

12. Downstream Market for Corn Seeds: As already pointed out, CCI has to look at Monsanto’s edge with regard to upstream market for corn transgenic traits/technology given that its products are in an advanced stage in the regulatory pipeline with GEAC.

Further, at the downstream market end, Monsanto’s 15-20% has to be read along with Mahyco’s 0-5%. Combined with DowDuPont’s 20-25%, this is indeed a limited market for farmers.  We once again point out that the CCI has to take up a cumulative assessment, and not case by case. Meanwhile, more and more farmers are being shifted to hybrid corn cultivation by large scale devious programmes initiated by big Monsanto (like Project SunShine, Project Golden Rays etc.) through state government departments, forcing farmers to become dependent on external seed sources by luring them into hybrid corn cultivation through freebies in the initial years. Most of these programmes are being taken up in adivasi/tribal pockets where livelihoods are precarious, to say the least. Our fact finding reports on these programmes are present here: This major expansion of hybrid corn cultivation (induced by mainly Monsanto based on inexplicable, unscientific reasons), in the context of these mega-mergers will induce great riskiness in the livelihoods of the most vulnerable farmers in the country.

13. Licensing of Herbicide Tolerant Trait/Technologies: The Form IV submission by Bayer is not revealing about the advanced stage (in fact, in the penultimate stage and could come up for approval any time now) of HT GM seeds in corn that Monsanto has, in the regulatory pipeline with GEAC.

14. Market for Vegetable Seeds: In both the tables of (40) and (42), one for both OPV and hybrids combined and the latter for just hybrid seeds in vegetables, it is clear that there is already a monopoly for either Bayer or Monsanto (for example, in Cabbage, Cauliflower, Bitter Gourd, Okra, Hot Pepper, Tomato, Watermelon etc.) and the combined share is significantly higher than the nearest competitors. Further, for each vegetable, the share of Mahyco also has to be considered.

It is also apparent that there is going to be significant AAEC in the hybrid seed market in vegetables, given the already large shares of both these companies Bayer and Monsanto in this market.

Reasoning proffered by Bayer in (49) to (63) does not hold good given the substantial existing market segments that these companies have. For instance, what is listed in Point 62 as an advantage for the country’s food resources’ prospects, is also a reason (combined R&D and distribution efforts of these Parties) why competition will be adversely affected.

15. Seeds treatment products: The dominance of Bayer is apparent, across different crops like Paddy, Cotton and Corn, and this needs to be investigated by the CCI for itself, with or without the proposed combination.

16. We find that the following statements made in Form IV are false and questionable:

  • Open pollinated and hybrid seeds may be interchangeably used by farmers and are substitutable products – this is an outright unscientific statement to make.
  • As there are a large number of varieties available in the market, farmers weigh their options before buying seeds that they need – academic studies are showing that farmers are undergoing processes of de-skilling, and seed decisions are now becoming irrational and are almost fads.
  • Farmers take advantage of the immense array of choices not only in terms of source of supply but also on the type of product they wish to use on their land – as pointed out above, environmental learning of farmers is reported to be declining, with increase in social learning, including being influenced by aggressive marketing tactics of corporations.
  • Use of better yielding seeds will increase productivity of farm lands, which will increase incomes of farmers, who constitute more than 65 per cent of the Indian population, and which will spur economic development in India: from the agrarian distress that is manifest all over the country, and from official data, it is not clear how incomes of farmers have increased, when a large majority of farmers still have negative net returns (NSSO 70th Round).

In Summary:

There is prima facie evidence, from the Parties’ own submission of Form IV, of monopoly-like situation of either of these two corporations existing already in several market segments, even before the proposed acquisition, and there is a distinct picture of such a monopoly emerging after the combination, for different kinds of products.


It is apparent that this mega merger will have its impacts on India’s farmers, that too some of the most vulnerable marginal/smallholders or adivasis etc (cotton, maize and vegetable farmers). At a time when India’s farmers are already reeling under a severe agrarian distress, anything that limits their choices, or makes their enterprise more risky should be regulated strictly and prevented.


