India’s Push for GM Mustard Called into Question

TWN Info Service on Biosafety
8 March 2023
Third World Network

Dear Friends and Colleagues

India’s Push for GM Mustard Called into Question

India approved the country’s first ever environmental release of a genetically modified (GM) food crop, DMH-11 mustard, in October 2022. The approval was for a limited period of four years, but environmental release is an important step towards future commercial release. On 3 November 2022, the Supreme Court of India ordered a suspension of the GM mustard’s environmental release, and the debate over its biosafety continues. (Item1)

Proponents claim that the GM mustard will have higher yields. However, evidence shows that the DMH-11 yield is lower than at least four hybrids cultivated in India, as well as than traditional non-hybrid varieties. Use of the system of mustard intensification (SMI) reportedly produced yields of 4000-5700 kg/ha – far more than that of DMH-11. Another concern involves the status of DMH-11 as a herbicide-tolerant crop. Even though the authorities argue that DMH-11 has not been developed as a herbicide-tolerant technology, it has herbicide tolerance traits and farmers would be tempted to use herbicides, even if illegally. (Item 2)

A Supreme Court-appointed technical expert committee in 2013 recommended a 10-year moratorium on field trials of all GM food crops unless the lax testing, regulatory and review mechanisms, including conflict of interest in regulatory and oversight mechanisms, are fixed. A Parliamentary Standing Committee of 2012 “unanimously” recommended that field trials of GM crops should be “discontinued” until “all regulatory, monitoring, oversight, surveillance and other structures” were put in place. Along these same lines, scientists, farmers and civil society are questioning the authorities’ rush and lack of due diligence in approving the GM mustard.

With best wishes,
Third World Network

Item 1


GRAIN, 1 Feb 2023

On 18 October 2022, India’s government approved the country’s first ever environmental release of a genetically modified (GM) food crop, DMH11 mustard. The approval was issued for a limited period of four years, but the environmental release is considered to be a crucial step on the way to commercial release.

To date, in India, only GM Bt cotton has been approved for commercialisation. Over the past two decades of Bt cotton farming, several reports have emerged highlighting its distressing impact in India, ranging from increased use of pesticides and insecticides to control “superpests”, to increased indebtedness and farmers suicides.[1][2] Hundreds of local and indigenous cotton varieties in India have been lost to Bt cotton. These have been replaced by Bt monocultures or have become extinct due to genetic contamination. Civil society groups, including Sarson Satyagraha ,and political parties have opposed the environmental release of GM mustard, warning of the risk of contaminating local mustard germplasm and affecting the genetic diversity of India, where mustards have been cultivated for nearly 6000 years.[3]

On 3 November 2022, the Supreme Court of India ordered a suspension of GM mustard’s environmental release. It also ordered the Indian government to ensure that “no hasty action is taken” pending the hearing of the application. However, newspapers report that some Indian Council of Agricultural Research locations in Uttar Pradesh and Rajasthan have planted GM mustard.

What is DMH-11 mustard?

DMH-11 was developed by Dr Deepak Pental and his team at the Centre for Genetic Manipulation of Crop Plants under the University of Delhi. It is a cross between the popular Indian mustard variety “Varuna” with an East European variety “Early Heera-2”. Since mustard is a self-pollinating crop, crossing was made possible by sterilising one of the parental lines.[4] In the DMH-11 “Varuna variety” parental line, a barnase gene was introduced to induce male sterility and prevent the plant from self-pollinating naturally. Whereas in ‘Early Heera-2’, a barstar gene was introduced which blocks the effect of barnase, thus allowing seeds to be produced when farmers grow DMH-11. A third gene adds to the controversy: the herbicide tolerant bar gene. It was introduced in both parental lines for herbicide resistance, to confer tolerance in the plant to the use of Glufosinate Ammonium. Glufosinate is a broad-spectrum herbicide, similar to Monsanto’s “Round-up” (glyphosate). Non-GM plants die when sprayed with glufosinate. The DMH-11 is therefore not only a transgenic crop because it uses three foreign genes from a different specie but it is essentially a herbicide-tolerant crop.

