To: November 13, 2019
Joint Secretary (Seeds),
Ministry for Agriculture & Farmers’ Welfare,
Government of India.
Sub: Views/Comments on the Draft Seeds Bill 2019, available at http://agricoop.gov.in/sites/
Namaste! Alliance for Sustainable & Holistic Agriculture (ASHA) is a national platform of committed individuals and organisations committed to secure and improve farmers’ rights and sustainable farm livelihoods. This is our response to the Draft Seeds Bill 2019 put up on the Ministry of Agriculture and Farmers’ Welfare website.
ASHA believes that sustainable livelihoods for farmers as well as sustainable agriculture itself require a Seed regime in Indian farming which will not only keep intact farmers’ rights of breeding, selecting, saving, using, exchanging/bartering, distributing and selling seeds but actively encourages farmer level self-reliance when it comes to seed, and encourages agro-diversity as a key and critical component of sustainable agriculture and resilience to climate change stresses. Exclusive rights on seeds and planting material, albeit in the form of plant varietal IPRs and even patents on genetic sequences cannot be part of such a regime and are unacceptable to us.
It is also acknowledged that while the objective of self-reliant, agro-diverse farming is fully realized, there is a rapidly burgeoning commercial seed trade in Indian agriculture, actively encouraged by the policies of the government. We have a situation of retreating public sector when it comes to appropriate agriculture research on, and production/distribution of locally suitable, diverse seeds (that too in organic growing conditions). The current situation is also marked by increasing profiteering through limiting and standardizing Seed, and making it expensive, which has been seen to occur globally when control of seed is taken over by the private corporations. In such a context, it becomes imperative to bring in a legislation that will regulate commercial seed trade in India.
In all those cases where farmers are consumers of seeds (as opposed to seed breeders, savers and producers themselves), timely availability of appropriate, adequate, diverse varieties of seed, at affordable rates in accountable systems is the key problem from the farmers’ end and this is what the Seeds Bill has to address. Similarly, it is important that seed producing farmers’ interests (the ones who get into production and buy-back arrangements with seed companies and others) are also protected in the same statute, while farmers’ collectives or FPOs which are getting into seed production and supply should have some exemptions accorded to them, even as consumer-farmers’ interests are fully protected even here.
Such a statutory regulatory regime should not be confused with, and should not have any overlaps with, any legislation which seeks to provide proprietary IP rights, or plant varietal protection and exclusive marketing rights connected therewith. What is missing right now, but important to build in is a non-exclusivity clause around the registration procedure, which means that the same seed variety can be sold by another producer by another brand or label without a first-come, first-registered-for-an-
This Draft Seeds Bill 2019 should have a simple remit – get every person/ firm which wants to make money by way of seed, to first state by empirical evidence what they are promising by way of performance of such a seed, make such seed affordable, then make them stick to their claims by way of quality parameters, and holding them accountable/liable for the same. It should be recognized that the food self-reliance of the nation and the livelihoods of millions of farmers depends on this. Such a statute should also safeguard the nation’s unfettered control over agro-diversity, which is so vital for self-reliance and resilience in agriculture.
Regulation of quality of seed will no longer be enough to protect farmers’ interests unless seed prices are also regulated. One of the important components of any regulation should be seed price control since the sector right now attracts many players for the profit-making opportunities it presents whereas Seed is an ‘Essential Commodity’ and should be treated as such.
The Seeds Bill acquires new importance and criticality in a context when a demand for repeal or amendments to the Essential Commodities Act is being voiced. All the empowering provisions of the Essential Commodities Act’s Seeds Control Order 1983, being used by governments to protect the interests of farmers, should therefore be reflected in any proposed Seeds Bill.
The non-negotiable aspect of this approach is that the statute should primarily be for protecting and upholding farmers’ rights towards seeds, and ensure that they are not exploited as seed consumers. For farmers’ interests with regard to commercial seed to be protected, we demand the following components to be incorporated, which are missing at present in the Draft Seeds Bill 2019.