It is also apparent from the way the Form IV has been designed, based entirely on which, there is a danger of CCI coming to wrong assessments of potential AAEC. We would like to repeat that the following additional information should also inform the CCI’s regulatory processes:


  • Products in the regulatory pipeline, especially with GEAC and RCGM which tend to give a market edge to certain parties, for having fulfilled the biosafety requirements in the transgenic regulatory regime;
  • IPRs held by these companies on different products, giving them a market edge;
  • Full details of the October 13th 2017 definitive agreement of Bayer with BASF, and the implications for AAEC from the same, along with the similar deal that Monsanto has with al with Tierra Agrotech Private Limited – the CCI has to run public consultations on these combinations and agreements in a manner similar to the current one;
  • Mahyco’s market share for various products, given that Monsanto has a 26% shareholding in Mahyco;
  • Cumulative effect of all three mega combinations in the seed and agri-chemical industry.


The Directive Principles of State Policy require the State [Article 39(c)] to ensure that the operation of the economic system does not result in the concentration of wealth and the means of production to the common detriment. This combination would essentially result in such concentration, and common detriment. From all evidence that already exists, this is a serious threat to competition, and thereby, farm livelihoods (in addition to several indirect impacts on other citizens and environment). These mega-combinations should be stopped and the CCI is urged strongly to do so. We write to you to urge you to firmly disallow the acquisition of Monsanto by Bayer AG.


Further details about this submission, as laid down by CCI:

(a) Name, address and contact details of the person(s) writing to the Commission:

Rajesh Krishnan, Farmer, Vayalorathu house, T.P 14/71-b, Kulirmavu, thrissilery, P.O Manathavady, 670646 Wayanad, Kerala.

Phone number- 7559915032, 9845650032


(b)How such a person(s) is adversely affected or is likely to be affected by the combination, keeping in view the relevant provisions of the Act/factors provided under sub-section (4) of Section 20 of the Act:

The party submitting this document is making the submission on behalf of farmers of the country who are likely to be affected by the combination. It is apparent that this combination would result in the parties to the combination being able to significantly and sustainably increase prices and given the high likelihood that the combination would result in the removal of a vigorous and effective competition in the market. It is seen prima facie that the parties, even without the combination, have indulged in abuse of dominant position. We urge the Commission to inquire into this too.



Rajesh Krishnan

  1. Afsar Jafri, Focus on the Global South, Delhi
  2. Ajay Etikala- Concerned Indian Citizen, Delhi
  3. Anand, Swati, Michael and Rohit, Paryavaran Suraksha Samiti, Vadodara
  4. Ananthasayanan, Safe Food Alliance, Chennai
  5. Aruna Rodrigues, Sunray Harvesters, MP
  6. Babubhai Patel, Secretary, Bharatiya Kisan Sangh, Gujarat
  7. Badribhai Joshi, Shantigram Nirman Mandal, Tanachha, Dist. Bharuch
  8. Balaji Shankar, Tharchaarbu Iyakkam, Tamil Nadu
  9. Balkrishna Namdeo, Bhopal Gas Peedit Nirashrit Pensionbhogee Sangharsh Morcha