DMH-11 is a herbicide-tolerant crop

The main controversy surrounding GM mustard is undoubtedly its hidden herbicide tolerance (HT) trait described above. Its developers claim that DMH-11 was not developed to be HT. However, the letter authorising its release issued by the Genetic Engineering Appraisal Committee (GEAC) last October clearly indicates that the genetic make-up of DMH-11 and both the parental lines carry the bar gene and hence prove the presence of herbicide tolerance. The approval letter also included a condition that no herbicide of any kind would be allowed to be used in the field to grow the GM mustard under any circumstances, and that such use of herbicide without proper approval would result in appropriate legal action. This condition itself is evidence that the GM appraisal committee is well aware that this GM mustard is herbicide resistant and that there is a high probability of herbicide use in the farmers’ fields.

In a country as large and populous as India, it is difficult for government authorities to prevent farmers from using herbicides when they are readily available on the market. In recent years, India has witnessed illegal planting of herbicide tolerant crops, such as maize, soyabean and cotton.[5] [6] Farmers’ unions and civil society groups have alerted the GM appraisal committee and its ministry, demanding serious action to curb the illegal spread of unapproved herbicide-tolerant GM crops but no strict action has been taken.

The government’s Task Force on Agri-Biotechnology, headed by Dr M.S. Swaminathan, two parliamentary committees and the Supreme Court’s Technical Expert Committee have all opposed the cultivation of HT crops in India. The Supreme Court Technical Expert Committee has called it “unsustainable” and “unsuitable” for India. It noted that the herbicide sprayed on HT crops causes cancer and therefore recommended a “total ban” on all HT crops on a “precautionary principle” since no long-term safety studies have been done on the impact of edible GM crops on human and animal health and biodiversity.

Not really “Made in India”

To sell GM mustard to the government and the public, the developers have labelled it “Swadeshi” or “Made in India”. Unlike Bt cotton which was developed by Monsanto, DMH-11 is developed by a team of Indian scientists at a public research lab under the University of Delhi. The research was funded by the National Dairy Development Board and the Department of Biotechnology. In reality, though, the three external genes used in the GM mustard are patented technology from Bayer CropScience.

In 2002, a similar GM mustard variety was rejected by Indian regulators when Bayer’s subsidiary, ProAgro Seed Company, sought commercial cultivation approval. Bayer’s application was rejected because the Indian Council of Agricultural Research said its field trials did not show an increase in yield.

Questionable economic benefits 

Since 2002, the claim of a ‘higher’ yield from GM mustard has been challenged not only by civil society groups but also by agricultural scientists. The developers of DMH-11 claim that this GM mustard would yield more.

However, GM Free India says that this GMO has never been tested according to the protocols of the Indian Council of Agricultural Research, and that the reported yield increase is over DMH-11’s parent variety Varuna, and not over currently available high-yielding varieties and hybrids. The current head of the Directorate of Rapeseed-Mustard Research (DRMR), Dr P.K. Rai, echoes the same sentiments: “DMH-11 has never been tested for yield performance in India. Without completing the field trials, it is difficult to say whether this GM hybrid variety is better than the existing ones”. For higher yields, there are simple traditional techniques such as the System of Mustard Intensification (SMI) practiced by farmers, which increase yields significantly, between 4 and 6 tonnes per hectare. With DMH-11, what is more, there is a strong possibility that productivity could be reduced if the male sterility trait is spread to other mustard varieties, leading to losses for farmers.[7]

Given the government’s intention to build self-reliance in oilseed production to save the huge foreign exchange outflow of about USD 15-20 billion annually on edible oil imports, the move to commercialise GM mustard could defeat India on two fronts. First, the use of herbicide-tolerant mustard would lead to increased imports of herbicides in India. At the same time, India could lose its capacity as an exporter of non-GM and organic foods. Countries that import food grains from India because India doesn’t grow GM food would probably look for an alternate market as the chances of contamination from GM mustard would be much higher after commercialisation.

It could affect bees and other pollinators

Assessing the impact of GM mustard on bees and other pollinators should have been a primary concern of biosafety regulators. However, the recommendation of the GM appraisal committee is evidence that no scientific studies have been conducted to assess this impact.