1. SEED PRICE REGULATION HAS TO BE AN INTEGRAL AND CRITICAL FUNCTION OF REGULATION: In the rapidly changing scenario with regard to commercial seed business, it becomes imperative that state governments have the authority through the Seeds Bill, to fix the retail seed price of all seeds being commercially traded, and royalty/licensing fees for any (technology) sub-licensing agreements, as in the case of cotton seed.
a. Such seed price regulation should be for all seed, and not just in ‘emergent situations’ as proposed in the Draft Seeds Bill 2019. Real time monitoring of the emergent situations is not in place and therefore, this provision based on ‘emergent situations’ will be rendered meaningless in reality.
b. Such seed price regulation should also include fair returns to seed-producing farmers, in addition to regulation of other terms and conditions for seed production by farmers.
c. Further, given that the Seeds Control Order of 1983 is likely to get nullified after the Seeds Bill is notified, it is important to incorporate all the powers that state governments have under the Order into the proposed Seeds Bill, including the ‘Power to Distribute Seed’ (compulsory licensing).
2. COMPENSATION PROVISIONS HAVE TO PROTECT FARMERS’ INTERESTS: A critical provision in the regulation that upholds farmers’ interests is the Compensation-related section. Farmers should get compensated in case of failure of performance against the claims made. However, this provision is very inadequate in Draft Seeds Bill 2019 (Sec. 21). Without easy adequate and prompt compensation to farmers for sub-optimal performance of a seed, the main objective of this regulatory statute cannot be said to have been fulfilled. It is with great concern that we note that despite the Seeds Bill Amendments of 2010 proposing to move away from the original idea of farmers taking resort in the Consumer Protection Act, the 2019 version of the Bill once again talks about compensation to be sought through the Consumer Protection Act. This is regressive.
The compensation mechanisms should be accessible to the farmer – district or even taluka/tehsil/block level compensation committees would be needed for this purpose. Compensation awarded should have a formula to cover the costs incurred and should also be against the value of the claims made for the performance of that variety at the time of registration (the guarantee of performance is not just about germination of the seed, but the actual crop performance). The compensation claim should be resolved within 30 days of filing of the claim and the farmer be paid within three months of the award of the compensation so that the farmer’s next growing season is not affected and this should be incorporated into the legislation. Any farmer aggrieved by the decision of the Compensation Committee should be able to appeal to a prescribed authority which shall dispose off the appeal within a specified time and manner that is prescribed. Further, compensation in the case of certified seed that causes losses to farmers should be shelled out by the certification agency too. It is these kinds of modalities that are missing right now, and should be incorporated into the Draft Seeds Bill 2019.
3. PENALTIES HAVE TO ACT AS DETERRENTS: The “Offences & Penalties” section needs to ensure that penalties are effective as deterrents, and these provisions are quite inadequate at present under Sections 42 to 44 in the Draft Seeds Bill 2019. Penalties’ range has been increased by a mere INR 20,000/–75,000/- in the case of two kinds of offences from what was proposed in 2004 (and in one more kind of offence, to five lakh rupees from fifty thousand rupees proposed in 2004 along with one year imprisonment), whereas what farmers’ groups have been asking for is very different, and what the Parliamentary Standing Committee had recommended is very different too. The Committee had suggested that the level of punishment should begin with a fine of Rs. 200,000/- which may extend up to Rs. 10,00,000/- along with an imprisonment for a term of 3 months which may extend up to one year, for offences as described under Sec. 42 (3) of Draft Seeds Bill 2019. The Parliamentary Standing Committee also recommended that for repeated violations/offences, punishment should be in consonance with penalties provided in Sec. 73 of PPV&FR Act 2001.
It is important to have penalty clauses which are in proportion to damage/losses caused to farmers and in proportion to the seed stocks produced or stored by the offende,r and not just as fixed amounts. Penalties should also include seizure of the assets of the seed company. This will then act as a real deterrent.
There is a need to publish the names of all seed producers, dealers, processors and others whose varieties have been cancelled or who have been charged with contraventions of the statute.
4. IMPORT OF SEED SHOULD BE AVOIDED/DISCOURAGED: In a statute like the Seeds Bill, India needs provisions that do not encourage or liberally allow for import of seed from elsewhere.