10. Bharat Mansata, Vanvadi Agro-ecological Regeneration Association (VARA), Maharashtra

11. Bharatbhai and Krishnakantbhai, Bhavanagar Sajiv Kheti Manch

12. Bimal Prasad, Odisha Soochana Adhikar Abhiyan, Bhubaneswar, Odisha

13. D. V. Sreedhar, Goodnews India Foundation

14. Devesh Patel and other Farmers, Madhya Gujarat Sajiv Kheti Mandal

15. Dr Debal Deb, Ecologist, Centre for Inter-Disciplinary Studies, Kolkata

16. Dr Nandita Shah, SHARAN Auroville

17. Dr Tarak Kate, Dharamitra, Wardha, Maharashtra

18. Dr G. Sivaraman, Poovulagin Nanbargal, Chennai

19. Dr Ponnammal Natarajan, Retd Dean, Anna University

20. Dr (Ms) Suhas Kolhekar, National Convener, National Alliance of People’s Movements, Pune

21. Gopi Devarajan, OFM-Organic Farmers Market

22. Harinesh Pandya, JANPATH network-Gujarat, Ahmedabad

23. Himanshu Limbasiya and Kantibhai Bhut, Saurashtra Sajiv Kheti Manch

24. Jagannathan, Nalla keerai, Thiuvellore

25. Jagdish Patel, People’s Training and Research Institute, Vadodara

26. K. Jagadeesan, Advisor, Federation of Tamil Nadu Rice Mill Owners Association

27. Kapil Shah, JATAN, Vadodara and National Secretary, Organic Farming Association of India (OFAI)

28. Karpagam, organic farmer, Point Return, Maduranthagam, Tamil Nadu

29. Kavitha Kuruganti, Alliance for Sustainable & Holistic Agriculture (ASHA), Bangalore

30. Kirankumar Vissa, Rythu Swarajya Vedika, Telangana & Andhra Pradesh

31. Lali Dhakar – President, Ekal Nari Shakti Sangathan, Rajasthan

32. Manoj Solanki, Ramkrishna Trust, Madhapur- Kutch.

33. Nachiket Udupa, concerned citizen, Delhi

34. Narhari Mahato, Secretary General, All India Agragami Kissan Sabha (AIAKS)

35. Nawab Khan, Bhopal Gas Peedit Mahila Purush Sangharsh Morcha

36. Nirmal Chandel – Convener – National Forum for Single Women’s Rights

37. Pamayan, Thalaanmai Uzhavar Iyakam

38. Parthasarathy, Organic Farmer, Chennai

39. Parul Chaudhary, Rajasthan

40. Parul Zaveri, Kaninika Organic Farm, Ahmedabad

41. Patel Kaushil N, Organic retailer, Vadodara

42. Patel Trushna K, Organic retailer, Vadodara

43. Rachna Dhingra, Satinath Sarangi, Bhopal Group for Information and Action

44. Radhika Rammohan, Restore, Chennai

45. Rajanibhai and Narshibhai, Sabarkanha Sajiv Kheti Manch

46. Ramasubramanian, Samanvaya Consulting, Chennai

47. Ramesh Chandran, Anantha Trust, Coimbatore

48. Rashida Bee, President, Bhopal Gas Peedit Mahila Stationery Karmchari Sangh

49. Ravi Kanneganti, Convenor, Telangana Rythu Joint Action Committee

50. Rohit Parakh, India For Safe Food, Mumbai

51. Sangeetha Sriram, Restore Gardens, Chennai

52. Selvam Ramaswamy, Tamil Nadu Organic Farmers Federation, Erode

53. Shailesh Vyas and Ramesh, Satvik, Bhuj

54. Shrenik Shah, Bhavnagar, Gujarat.

55. Sivakumar, Nalla Sandhai, Thiruvellore

56. Sreedevi L, Bio Basics, Coimbatore

57. Subhash Lomte Convenor National Campaign Committee for Rural Workers & Jai Kisan Andolan (Swaraj Abhiyan)

58. Sujatha Mahesh, Organic Farmer, Pondicherry

59. Suresh Lakshmipathy, Tula India, Chennai

60. Umendra Dutt, Kheti Virasat Mission, Punjab

61. Vasant Futane, Organic Farmer, Village Rawala, Warud Tehsil, Dist. Amravati

62. Vinay – Charul, Loknaad, Ahmedabad

63. Vinita Mansata, Earthcare Books, Kolkata

64. Yatri Baxi, Paryavaran Santri, Ahmedabad



by Kavitha


8:45 am in News by Kavitha

Ahmedabad/New Delhi, 26th April 2012: The Gujarat government’s cabinet decision yesterday to withdraw controversial American MNC Monsanto’s proprietary seed from ongoing government projects was welcomed by Bharatiya Kisan Sangh (BKS) and Alliance for Sustainable & Holistic Agriculture (ASHA). BKS state President Maganbhai Patel, Kapil Shah of Jatan and Prabhakar Kelkar, National President of BKS organized a press conference in Ahmedabad today, thanking the government for its decision, having protested and campaigned against the unscientific, controversial and unsustainable aspects of Project Sunshine for several seasons now. Earlier, a Cabinet Sub-Committee has recommended the withdrawal of Monsanto’s seed from government projects.