On 25 August 2022, the appraisal committee established an expert committee to examine the impact of transgenic mustard on honey bees and other pollinators, and to assess the need for the conduct of field demonstration studies.[8] The expert committee produced its report within an express period of 45 days, stating that “based on the review of scientific evidence available worldwide, it appears unlikely that the bar, barnase, and barstar system will have an adverse effect on honey bees and other pollinators”. It also suggested that the field demonstration studies could be conducted after the environmental release”. Groups like the Confederation of Apiculture Industry have called out the committee’s approach as callous and unscientific.

The biggest loss will be in honey exports. India is the world’s fifth largest exporter of honey. Exporters fear that the herbicide-tolerant GM mustard will dramatically impact honey production and exports.

Immediately after the government approval, the beekeepers and honey exporters of the Confederation of Apiculture Industry staged a protest at the Indian Council of Agricultural Research-Mustard Research Institute in Bharatpur, Rajasthan, demanding that the approval be withdrawn. They submitted a memorandum to the Prime Minister of India pointing out that Indian honey is exported with a non-GMO certificate, which will no longer be possible after the commercial release of GM mustard, putting their business and livelihoods at risk.

India will continue to fight and reject GM mustard

India has a long history of fighting against GMOs. During the fight against GM brinjal (eggplant), the government acknowledged that the regulatory system was flawed, that the risk assessment system was not robust and that the testing systems were grossly inadequate.[9] Yet, the Coalition for GM Free India has shown that India’s regulatory system is riddled with conflicts of interest and lacks the specific scientific protocols that are required for testing HT crops. In its fight against the release of GM mustard into the environment, the Coalition exposed 15 lapses by the regulatory authority in the processes and procedures used to evaluate and approve GM mustard.

For Indians, mustard is not just an oilseed but its leaves are eaten directly as part of Indian cuisine (sarson da saag). It is also part of Indian traditional medicine, particularly Ayurveda, where mustard seeds and oil are used. In the case of Bt brinjal, this -direct consumption of the GMO as a food product- was one of the main considerations for the indefinite moratorium.

The commercial release of DMH-11 doesn’t just threaten India’s mustard genetic diversity, it would also open the door to several other GM plants and crops currently under development by the public and private sectors, including banana, eggplant, rice, corn, sorghum and other fruits and vegetables.

Indian farmers have witnessed the disaster caused by Bt cotton. Their protests along consumers and scientists against the environmental release of GM mustard will hopefully be a wake-up call for the government to impose a moratorium on the release of this and all other GMOs. And make it clear that the solution to India’s challenges doesn’t lie in GM products but in supporting farmers and local seed diversity.

[1] KR Kranthi and Glenn Dais Stone, “Long-term impacts of Bt cotton in India”, Nature Plants, Volume 6, 2020,

[2] Coalition for a GM-Free India, “15 YEARS OF BT COTTON IN INDIA: Admission of Failure Official Now”, June 2017,

[3] Sarson (mustard/ rapeseed) Satyagraha was launched in Delhi on 15 July 2015 with a prayer meeting and pledge-taking at the Mahatama Gandhi Memorial at Rajghat, joined by many organisations and individuals to restrict the entry of GM mustard in India.

[4] Mustard is a self-pollinating plant, which means each mustard flower is a ‘perfect flower’ that contains both male stamen and female pistils and therefore does not require another flower/plant to pollinate. Therefore, if a hybrid mustard crop has to be developed, it would need to be genetically engineered to enable hybridisation, as happened in the case of DMH-11.

[5] “Ban on GM Crops”, Press Information Bureau, Ministry of Agriculture & Farmers Welfare, Government of India, 2 July 2019,

[6] Jitendra, “Illegal GM Soybean: Farmers’ body demands CBI probe into GEAC inaction”, Down to Earth, 9 March 2018,

[7] Press Trust of India, “GM mustard sown in 6 field trial plots days before SC heard plea against it”, Bharatpur (Rajasthan), 14 November 2022,

[8] Minutes of the 147th Meeting of the Genetic Engineering Appraisal Committee, held on 18 October 2022,

[9] Manoj Mitta, “Bt Brinjal exposes serious regulatory lapses”, The Economic Times, 6 February 2010,

Item 2


 By Prasanna Mohanty
Fortune India
29 Nov 2022 

Genetically modified (GM) food, which had sparked intense national debate for years during the UPA-II and which had led to an indefinite moratorium on Bt brinjal in 2010, is a cause of concern again after the Centre permitted “environmental release” (one step away from “commercial release”) of GM mustard (DMH-11 hybrid) on October 18, 2022. The Supreme Court is now hearing the case – a continuation of long-pending litigations relating to GM crops beginning in 2004 (after Bt cotton was released in 2002).

