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Ten questions about GM Mustard that must be answered!

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Here's a quick summary;

Genetic Modification of plants results in irreversible change to the plant composition & not enough has been done to understand how this effects human & animal health

Many countries banned Genetically Modified Food Crops (GMO Crops) because of their high-risk v/s low benefit profile

GMO technology benefited mostly Crop-science companies like Bayer & Monsanto which sell Herbicide resistant GMO seeds as well as the Herbicide to farmers 

India till date did not allow any GM Food crops. In non-food crops only GM Cotton (BT Cotton) has been allowed & the experience is not very good

Right now the Government of India is trying hard to approve the GM Mustard. If GM Mustard is approved many other GM crops like Wheat, Rice, Sun Flower, Soya will be allowed in next 2-3 years 

The Government's attempt to approve GM Mustard is based on outright lies, half-facts; irresponsible science, improper evaluation, investigation and by way of hiding essential data, information from public

This petition demands that the Ministry of Environment should answer 10 questions on GM Mustard evaluation before thinking of approving it   

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Even as I was giving finishing touches to this draft, I came to know about the sad demise of Mr. Anil Madhav Dave, Minister for Environment, Forestry & Climate Change. RIP Shri Dave _/\_

Dear Friends,

In support of the individuals & groups opposing approval of GM Mustard strain DMH-11 I have published two articles earlier, once in February 2016 and once in October 2016. My primary intention in posting these two articles was to add more scientific-muscle to the arguments of  #NoGMMustard activists by way of;

--> Highlighting the Herbicide Tolerant nature of DMH11 which otherwise was/ is being conveniently ignored in all the reviews, arguments in support of the approval (Herbicide = Glufosinate Ammonium a.k.a Basta et al)

--> Elaborating on how the original research and field trials by Dr. Pental et al & the GEAC safety review completely ignored the primary and highly stable metabolite called N-Acetyl-L-Glufosinate (NAG) that forms abundantly within Glufosinate exposed plants.  

Cut to May 2017, The regulator GEAC concludes the review process, clears DMH-11 application ‘with a few conditions’ and docks it with the Ministry of Environment, Forestry & Climate Change ~ MOEFC for the final approval (my own ‘unanswered’ comments are available here. Ironically despite all the hue and cry, GEAC still chose not to make public RARM document and their clarifications on the 440+ scientific (out of 700) comments solicited online between Oct-Nov 2016.

Despite this not-so-transparent regulatory climate, the anti-GMO activists are still doing their best to sensitize the country’s leadership and prevent MOEF from formalizing this approval – the writing on the wall however is clear, that DMH-11 will be steamrolled nonetheless on the improbable rhetoric of helping India achieve self-sustenance in oil-seed production! Clearly there is more than scientific review at play in this super-accelerated approval process

Now considering this approval is being bandied about as the victory of science over dogma, this needs to be countered in a suitably scientific fashion. I hence ask MOEFC to answer my following 10 questions prior to taking a final call on approving DMH-11 for commercialization;


As claimed by the applicant & as verified by the regulator, the Barnase-Barstar gene constructs inserted in DMH-11 are towards achieving male sterility and fertility restoration. The applicant also claims that the Bialaphos resistant gene a.k.a. ‘bar-gene’ has been merely inserted as a marker & not specifically to make DMH-11 Glufosinate resistant (Ref 1:

There is sufficient quantum of peer-reviewed scientific literature out there which conclusively shows that application of Glufosinate to GM plants that have a bar-gene progressively and precisely results in a dramatic reprogramming of the transcriptome* which would mean a) the bar-gene inserted GM plant would have non-native genes that produce non-native proteins; b) the native gene activity is either up-regulated or down-regulated thereby altering certain biochemical pathways & thereby changing the nutrient composition of the plant – some of these altered amino-acid compositions are thought to be behind the celiac disease & gluten allergy seen among the populations of GMO friendly countries like USA.



  • Why was ‘bar-gene’ chosen as the marker fully knowing the intention is not to make the GM strain herbicide tolerant?
  • Why weren’t the pleiotropic effects of bar-gene in Glufosinate exposed DMH-11 studied in greater detail** during the safety evaluation & during the field trials?
  • Considering the bar-gene's impact on trascriptome is applicable only when the GM crop is exposed to Glufosinate, have the field trials included cultivating DMH-11 with Glufosinate exposure? (with non-exposed DMH-11 as a control?)
  • Considering the bar-gene in HT crops can trigger gluten-allergy & considering at least 50% of Indians sustain on wheat which has gluten, has there been any allergy study conducted on DMH-11 specific to Gluten Allergy & Celiac disease?

**The section 4.7 of AFES document incidentally titled “pleiotropic effect, if any, of the gene modification” rules out the changes in transcriptome in precisely TWO sentences! (Ref: AFES document -


It’s been proven that the bar-gene conferred herbicide-tolerance will dramatically increase use of Glufosinate Ammonium by the cultivators (despite & in spite of the ‘recommendations’). It is also known that the primary metabolite N-Acetyl-L-Glufosinate (NAG) that forms as a consequence of the acetylation of Glufosinate enabled by the bar-gene will reside ‘very stably’ within the GM plant biomass (which is food for animals as well as humans in crops like Mustard). While NAG in residual quantities is relatively non-toxic, its toxicity over a longer term and at elevated levels has not been well studied. It is a proven concept though that ~10% of the ingested NAG converts back into toxic Glufosinate by the gut bacteria of the consuming animal/ human – thereby compounding both the short & long-term ill effects


  • Despite the above open source information which hopefully the applicants & regulators too have access to, why wasn’t N-Acetyl-L-Glufosinate (NAG) studied in greater detail nor even mentioned in AFES document?
  • If NAG was indeed evaluated methodically in the RARM document, why is this data not being shared publicly?


The AFES document and a few other applicant resources repeatedly claim that herbicide tolerance is an unintended trait in DMH-11 and that the whole purpose of developing DMH-11 strain is for yield enhancement. Apart from yield the other important differentiator in various strains is the Erucic acid content in Mustard oil – considering Erucic acid has a role in cardiac muscle damage, a lower concentration is supposed to be ideal – as in Pusa Mustard-30 that has <2% of Erucic acid.  


  • Based on the assertions made w.r.t. HT trait, will MOEFC explicitly disallow DMH-11 cultivators to use Glufosinate Ammonium on their crops?
  • If yes, how will MOEFC enforce this ‘recommendation’ and ensure the crop-science companies do not influence the cultivators with their promotional bundling of seed, herbicide and credit?
  • Now while DMH-11s yield has been shown as superior to the likes of Varuna & Maya, why has it not been compared with the Pusa Mustard hybrids particularly the very high-yielding, low Erucic acid containing Pusa Karishma LES-39 & Pusa Mustard-30?
  • Why is the high Erucic acid content of DMH-11 @ 12-16% in dry seed not a concern & has this parameter been considered during the review of DMH-11 application?

As the legislated gate-keeper of all genetic technologies that intend to mainstream in India, it is important MOEFC should err on the side of caution and disapprove DMH-11 commercialization thereby avoiding the consequent opening the flood gates to other half-understood and commercially motivated (read: Herbicide Tolerance) plant GMOs.

I wish & hope MOEFC will issue a public response on my above list of 10 questions and take a first step in the right direction.

Food safety first & foremost! 

 Jai Hind!

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