The seeds of Monsanto, under the brand name “Prabal”, a double-cross hybrid of Maize, were being distributed to more than half a million tribal farmers of Gujarat since the inception of Project SunShine under Vanbandhu Kalyan Yojana in 2008. This project came under great criticism not only from within the state but also at a national level by various agencies including farmers’ organizations, tribal organizations and leaders, organic farming promoters, ecologists and scientists. It is estimated that the Gujarat Govt has procured seeds from Monsanto worth of 500 million rupees in the last four years, to be distributed in turn to poor tribal farmers, thereby providing ready markets for this controversial corporation seen by many as anti-farmer. It is not clear whether proper bidding and other transparent procedures were followed or not while favoring Monsanto in this project, apart from several questions on the scientificity of proprietary hybrid seed being chosen to be distributed to resource-poor, vulnerable farmers.

Several efforts were put in by various groups and individuals against this project, through letter campaigns, rapid appraisal visits, public debates and personal meetings with policy makers. Bharatiya Kisan Sangh, the largest farmers’ organization in Gujarat, has also been demanding withdrawal of Monsanto and its ‘Prabal’ seed from such government support. This proprietary hybrid seems to have been selected against the opinions of agricultural scientists. There has been increasing opposition in the state since the past couple of years against such encroachment of MNCs in State’s agriculture. In February 2012, ASHA (Alliance for Sustainable and Holistic Agriculture) released a Rapid Appraisal Report visiting tribal farmers of project villages and pointed out to several problems and flaws in the project. The last Assembly Session witnessed a debate and questions being raised on Monsanto’s seed. It appears that finally, the government has sought opinion of State Agriculture Universities, which gave their scientific opinion against these seeds for distribution to tribal farmers.

Four reputed scientists having enormous experience of working with maize and agricultural universities including two past Vice Chancellors were requested to opine about selection of ‘Prabal’ for distribution through government project.

All of them have opined about it in writing and have voiced strong views against the inclusion of this proprietary brand..

Dr. M. C. Varshneya, Former Vice C hancellor of Anand Agriculture University said, “Prabal variety of maize  was selected by tribal department without consulting Research Scientists.
1. Prabal is suitable only for deep soils.
2. Prabal needs more water than other varieties.
3. Heavy doses of fertilizers are needed for Prabal.
4. Prabal is not suitable for Godhra (where the maize Research Station is located) conditions where shallow soils and rainfed crop is taken”.

He adds, “ Inspite of candid opinion of University Scientists, Prabal seed was distributed to the farmers. Rather to say it was pushed on farmers without caring for technical suitability of the variety for that area.” As per his view SAU was not given a fair chance to supply its seeds. Showing his helplessness he says “Nothing could be done to stop the Monsanto released variety Prabal from entering in Gujarat.”

A well known maize breeder Dr. S. N. Goyal (awarded by the state government for his remarkable work) who worked as a Research Scientist for Maize at Anand Agricultural University for 12 years (from 1994 to 2006), and during whose tenue some of the most popular maize varieties in Gujarat were released, opined that, “My considered opinion about “Prabal” hybrid is, being a late-in-maturity, yellow-coloured and dent-type seed, “Prabal” is unsuitable for majority of maize growing areas of Gujarat. He described the following seven reasons for his view.

1.     Majority of maize growing areas, especially eastern part is rain-fed for where early maturity varieties are recommended and grown. Late maturity hybrids grown under rain-fed condition may not set seeds and chances of crop failure will be high which may lead to farmer’s distress.

2.     To overcome the risk of total crop failure in rain-fed area, farmers grow maize with other crops as an inter-crop which is not possible with “Prabal” Hybrid which is meant only for sole cropping.

3.     “Prabal” hybrid requires high inputs involving more expenditure which is not desirable under rain-fed condition, especially for resource poor farmers.