Why does the Centre want GM mustard (DMH-11), which is also herbicide-resistant (HT), to be released into the environment without first establishing its need and efficacy? It raises many critical questions but the most basic one is about the misleading claims about its objectives.

The Centre’s affidavit of November 9, 2022, explaining its position to the court says, it is driven by three commitments: (i) increase in farm productivity (edible oil and legume) to make India self-sufficient (ii) increase in farmers’ income and (iii) cut in import bill (“55-60% of edible in India is imported”).

All three objectives hinge on one single factor: a higher yield of DMH-11. But does DMH-11 give a higher yield than hybrids and traditional varieties widely used in India?

Does GM mustard give a higher yield?

The Centre’s affidavit says a conditional yes. The sentence reads: “The GM mustard hybrid DMH-11 has shown increased per-hectare yield by 25-30% over the traditional varieties…”, adding, “due to exploitation of hybrid vigour”. The source of information is not revealed, nor is any other detail.

Note, despite the claim of “hybrid vigour”, the comparison is not with hybrids (many hybrids are cultivated in India for decades), but with “traditional varieties”. Varuna is a traditional variety of mustard, not a hybrid, which happens to be one of the parental varieties used for developing DMH-11 (the other is Early Heera 2).

The Centre’s 2016 affidavit was more specific: “No such claim has been made in any of the submitted documents that DMH 11 out-performs non-GMO hybrids. The comparison has only been made between hybrid DMH 11, NC (national check) Varuna and the appropriate ZC (zonal checks) – MSY of 2670 Kg/ha have been recorded over three years of BRL trials which is 28 per cent and 37 per cent more than the NC & ZC respectively”.

Note, here it is against Varuna only (in national and zonal checks).

The Centre is apparently relying on the claims of DMH-11’s current promoter, Prof Deepak Pental of the Centre for Genetic Manipulation of Crop Plants (CGMCP), Delhi University. On August 25, 2022, he told the Genetic Engineering Appraisal Committee (GEAC) – a statutory body which recommended DMH-11’s environmental release – that “on average, hybrid DMH-11 showed a 28% yield increase over the mega variety Varuna”.

On the other hand, the Centre’s nodal institute to carry out yield assessment – Indian Council of Agriculture Research (ICAR)’s Directorate of Rapeseed and Mustard Research (DRMR) at Bharatpur – has denied claims of the superior yield of DMH-11.

On November 20, 2022, DRMR director PK Rai told a national daily that GM Mustard (DMH-11) “has not been tested according to ICAR protocol” and that “it has just entered our system. Once trial and studies are over, one will get a clear picture on actual yield of DMH-11”.

Rai also said DMH-11 had been sown in six field trial plots, before the Supreme Court’s injunction not to do so came (on November 3, 2022). Few know that the Centre approved the environmental release on the very day, October 18, 2022, and the GEAC recommended this. The Centre’s affidavit of November 9, 2022, disclosed this.

Why this extraordinary hurry when the matter is pending before the court and why is the comparison only with Varuna?

What Centre and GEAC missed on yield

The answer to the second part is simple. One, the DMH-11 yield is lower than at least four hybrids cultivated in India for decades.

This was revealed by a study of the very same CGMCP (current promoter).

CGMCP scientist Yashpal Singh Sodhi established this at a seminar in New Delhi on February 20, 2015 (organized by the Indian Society of Oilseed Research). His data showed four non-GM hybrids had higher yields and a fifth had nearly the same yield as that of DMH-11. His analysis was based on 2013-14 data. He did not include DMH-11 yield in his comparison but compared the yields of 14 mustard hybrids and non-hybrids.

