Response to FFRC letter dated 19th November 2020, in response to our letter dated 5th November 2020 on Planned Mandatory Fortification in India of Edible Oils and Rice

Mr Ashok Kumar Mishra,
Assistant Director, FFRC (Food Fortification Resource Centre)

 Sub: Response to FFRC letter dated 19th November 2020, in response to our letter dated5th November 2020 on Planned Mandatory Fortification in India of Edible Oils and Rice

Dear Shri Ashok Kumar Mishra,

This is a long overdue response from our side to your letter addressed to Ms Usha S, dated 19th November 2020 which was in turn a response to our earlier letter from 5th Nov 2020 with the subject, “Regarding FSSAI’s planned mandatory fortification of Edible Oil with Vitamin A and Vitamin D and Rice with Vitamin B12, Iron and Folic Acid”. We appreciate your detailed response. However, we continue to have serious concerns about the implications of mandatory fortification on health and livelihoods in India and share these with you below along with solid supporting evidence.

Questions on efficacy of Fortification remain unanswered – a blanket approach cannot meet the complexity of malnutrition in our country 

It is well known that undernutrition in the form of protein and calorie inadequacy is a fundamental problem in India, which the WHO confirms is a certain contributor to vitamin and mineral deficiency. Monotonous cereal-based diets, and low consumption of vegetables, eggs, milk, flesh foods, and fish have worsened the nutritional scenario, resulting in multiple vitamin and mineral deficiencies. According to the latest NSSO data, the share of calories from protein sources for Indians is only 6–8% (Bamji et al. 2020). In such a scenario, adding one or two synthetic vitamins or minerals in the absence of adequate calorie and protein consumption may in fact be toxic and have adverse outcomes in undernourished populations (Tiwari et al. 2011). For instance, iron fortification is known to have caused gut inflammation and pathogenic gut microbiota profile in undernourished children (Zimmermann et al. 2010).

Your letter states that the dosages of micronutrients added to staples is adjusted to provide 30-50% of an individuals’ daily nutrient requirement. Nutrition science shows that Recommended Dietary Allowance (RDA) has limitations when applied to an undernourished population. RDA for an individual nutrient is calculated only when the RDA for all other nutrients is met (NIN 2008). Thus, RDA cannot be invoked for undernourished populations because of huge protein energy deficits. In all likelihood, fortification could result in toxic outcomes for undernourished populations and is highly concerning.

Fortification with one or two chemicals to address one nutrient deficiency will be limited by another nutrient deficiency.  For e.g. haemoglobin synthesis requires not just iron but good quality proteins and many other micronutrients as well (Dary 2011). Apart from iron, Vitamins A, C,E, B2, B6, B12, folate, magnesium, selenium, zinc are needed for hemoglobin synthesis. Only a diet that contains good quality proteins, vitamins and minerals will be able to address multiple nutrient deficiencies. Isolated nutritional deficiencies are unlikely in an undernourished population. Thus, this proposal for mandatory fortification citing RDA for micro nutrients while not taking into account the shortfall in macro nutrients of the population, is specious.

There are several studies that challenge the efficacy of fortification. The 2021 study by experts from the ICMR, AIIMS and the Ministry of Health published in the Journal of Nutrition highlights that increasing iron intake alone has no impact and cannot replace dietary diversity, which facilitates iron absorption while providing all other hematopoietic nutrients (Kulkarni et al. 2021). A meta-analysis of data from several rice eating countries shows that rice fortified with iron, vitamin A, or folic acid made no difference to anemia and little difference to Vit A deficiency (Peña-Rosas et al.2019). Even for double fortified salt (DFS), which is widely promoted by the government through PDS and mid-day meals programs, large scale trials of effectiveness don’t exist and there is little evidence of efficacy, while organoleptic changes have been significant (Kapil & Sareen 2014; Yadav et al. 2019).

Another important concern is the high level of carbohydrate consumption in India which is linked to diabetes, hypertension, heart disease and makes the focus on cereals as the vehicle of mandatory fortification as ill-advised as it will create a further dependence on cereals for essential vitamins and minerals at the cost of other nutrient dense food groups (Mohan et al. 2018). 5.4% children under five, 38.1% women and 45.3% men are already overweight or obese in India according to the NFHS 5.

Is prevalence data on micro-nutrient deficiencies reliable, or is it opportunistically cited and used by the government?