4.     Considering the AAU report, despite of high dosage of NPK application to “Prabal” hybrid, marginal depletion in  NPK and Zinc level have been observed in maize fields, which will result in soil deterioration in the long run.

5.     Storability of “Prabal” Grain / seed, which is dent type is less compared to flint type, which may lead to food insecurity for tribal families.

6.     “Prabal” hybrid is double cross hybrid. Double cross hybrids are less uniform and unattractive as compared to single cross hybrid. Double cross hybrid has high cost of seed production. Now-a-days, only single cross hybrids are developed and released. Using double cross is considered as an age old technology in the scientific forums. Double cross hybrid technology is rejected in USA also. World over, including at ICAR and SAUs in India, single cross hybrids are developed.

7.     Economic survey of “Prabal” growing hybrids in Gujarat revealed that financial gain is achieved only to 25% to 30% sample farmers in Dahod, Panchamahal and Vadodara and 40-50% in Sabarkantha and Banaskantha district, where as in rest of the area, it had no significant impact on economy.


Another retired senior plant breeder and former Research Scientist for forage crops at State Agricultural University Dr. J. P. Yadavendra, told that, “The crop varieties are developed and released as per regional requirements and specific agro-ecological niches.  Any crop variety/hybrid which has not been tested in a particular environment and disseminated for general cultivation among farmers poses a great danger in the long run. To safeguard the farmers’ interest, there should be an honest follow up of the official guidelines set up for the purpose by the state agricultural universities.  In case of cross-pollinated crops, the contamination of the well-adapted local cultivars may lead to the loss of valuable existing gene pool. In my opinion, the popularization of Prabal maize hybrid amongst the tribal farmers of Dahod and Panchmahal districts of Gujarat has been done without considering the proper procedures and opinion of the cultivators.” It is important to note that he is working in tribal areas of six states of India through an NGO called Gramin Vikas Trust.

Padmashree Dr. M. H. Mehta, Former Vice chancellor of Gujarat Agricultural University opined that, “ We do not seem to have given enough back up and large scale extension support to promising new maize varieties of Agri. University in Gujarat. Instead there seems a stronger support and preference to the varieties of multinational company. I have watched the organic model of Bihar where through a state level lead up & the package of eco-friendly agri. bio inputs, excellent yields of vegetables could be achieved in some of the poorest & backward districts. Low input cost, eco-friendly technology is the most appropriate for tribal people. It is time to adopt such a model for Gujarat farmers.”

Multinational seed companies including Monsanto are encroaching upon Indian agricultural fields by using government funds. At least four other states began spending public money to buy such seeds in the name of farmer/tribal/rural welfare, emulating the Project Sunshine model and serious opposition has been mounted against this in the other states too, with Odisha dropping this support after piloting it for one season.

“Gujarat’s Project Sunshine is a classic case of how Agri-MNCs like Monsanto bypass scientific opinion and administrative procedures and promote their unscientific and risky products. It is also a matter of investigation whether proper bidding was done to buy these seeds or not. It is the same companies like Monsanto that also promote GM crops and sell patented technology. Even as genetically modified maize is knocking on the door, pushed by corporations like Monsanto, ready ground is being created for this controversial technology by replacing public varieties through various questionable practices.”, said ASHA.

BKS appreciates the Gujarat Government’s move and strongly demands withdrawal of such seeds & projects in all states of India. At the same time, it warned the state government to be extra cautious to ensure that the same seed does not take back door entry. It is high time to set up a non-corrupt, transparent, efficient and scientific system so that such case never occurs in future

Gujarat Govt should ban Monsanto and GM crop trials in the state

Various groups in Gujarat and elsewhere in the country are now demanding a ban on Monsanto and various GM crop trials allowed in the state of Gujarat. This was in the context of Gujarat Government’s decision to withdraw this controversial agri-business corporation’s proprietary seed from government projects in the state. Monsanto’s seeds worth crores of rupees have been distributed without proper scientific basis and by bypassing proper administrative procedures. The Press Release added that “Monsanto is the company along with other corporations trying to introduce GM crops including Bt Brinjal, Roundup Ready Bt maize and so on. This company already controls around 93% of India’s cotton seed through its proprietary Bollgard technology when it comes to GM cotton. It is also being proceeded against by the National Biodiversity Authority for violations in Bt brinjal development, while being investigated by Indian biosafety regulators for violations in its GM maize trials”.