His data showed, as against DMH-11’s yield of 2670 kg/ha (as the Centre claims), four hybrids had higher yields: NDDB-DMH-1 (2924 kg/ha), NDDB-DMH-3 (2719 kg/ha), NDDB-DMH-4 (3102 kg/ha), Pioneer-45S42 (2819 kg/ha) had higher yieldsThe fifth hybrid, UPL-Advanta-Coral432 (2644 kg/ha), had nearly the same yield.

Two, the DMH-11 yield is lower than traditional non-hybrid varieties too, but before that a backgrounder.

The benefits of the system of crop intensification (SCI) are widely known to the world, including India, for decades. Here, existing traditional and hybrid varieties of crops are taken but the management of plants, soil, water and nutrients is altered to give higher yields. Take the case of the system of rice intensification (SRI), practised in India for long. The Cornell University’s SRI International Network and Resources Center says about “60 countries” have adopted SRI and paddy yields have gone up by “20-100%”. Similar is the case with wheat (WIS) and finger millet, wheat, maize, sugarcane, tef, oilseeds (mustard), legumes (soya and kidney beans) and various vegetables.

For mustard, it is called the system of mustard intensification (SMI). Newspaper reports say the use of SMI gives yields 4000-5700 kg/ha – far more than the DMH-11 – in Madhya Pradesh, Bihar, Odisha and West Bengal. Even without SMI, the indigenously developed Sitara Sringar of Rajasthan yields 3000-3500 kg/ha.

All the above facts negate the very raison d’être of DMH-11: higher yield in mustard would lead to self-sufficiency, raise farmers’ income and cut import bills.

Is DMH-11 herbicide-tolerant (HT)?

Another critical concern involves the status of DMH-11 as a herbicide-tolerant (HT) crop.

This classification is important because India (a) doesn’t allow any HT crop and (b) doesn’t allow farmers to use herbicides in their fields.

In fact, the GEAC’s approval for DMH-11 (October 18, 2022) came with a rider: “Usage of any formulation of herbicide is not permitted for cultivation in the farmer’s field under any situation and such use would require the necessary permission as per the procedures and protocols of safety assessment of insecticides/ herbicides by CIB&RC (Central Insecticides Board and Registration Committee).”

A few days later, on October 21, 2022, the Centre issued a gazette notification restricting the use of glyphosate to “any person except pest control operators” because it poses “health hazards and risk to human beings and animals”. This came after the action was sought by state governments against the sale and use of glyphosate following a surge in illegal cultivation of HTBt cotton. India allows Bt cotton (GMO) but not herbicide-tolerant Bt cotton variety – that is, HTBt cotton.

Now, it is well-known that DMH-11 is transgenic (GMO) as well as herbicide-tolerant (HT). The GEAC (August 25, 2022) clearly spelt out that one of the three foreign genes in it, bar “confers resistance to herbicide phosphinothricin – commercial name Basta”. The other two foreign genes in DMH-11 are barnase and barstar.

The Centre’s affidavit too admits this but, refuses to call it an HT crop.

The affidavit argues that GM mustard “has not been developed as a Herbicide-tolerant technology” and that its “HT characteristic/trait” is pure because of the bar gene used as a marker “for eliminating fertile plants in the hybrid seed production plots”. Hence, it argues, it is “not appropriate” to call it HT crop. It further argues that such a label would be warranted only if “this trait is the sole reason for permitting GM mustard from the environmental angle”. It also tells that Indian farmers are “not permitted” to use herbicides “for the cultivation of GM mustard”.

Notwithstanding the wordplay, if an HT crop is permitted for cultivation, farmers would be tempted to use herbicides even if illegally as in the case of HTBt cotton. The reason is simple: the sale and import of herbicides are not illegal and the government can barely do more than issue notifications to restrict their use. On the other hand, the advantages of herbicides for farmers are plenty: all weeds are removed with one herbicide, saving labour costs and time. Farmers are unlikely to consider long-term adverse consequences for human lives and soil and water toxicity. Had that not been the case, Punjab wouldn’t have known for “cancer trains” or “cancer belt”.

The Centre’s wordplay is also because of strong opposition to GM food and HT crops without first establishing their need, cost-and-benefit analysis, due diligence and scientific rigour in tests for biosafety (human and environment) and removing the conflict of interests in the oversight and regulatory mechanism (GEAC). Besides, the predominance of small landholdings (86% of farmers small and marginal with less than 2 ha or 5-acre land) makes Indian farmers particularly vulnerable to contamination from GM and HT crops (if biosafety is not already established). Agro-climate conditions of India are another critical consideration in this.