Import of seed should be prevented and discouraged since this is a matter of sovereignty and autonomy of the nation as well as the farming community, apart from potential economic impacts that such imports can have. This can be done for commercial purpose if at all, only after pest risk analysis and local adaptability have been studied. Multi-locational agronomic trials must be done in India and in states where such registration is sought and cannot just be on the basis of the data furnished by the importer. Further, foreign seed certification or self-testing cannot be held valid in India. Liability clause must ensure that seed importer is held responsible for any pest/disease outbreak, weed invasion, genetic contamination and for subsequent clean-up operations.
Contamination of domestic non-GM plants will destroy India’s competitive advantage for non- GM and/or organic crops when GM seeds are imported, including inadvertently. Seed imports should not be allowed at all in India for those crops from countries which grow transgenic varieties of those crops when those varieties are not allowed in India under the Indian regulatory regime for gene technologies. A Schedule should be annexed to the Act, to list countries and crops whose imports must not be allowed in India, including those which are into field testing in other countries.
Testing facilities and capacity for surveillance at ports of import must be strengthened and testing procedures followed without exception to ensure that GM seeds do not come in stealthily as country of origin is often masked by trans-shipments.
All of this has not been adequately addressed in the current version of the Bill (Chapter VII of the 2019 Bill) even though pointed out in the past, including in the form of some recommendations by the Parliamentary Standing Committee in its report.
5. HORTICULTURE NURSERIES TO BE REGULATED: It is not clear why the 2019 version refers to only Fruit Nurseries and not Horticulture Nurseries in a specific provision for the purpose. We note that the definition of Agriculture in this version covers Horticulture also, and that the earlier versions covered Horticulture Nurseries. It is important to regulate horticulture nurseries since many vegetable farmers depend on seedlings supplied by nurseries and do not plant seeds directly themselves, and horticulture covers fruit species also.
6. REGISTRATION DETAILS AND PROCESS:
a. Registration can be at the state level too, by the State Seeds Committee, as is now being proposed in the Draft Seeds Bill 2019.
b. Registration should have a non-exclusivity clause which allows others also to sell the same seed variety under any other brand name, provided that the other brand or label also gets registered under the Seeds Act.
c. Registration under this Act should be termed as “Registration for Performance” in a process that is distinctly different from the existing varietal release system in the country, and from the registration after DUS testing in the Plant Varietal Registration system under Protection of Plant Varieties & Farmers’ Rights Act 2001. Any overlaps with the other system need specific sub-provisions to be built into the Seeds Bill. Any other permission or clearance system for sales, processing etc., should be termed as Licensing, while Approval/Permission granting systems exist under Environment Protection Act, Plant Quarantine Order etc.
d. The registration details, which should be put out in the public domain, should consist of geographical location, seed passport data, results of local agronomic trials in different growing conditions which should be conducted only by accredited government/semi-government/
e. Registration should also have a mechanism of random pre-registration testing against the claims of the applicant. This is something that has also been recommended by the Parliamentary Standing Committee on Agriculture in 2006-07 on the Seeds Bill 2004.
f. Seeds registered should be sent to NBPGR for retention in the National Gene bank.
7. EXEMPTIONS NEEDED FOR FARMERS’ INSTITUTIONS PRODUCING AND SELLING SEED: There is a need to provide some exemptions in this proposed legislation for all-farmers’ institutions which have explicitly been created for seed production and supply (like FPOs into seed production and trade). In all such cases that get exemptions, the government should take additional responsibilities, like the responsibility for seed certification etc. Exemptions should be correlated to criteria like distance of sale from the seed producing FPO, turnovers etc.. This should be included into Seeds Bill 2019 Sec. 47 provisions for exemptions from provisions of the Act for certain organisations.
8. TRANSPARENT AND INDEPENDENT FUNCTIONING: Any proposed institutional set up should have clearly laid down, pro-active mechanisms for information-sharing and transparent decision-making so that corruption and arbitrariness can be tackled. Such mechanisms are best set up at a decentralised level rather than in a highly centralised manner. The Central and State Seed Committees should have more representatives in the form of independent public professionals (independent from the industry) and farmers’ representatives.