The Gujarat government decision to withdraw Monsanto from Project Sunshine is significant in the context of GM crop trials also. Last year, Rajasthan government had annulled agreements that it made for seed-related R&D with Monsanto and other corporations while Odisha did not pursue a Public Private Parntership programme initiated in the state after one season.

In India, at least eight states including Bihar, Rajasthan, MP, Chhattisgarh, West Bengal, Orissa, Kerala and Karnataka have decided not to allow any GM crop trials, while Uttarakhand and Himachal Pradesh have also said NO to such trials. Some of them have declared their desire to remain totally GM free. Only three states have allowed trials of this controversial and hazardous technology: Andhra Pradesh, Haryana and Gujarat. In Gujarat, NOC by state govt was given to about 10 “events”, all of which have proprietary right of MNCs. It was also found that this was done without the legally obligated institutions in place for monitoring and supervision. It is also worth noting that illegal planting of GM crops has been recorded in the past without any liability being fixed.

Why Gujarat Should Ban GM Crop Trials

There are various important reasons to ban such trials in Gujarat as mentioned below:

1.     The very need of Bt Maize, HT Maize and HT cotton has not been assessed or decided by scientists and farmers and there are safer alternatives available with SAUs. Need assessment and assessment of alternatives is not governing GM crop trials-related decisions.

2.     Open air trials precede biosafety clearance (biosafety testing runs parallel to such open air trials) and these open air trials pose a great risk since this technology is a living, imprecise, unpredictable, irreversible and uncontrollable technology.

3.     Open Air Trials are permitted based on privately-generated safety data and not even independent scientific analysis. This was also stated as an argument against such crops being released by very senior and credible scientists in the country.

4.     All the GM crops trials are sponsored by the seed developer. (No Blinding is done). This may lead to biased results. There is a need to cut off the relations between company and evaluating agency.

5.     There are chances of contamination from novel organism to local germplasm as the facilities and isolation requirements to avoid the contamination are limited and questionable. Moreover, the agri-campuses where such trials take place are also repositeries of valuable germplasm collections.

6.     As per the EPA, there is a need to have State Biosafety Coordination Committee (SBCC) in function, In Gujarat, SBCC is non-functional with different agencies washing off their hands on their responsibility.

7.     There are mounting evidences depicting risks related to transgenic crops including unexpected changes in the organism, ecological and health risks.

8.     Even the export and trade of certain farm products will be at risk (as example of rice in China and basmati rice in India). Field trials have been known to cause enormous damage to trade security in various parts of the world in the past.

9.     The seed owner wants to enjoy IPR restricting the very right of farmer to produce their own seeds. We cannot have such trials until several basic things are made clear.

10.  GM crop trials are disallowed in an overwhelming majority of states in India. Why should Gujarat allow them, and on what additional scientific basis and regulatory capability?




Maganbhai Patel, BKS:  09426394801

Kapil Shah, Jatan:  09427054132

Kavitha, ASHA: 09393001550


by Kavitha

Project Sunshine needs to be suspended immediately

1:13 pm in News by Kavitha

A rapid appraisal of Project Sunshine in Gujarat, organised by ASHA, came up with its report recently. The main conclusions of the team which took up the rapid appraisal include:

1. Tribals prefer desi corn for their food consumption purposes while hybrid corn is less preferred; any government projects promoting hybrid corn should keep this in mind and ensure that food and nutrition security needs are met first and foremost.

2. Hybrid corn and the package being offered as part of Project Sunshine is indeed leading to chemicalisation of agriculture, which pose questions around environmental sustainability of this approach. Recommended dosage of fertilizers is higher than prescribed by the local agriculture university and unscientific.