Missing due diligence

It is the unscientific manner in which the GEAC and the Centre have acted, historically and now, which has sparked protests from scientists, farmers and rights groups. Both have approved GMOs (Bt cotton earlier and now an HT crop to boot) without adequately testing for human and environmental safety, efficacy and socio-economic consequences.

A Supreme Court-appointed technical expert committee (TEC), set up after the Bt brinjal controversy, was categorical in its 2013 report that (i) GM and HT crops (ii) crops of Indian origin (in which India is “the centre of origin or diversity”) “should not be allowed” unless there are “extraordinarily compelling reasons” and (iii) recommended a 10-year moratorium on field trials of all GM food crops unless the lax testing, regulatory and review mechanisms, including conflict of interest in regulatory and oversight mechanisms, are fixed first.

A Parliamentary Standing Committee of 2012 very much said the same thing. It “unanimously” recommended that field trials of GM crops “under any garb” should be “discontinued” until “all regulatory, monitoring, oversight, surveillance and other structures” were put in place.

Did anything change in clearance for DMH-11?

The answer is a clear no. Here is why.

One, the biosafety data on DMH-11 is not available in the public domain for scrutiny. The Centre’s affidavit says, the dossier on “food and environmental safety (AFES)” was uploaded on the official website for one month only, between September 5, 2016, to October 5, 2016, and its scrutiny was allowed in person “at the premises of the MoEF&CC” only.

Why such secrecy? All such data for Bt brinjal was available in public for years to be verified.

Two, conflicts of interest in the testing and clearance process remain unchanged – to which both the TEC and parliamentary panel had particularly objected.

The DMH-11 project (of CGMCP) is (a) funded by the Department of Biotechnology (DBT), along with another public entity NDDB (b) the biosafety risk test data was “generated” by CGMCP (self-certification exercise) and (c) the risk assessment report on the basis of this data was “prepared” by a DBT unit (Review Committee on Genetic Manipulation or RCGM).

Yet, a DBT official co-chairs the GEAC (final recommending authority), carrying a higher weightage (it is a technical post) than the other co-chair, an official of MoEF&CC (generally an IAS officer) – as the 2012 parliamentary panel had commented.

Three, the 2012 parliamentary panel had lamented that long-term environment impact assessment and chronic toxicology studies of GM crops had “not even been attempted till now”, nor socio-economic benefits of Bt cotton to farmers studied (it said “no significant socio-economic benefits” of Bt cotton as it is capital intensive, increased investment manifold, exposed farmers to “far greater risks due to massive indebtedness” and after the initial euphoria “only added to the miseries of the small and marginal farmers” constituting the majority). The TEC had shown that the claim of rising milk production by consuming Bt cotton feed was misleading as well.

For the Centre to then claim “transparency” and a “strengthened” regulatory regime” makes no sense.

Finally, whose technology is DMH-11?

To know this, one would have to check the GEAC minutes of November 7, 2002.

It says, M/s Proagro Seed Company, Gurgaon, had approached it in 2002 to seek commercial release of its transgenic hybrid mustard and mustard seed carrying barnase, barstar and bar genes – same ones that DMH-11 carries but named MT95003 and MT 95005 then. But the GEAC deferred a decision because of incomplete studies and tests and unresolved concerns about health and environmental issues involved, it decided to “defer” a decision.”

It resurfaced in 2017 as DMH-11, through Prof Pental of CGMCP.

The next big questions that beg answers are: Who owns Proagro Seed Company now? More importantly, who owns the patent for the barnase-barstar-bar system? What is the connection between Proagro and CGMCP? Who are the leading producers of the herbicide “herbicide phosphinothricin – commercial name Basta” the DMH-11 is tolerant of?

The answer would reveal the secret behind the hurry and lack of transparency in clearing DMH-11 (the decision on Bt brinjal followed several rounds of national dialogue in various parts of the country).

It will also reveal if GM mustard will actually add to the foreign exchange burden by way of royalty outgo for using the technology and buying the herbicide.

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