9. REMOVAL OF CONFUSION WITH ANY OTHER LEGISLATION: The term “registration” and the implied understanding in various debates with regard to exclusive marketing rights (as contained in the Protection of Plant Varieties and Farmers Rights Act 2001) that accrue from such registration under the proposed legislation should be clarified (some comments of the Parliamentary Standing Committee 2006-07 also reflect this). This legislation is not meant for any exclusive or any other kind of marketing rights. It is about the requirement to register before making money on seed as a commodity and about delivering against claims. Therefore, the term “registration” in this proposed legislation should be changed to “Registration of Varietal Performance” and “Licensing for seed sales, seed stocking, seed processing, seedling nurseries etc.” to remove any confusion on this front. Similarly, any overlaps with the notified seeds system (after plant varietal release processes are followed, and the released variety is notified in an Official Gazette) should be explicitly incorporated into the Seeds Bill through suitable sub-provisions.
10. SEED TESTING LABS: All seed testing labs related to the Act and its implementation should be equipped to take up testing for transgenic and gene-edited seeds also, at an LOD of at least 0.01% (and revised to match the latest technical abilities in terms of lowering the LODs), with primers available for event-specific testing, which also test for suspected-to-be-illegal GM seed samples deposited by public interest groups. There is a need for periodic audit of performance of the labs.
SPECIFIC AMENDMENTS PROPOSED ON THE SEEDS BILL 2019
1. Amendment in the objective of the Bill: A bill to provide for regulating the quality of seeds and their price for sale, import and export and to facilitate timely availability of appropriate and adequate quantities of diverse varieties of seed to farmers in a transparent and accountable regime that compensates farmers for losses due to poor quality seed, and for matters connected therewith or incidental thereto.
2. In “Preliminary”, Section 1, Clause 3, Sub-clause (b): “provided that nothing in this Act shall restrict the rights of the farmer to grow, save, use, exchange, barter, share or sell his/her farm seed and planting material except when s/he sells such seed or planting material under a brand name already registered under this Act”.
3. In the “Definitions” section, sub-section 2, insert: “Branded seed is such seed that is expressly sold in a packed container with a label and under a trade name, and cannot be farmers’ varieties”.
4. In the Definitions section, Section 2, sub-section 11: amend to “Farmer means any person engaged in the economic and livelihood activity of agriculture, who cultivates crops or other primary agricultural commodities, either by cultivating the land her/himself or through any other person, with or without land ownership, but does not include any individual, company, trader or dealer who engages in the procurement and sale of seeds on a commercial basis”.
5. In the Definitions section, Section 2, sub-section 12: Revert back to the definition of Horticulture nursery and do not limit to Fruit Nursery.
6. In the Definitions section, Section 2, sub-section 20: “Producer means any person, group of persons, firm or organization which grows or organizes the production of seed for commercial purpose, but does not include a farmer or a farmers’ organization consisting of more than 75% membership of farmers producing seed for other farmers with government certification support”.
7. In the Definitions section, Section 2, sub-section 21: “Registered kind or variety” in relation to any seeds means any kind or variety thereof, registered under Section 13, specifically understood as authorization or licensing for commercial seed trade without any plant varietal rights accruing.
8. Section 4 on Composition of Central Seed Committee: amend 4 (4) (vi) to – four independent specialists or experts in the field of seed development, including from civil society organisations.
9. Section 5 on Powers & Functions of the Committee: Insert 5 (c) to the current Section 5: “Seed Price control and Supply, including procedure for fixing seed prices and royalties”, Insert 5 (d) as: “Compulsory licensing of seeds where needed, especially if not covered for the variety under PPV&FR Act 2001”, Insert 5 (e) as “Regulation of advertising of seeds where required”and re-number the remaining list.
10. Section 7 on Registration Sub-Committee: Section 7 (2) (a): Change to “To register seeds of varieties after scrutinizing their claims as made in the application in such manner as may be prescribed including random pre-registration testing”.