3. While the project is running on subsidizing various inputs as of now, it increases dependency on market sources for inputs and thereby, riskiness in farming for vulnerable communities.

4. It is unclear why the government opted for proprietary seed primarily from one source, that too an American multinational having controversial record.

5. It is to be noted that fodder from hybrid corn crop is less preferred by animals, compared to local cultivars.

6. While there seems to be an increase initially in productivity and profitability, it is difficult to say how much and for how long. It appears that the government is trying to inflate the benefits compared to the reality, while ignoring the negative fallouts of the project. Net returns are negligible, especially when real costs are imputed/when the project closes down; comparisons are unscientific; the project investments are higher than the net returns obtained and all of these pose questions on this project’s claims.

7. It is not understood why the government bypassed the scientific expertise available within the public sector and why such investments have not been made on approaches that are more sustainable and in the control of farmers.

8. Projects like this pose serious questions around seed and food sovereignty of communities as well as the nation and need to be re-looked at, especially given that alternative approaches are being adopted quite successfully within the project region.

Having raised several questions born out of genuine concern and from insights into Project Sunshine (which is being blindly emulated in other states, unfortunately), we conclude that Project Sunshine needs to be suspended immediately, to be reviewed by an independent expert committee consisting of various kinds of expertise and stakeholders (tribal development activists and experts, tribal leaders, maize scientists, other agriculture experts, sustainability advocates, farmers’ leaders etc.). Meanwhile, project investments should be diverted into more sustainable, people-controlled alternatives which are quite possible, as small scale initiatives are showing on the ground.


by Kavitha

Monsanto Quit India Call for a Nation-wide DAY OF ACTION on Aug. 9, 2011 (Quit India Day) & KISAN SWARAJ WEEK, Aug. 9TH to Aug. 15TH 2011

10:30 am in News by Kavitha

Monsanto Quit India
Call for a Nation-wide DAY OF ACTION on Aug. 9, 2011 (Quit India Day)
& KISAN SWARAJ WEEK, Aug. 9TH to Aug. 15TH 2011

“No food shall be grown, that we do not own” – that is the reported objective of Monsanto, the multi-national seed and agro-chemical company notorious for suing and jailing farmers for the “crime” of reusing seeds they purchased from the company! If you are shocked by Monsanto’s aim of controlling the entire world’s food production system, what is more mind-boggling is how much progress it has already made towards its goal. Monsanto is today the world’s largest seed company, already controlling 23% of the proprietary seed market. The annual profit of this single company is Rs. 22,500 crores, more than the GDP of 48 countries! Known for its unscrupulous practices, it is now re-writing the laws and manipulating politicians and officials in the developing world to push its GM (genetic modification) technology, herbicides and proprietary hybrids. Recently, gross violations were exposed in its field trials of GM maize in Karnataka showing the impunity with which the company defies biosafety concerns.

If we as a nation want to protect our food sovereignty, if we want to retain control on what we grow and what we eat, this is the time for us to act decisively. This is a call to all like-minded organizations, alliances and individuals to come together for simultaneous actions on Aug. 9th, 2011 across the country with the outcry “Monsanto Quit India!”, and other actions observing Aug 9th-15th as Kisan Swaraj Week – sending a strong signal nationwide that citizens will not tolerate corporate domination of our food systems and agriculture.

The question of who controls our agriculture – our crores of farmers or a few big corporations – has deep ramifications for the whole society. We all have a big stake in whether unsafe genetically modified foods will be thrust on us, whether unsafe agri-chemicals would further damage our water, soil and health, whether 10 crore farmer families will lose their livelihoods, whether our rural and urban areas will be sustainable and whether we would have safe, diverse and nutritious food to eat. This Day of Action aims to strengthen the broader struggle against corporate domination of agriculture by focusing on its most potent symbol. More information including a leaflet can be accessed from the links under “Resources” below.

How you can participate in the August 9th nationwide Day of Action & Kisan Swaraj Week (Aug. 9th to 15th)

You can either participate in an event being organized in your area, or organize an event yourself. If you plan to organize an event on behalf of your organization or jointly with ASHA (Alliance for Sustainable and Holistic Agriculture), please contact Kavitha Kuruganti, Kiran Vissa or Rajesh Krishnan. The contact information including coordinators of various states is given below.