11. Section 11 on State Seed Committee: Amend 11 (a) to – “to register State seed varieties suitable for the state, based on independent verification of agronomic trials’ data and to fix prices of seeds registered”; Add 11 (g): “to collect data and review performance of seeds after the authorization through licensing”; Add 11(f): “to order compulsory licensing where required”.
12. Section 14 (1) on Registration of seeds of any kind or variety: Amend to: “No seed of any kind or variety shall, for the purposes of sowing or planting by any person be sold, except by a farmer as defined in this Act, unless such kind or variety is registered under Sub-Section (2)…”.
13. Section 15 on Procedure for Registration: Insert after 15 (1): “provided that every application for registration under Section 14 shall contain a complete passport data of the parental lines from which the kind or variety has been derived from and wherefrom the genetic material has been sourced and all such information relating to the contribution, if any, of any farmer, village community, institution or organization in breeding, evolving or developing the kind or variety”.
Correct the typo in Sec. 15 (2) to “as the case may be, shall, after such enquiry as it deems fit,…”
14. Section 15 on Procedure for Registration: Change 15 (2) to include pre-registration testing in the following manner: “On receipt of any application for the registration of a kind or variety of seed, the Registration for Varietal Performance Sub-Committee including at the state level, shall, after such mandatory testing as required, and other such inquiry that it deems fit and after satisfying itself that the kind or variety of seed to which the application relates to, conforms to the claims made by the importer or the producer/seller, as the case may be, as regards the efficacy of the kind or variety of seed…..(REST FROM THE BILL) and issue a certificate of registration for performance; further provided that such registration details will be put up in the public domain by the Central and State Seed Committee, in a format as prescribed”.
15. Section 20 on Evaluation of Performance: Include the phrase “independent” as suggested hereunder: “20. The Committee may, for conducting trials to assess the performance, accredit centres of the Indian Council of Agricultural Research, State Agricultural Universities and such other independent organizations fulfilling the eligibility requirements as may be prescribed, to conduct trials to evaluate the performance of any kind or variety of seeds”.
16. Section 21 on Compensation to Farmer: The following to be substituted as Section 20 (1): “Where the seed is sold to the farmer of a registered kind or variety by the producer, dealer, distributor or vendor as the case may be, s/he shall disclose the expected performance of such kind or variety to the farmer under given growing conditions and if such registered seed fails to provide the promised performance under such given conditions, the farmer may claim such compensation from such producer, dealer, distributor or vendor as may be determined by a District Level Compensation Committee set up under this Act by the state government for the purpose which is to adjudicate within a month of receiving the claim, provided that such compensation is equal at least to the monetary value of the promised performance and also compensates for the costs incurred by the farmer, and provided that such compensation is paid to the farmer after the Compensation Committee’s proceedings and orders within 3 months’ time”.
17. Section 22 onwards related to registration of processing units, seed dealers and nurseries: The term licensing may be substituted for ‘registration’. The registration of Horticulture nurseries to be included, and not just fruit nurseries of more than one hectare area.
18. Section 27 on Regulation of Sale Price in Emergent Situations: Regulation of Sale Price in emergent situations may be deleted, and instead, as suggested in Points 9 and 11 above, with regard to functions of Central Seed Committee and State Seed Committee, regulation of seed prices should be a key routine function of these Committees.
19. DELETE Section 32 completely on recognition for seed certification agencies in territory outside India.
20. Section 34, on Central and State Seed Testing Laboratories: Add, sub-section 34 (6) as following: “All seed testing laboratories shall be equipped to take up testing for transgenic and gene-edited seeds also, at an LOD of at least 0.01% (which is to be revised periodically to match the latest technical abilities to test at lower Levels of Detection), with primers necessary for event-specific testing; provided that such labs also test samples deposited by public interest groups of suspected unauthorized genetically modified seeds, transgenic or gene-edited”. Add, sub-section 34 (7) as: “all seed testing labs shall have to be audited periodically for conforming to standards and practices as prescribed”.