Here are some suggestions for what to organize:
· Demonstration at a Monsanto/Mahyco centre
· Padayatra to create awareness amongst farmers and consumers
· Protest against your government if it is partnering with Monsanto using public funds
· Seed Diversity Festival or a Traditional Foods festival
· Demonstration against field trials of GM crops in your state
· Film screening or awareness event about corporatization of our food system
· Bonfire of Monsanto seeds
· Seed Exchange among farmers & felicitation of Seed breeders
· TV or radio programs, press conference
· Release of local language material on Monsanto and its crimes
· Workshop/Round-table on how to stop corporate control of agriculture

You can also take part in a nation-wide post-card campaign in the lead-up to August 9th with a simple message to Monsanto: “Monsanto: We do not need or want your hazardous & unsustainable technologies in agriculture; we will not allow you to control our agriculture and seed resources; we refuse to have your poison served to us. MONSANTO, QUIT INDIA!” Post cards with this message can be sent to: Monsanto India Limited, Ahura Centre, 5th Floor, 96, Mahakali Caves Road, Andheri (East), Mumbai 400 093. Phone: 022-28246450/67029851; Fax: 022-28244707.

If you have better ideas, do share with us and we will propagate them!

- Alliance for Sustainable and Holistic Agriculture (ASHA)

Alliance for Sustainable and Holistic Agriculture (ASHA) is an all-India network of about 400 organizations of farmers, agricultural workers, consumers, social activists and academics, working to promote ecologically sustainable agriculture and secure livelihoods for farmers, and stop corporate domination of our agriculture and food system. ASHA organized the nation-wide Kisan Swaraj Yatra from Sabarmati to Raj Ghat in Oct-Dec 2010 for “Food, Farmers, Freedom”.

Resources and Links:
(1) Leaflet for Monsanto Quit India events

(2) Report on “Monsanto-izing Indian Agriculture”

(3) Monsanto: Corporate Manipulation and Deception

(4) Gross violations in GM field trials in Karnataka

(1) Poison on the Platter (Mahesh Bhatt):
(2) Poison on the Platter (Hindi):
(3) World according to Monsanto:
(4) Future of Food:

Overall coordination:
Kavitha Kuruganti:, 09393001550
Kiran Vissa:, 09701705743
Rajesh Krishnan;, 098456-50032

Andhra Pradesh: Kiran Vissa (ASHA);, 097017-05743
Bihar: Pankaj Bhushan (GM Free Bihar Movement);, 094729-99999
Delhi: Rajesh Krishnan (Greenpeace);, 098456-50032
Karnataka: Kodihalli Chandrasekhar (Karnataka Rajya Raita Sangha);, 098442-93908
Kerala: Sridhar Radhakrishnan (Coalition for a GM-Free India);, 099953-58205
Madhya Pradesh: Nilesh Desai (Beej Swaraj Abhiyan),, 094253-29222
Maharashtra: Aarti Pakharaj (Hamara Beej Abhiyan, Maharashtra), 094224 60587; Tejal V. (GM-Free Maharashtra),, 098337-07598
Orissa: Debjeet Sarangi (UNCAGE),, 099385-82616; Saroj Mohanty (Paschim Odisha Krushak Sanghatan), 097771-54149
Punjab: Umendra Dutt (Alliance for Safe & GM-Free Food, Punjab),, 098726-82161
Tamil Nadu: Ram (Safe Food Alliance),, 094449-57781; Kannaiyan (South Indian Coordination Committee of Farmers’ Movements), 094449-89543
Uttar Pradesh: Rakesh Tikait & Dharmendra Malik (Bharatiya Kisan Union), 092196-91168

KisanSwarajYatra: Movement for Food, Farmers and Freedom in India

4:07 pm in Video by Kirankumar

The Kisan Swaraj Yatra is a nation-wide mobilization drawing fresh attention to the continuing agricultural crisis in India, and calling Read the rest of this entry →