21. Section 40, sub-section 1 on Import & Export of Seed: Change 40 (1) (c) to: “All import of seed meant for commercial purposes shall be subject to registration as may be granted on the basis of information furnished by the importer as well as the results of multi-locational trials conducted in such an independent manner and for such period as may be prescribed to establish performance in India and specifically in the agro-ecological areas where the seed is sought to be sold. Further provided that no seed including transgenic seeds being commercially cultivated or field-tested in other countries, included in Schedule XYZ of the Act can be imported into India”.
22. Section 42 on Offences and Punishment: Substitute the following after ‘be punishable with’ – “a fine in proportion to the damage caused, and quantity of seed supplied or stocked or turnover value to cover real and potential loss to farmers, which shall not be less than Rs. 500000/- (five lakh rupees), which may extend to Rs. 10,00,000 (ten lakh rupees) and imprisonment for three months to one year, in addition to seizure or attachment of assets of the offender. Further, any individual or company convicted under this Act may be banned from any seed-related activity by the state government upon subsequent convictions. The state seed committee and central seed committee, as the case may be, shall publish a list of all seed producers and dealers/distributors/
23. Section 47 on ‘Exemptions from Provisions of Act’: Add to ‘any educational, scientific, research or extension organisation’, “farmer producer organisations”.
We urge you to ensure the above-mentioned changes in the Draft Seeds Bill 2019 before it is tabled in the Parliament, passed and notified. These changes are essential especially given that profiteering in the seed trade at the expense of farmers has been already linked to the current agrarian crisis including the unconscionable toll of farmers’ suicides in this country.
To uphold the rights and the best interests of farmers in this country, this legislation should be seen as the mechanism by which commercial seed traders can be regulated for quality and pricing through decentralized, constitutionally-mandated institutional mechanisms as opposed to the very centralized mechanisms that are present right now. We are also attaching an annexure on gaps from suggestions made by Parliamentary Standing Committee on Seeds Bill earlier and what is in the current Bill version.
1. Ajmer Singh Lakhowal, Bharatiya Kisan Union, Punjab
2. Akash Naoghare, Beejotsav Group, Nagpur
3. AK Devison, Kerala Coconut Farmers Association & South India Coordination Committee of Farmers Movements, Kerala
4. Alladi Mahadevan, Green Embryo
5. Ambika Das, Pani Laguri, Jayanti Kairam and others from Omon Mahila Sanghatan, Singhbhum West, Jharkhand
6. Ananthasayanan, Safe Food Alliance, Tamil Nadu
7. Avil Borkar, Gramin Yuva Pragatik Mandal, Bhandara, Maharashtra
8. Badagalapura Nagendra, President, Karnataka Rajya Raitha Sangha, Karnataka
9. Balaji Shankar, Tharcharbu Iyakkam, Sirkali
10. Bhanuja Cheruvu, REDS, Andhra Pradesh
11. Chamarasa Mali Patil, Karnataka Rajya Raitha Sangha, Karnataka
12. Chukki Nanjundaswamy, Karnataka Rajya Raitha Sangha, Karnataka and Amrithabhoomi
13. CK Janu, Adivasi Gothra Mahasabha, Kerala
14. Dhan Singh Sherawat, State President, Bhartiya Kissan Union (BKU), Maharashtra
15. Dr Devinder Sharma, Agriculture policy analyst, Chandigarh
16. Dr G S Koushal, Retd. Director Agriculture Department, Madhya Pradesh
17. Dr Satish Gogulwar, Amhi Amchya Arogyasathi, Gadchiroli, Maharashtra
18. Dr Tarak Kate, Chairman, Dharamitra, Wardha, Maharashtra
19. Dr V Rukmini Rao, Executive Director, Gramya Resource Centre for Women, Telangana
20. Gopi Deva, OFM-Organic Farmers Market, Chennai
21. Gurudas Themaskar, Sandesh, Gadchiroli
22. Harish Panwar, Beej Swaraj Manch, Madhya Pradesh
23. Jagdish Singh, Bharatiya Kisan Union, Madhya Pradesh
24. Kalpana Salunke, Pani Panchayat
25. Kannaiyan Subramaniam, South India Coordination Committee of Farmers Movements
26. Kapil Shah, Jatan, Vadodara, Gujarat
27. KM Rajegowda, Karnataka Rajya Raitha Sangha, Karnataka
28. K. Sella Mutthu, President, Tamil Nadu Farmers Association, Tamil Nadu
29. Kshitij Urs, RRA-N Karnataka
30. KT Gangadhar, Karnataka Rajya Raitha Sangha, Karnataka
31. KV Rajkumar, South Indian Sugarcane Growers Association, Tamil Nadu
32. Lakshman Singh Muniya, Lok Jagruti Manch, Madhya Pradesh
33. Lingaraj Pradhan, Paschim Odisha Krushak Sangathan Samanvaya Samithy, Odisha
34. Malathi, AMM eco house
35. Mohanan, Green house Terrace garden consultants
36. MS Selvaraj, VTMS, Tamil Nadu
37. Naba Nirman Krushak Sangathan (NNKS), Odisha
38. Natabar Sarangi, organic farmer and conservator of traditional paddy varieties, Odisha
39. Nilesh Desai, Sampark, Madhya Pradesh
40. Prakash Mahendran, Farmer and Senior Engineer at Arcadis, Karnataka
41. Pravin Mote, Centre for People’s Collective, Nagpur
42. Praveen Gaur, Farmer, Kharangna Gode, Wardha
43. Prof. Radhamohan, Founder, Sambhav and former Information Commissioner, Odisha
44. Radhika Rammohan, reStore, Chennai
45. Rajbir Singh Jadaun, State President, Bhartiya Kissan Union (BKU), Uttar Pradesh
46. Rajesh Krishnan, Thirunelly Farmer Producer Company, Wayanad, Kerala
47. Rakesh Tikait, National Spokesman, Bharatiya Kisan Union
48. Ram, Samanvaya Consulting
49. Ratan Singh Mann, Bharatiya Kisan Union, Haryana
50. Ravindranath, Kerala Coconut Farmers Association, Kerala
51. Rohit Parakh, India for Safe Food, Mumbai
52. S Venkatesan, South Indian Sugarcane Growers Association, Tamil Nadu
53. Saroj Mohanty, Convenor, Deshi Bihan Surakhya Mancha, Odisha
54. Satnam Singh Cheema, State President, Bhartiya Kissan Union (BKU), Uttarakhand
55. Seethalakshmi, Safe Food Sunday’s
56. Selvam Ramasamy, Tamil Nadu Organic Farmers’ Federation, Erode
57. Sharanya Nayak, HUMANE, Koraput, Odisha
58. Shuba Baharadwaj, Safe Food Alliance, Tamil Nadu
59. Sridhar Radhakrishnan, Thanal, Kerala
60. Srinivasa Lakshman Karumajji, Farmer, GoCharana Bhumi Farm, Visakhapatnam
61. Subhash Chaudhary, Bharatiya Kisan Union, NCR
62. Sukhdev Singh Gill, State President, Bhartiya Kissan Union (BKU), Himachal Pradesh
63. Sundarajan, Poovulagin Nanbargal
64. Suresh Lakshmipathy, Go Organic Life, Chennai
65. Thalanmai Uzhavar Iyakkam, TamilNadu
66. Umendra Dutt, Kheti Virasat Mission, Punjab
67. Usha Soolapani, Save our Rice Campaign, Trivandrum
68. V B Chandrasekaran, Founder Trustee, Mahatma Gandhi Sabari Ashramam, Chatti Post, East Godavari district, Andhra Pradesh
69. Vasant Futane, SANWAD, Amravati, Maharashtra
70. Vidyadhar Olkha, State President, Bhartiya Kissan Union (BKU), Rajasthan
71. Vijender Singh, Bharatiya Kisan Union, Haryana
72. Virendra Dagar, Bharatiya Kisan Union, Delhi
73. Yudhvir Singh, National Secretary, Bharatiya Kisan Union & All India Coordination Committee of Farmers Movements
Copy to: (1) Secretary, Ministry of Agriculture & Farmers’ Welfare; (2) Joint Secretary-Seeds, Ministry of Agriculture & Farmers’ Welfare