There is no consensus about the prevalence of vitamin and mineral deficiencies in India. For instance, according to one set of scientists, anemia is over diagnosed based on their 2021 study published in the Lancet conducted by Indian scientists (Sachdev et al. 2021). Yet another 2021 study by researchers from the National Institute of Nutrition, St Johns, and the Sitaram Bhartia Institute of Science and Research published in the American Journal of Clinical Nutrition and based on latest CNNS (Comprehensive National Nutrition Survey 2018-19) data show that vitamin A deficiencies in young children are no longer a public health problem (Reddy et al. 2021). They warn that continuing with supplementation programs, and we include mandatory fortification, can lead to hypervitaminosis. Such studies are contradictory to FSSAIs portrayal of national scale deficiencies. How can any large scale and mandatory fortification program be put in place when such confusion exists about the extent of nutrient deficiencies?

Indeed, the picture of national scale vitamin and mineral deficiency differs across classes, and regions requiring diverse and localized approaches. FSSAIs portrayal shows that the government is comfortable with contradictory evidence used opportunistically to defend its inaction to address the issue of malnutrition holistically and to facilitate agribusiness led reductionist solutions.

Economic impacts on local economy and livelihoods

Existing evidence shows that mandatory fortification of foods will have adverse economic impacts on consumers as well as informal players like small rice millers, oil ghanis/cold press oil mills, small farmers, and local enterprises. According to the FSSAI, international corporations will have the key role in supplying micronutrients, while Indian manufacturers will develop pre-mixes for essential food commodities, but there is no mechanism in place for price control of such micronutrients. Just five corporations have derived most of the benefits of global fortification trends and these companies have historically engaged in cartelizing behaviour leading to price hikes. The EU has even fined such companies for their cartelizing behaviour (Jitendra 2019). How will the FSSAI ensure that prices of such items are regulated?

Although FFRC in its letter claims that medium and large rice millers are being encouraged to fortify rice, the process itself is expensive and mandatory fortification will lead to many more small rice millers shutting down.  An indicative cost of producing rice through fortification for a medium sized mill is Rs 3.2 crore (as mentioned in Pilot Scheme Fortification of Rice and its Distribution under Public Distribution System). The rice millers associations in Punjab and Haryana had been protesting against these new norms of fortification of rice since March 2021, and have forced the FCI to relax norms (Tribune News Service 2021).

Globally and in India, studies have shown that fortification programs lead to increased market share of formal players, and reduce market share of the informal sector (Dury et al. 2019; Fiedler et al. 2012). Even if small players are able to undertake such fortification activities, the costs for them are prohibitive. Evidence shows that large-scale processing firms tend to coordinate with larger producers through contracts to secure scale and homogenous quality of raw material supply (Nwuneli et al. 2014). Even when included, smallholders may not always benefit from contracts (Dury et al. 2019). Given the centrality of agrarian livelihoods to India, has the FSSAI conducted any economic and social impact studies on long term impacts of centralized and corporate led food fortification on livelihoods and local economy?

Why is fortification mandatory but dietary diversity optional?

It is heartening to learn that the Authority does not consider fortification to be exclusive of, or alternative to food diversity, but It doesn’t not seem like the FSSAI is promoting dietary diversification with the same energy or commitment as fortification. If the two are complementary approaches and if “fortification only bridges the gap between the need and actual consumption of required micronutrients” as stated in your letter, then why is fortification mandatory and dietary diversity not? We already know that dietary diversity is the non-negotiable factor when it comes to nutrition and could be complemented by other approaches like supplementation.  When fortification becomes mandatory it will be the key policy approach while the other more critical holistic approach will not have a similarly enthusiastic policy support. Once iron-fortified rice is sold as the remedy to anaemia, the value and the choice of naturally iron-rich foods like millets, varieties of green leafy vegetables, flesh foods, liver, to name a few, will have been suppressed by a policy silence. Your letter states that fortification is not new with Vanaspati and iodized salt fortified in the 50’s and 60’s, but we would urge the FSSAI to stick to current and evolving independent science which is questioning reductionist approaches to complex problems.

While the FSSAI’s ‘Eat Right India’ is creating awareness about local and seasonal food according to your letter, what is the message when it is fortification that finds a mandatory stature and a huge emphasis even in documents of Eat Right India/Eat Right School, while local alternatives like kitchen gardens, poultry, livestock, fish ponds, and numerous other initiatives barely find any mention despite being a tested solution to malnutrition. Even government schools, anganwadis, State Rural Livelihood Missions are increasingly showing greater interest in kitchen gardens while the FSSAI’s key emphasis is on fortification.

Why push irreversible and costly approaches with dubious impact when more cost-effective alternatives exist?

The FSSAI has said that fortification is a ‘cost effective’ option for easy nutrition to the masses. However, the long-term costs of fortification will be profound and irreversible. Mandatory fortification will lead to irreversible infrastructural and market shifts, including consolidation of corporate power; for instance, in our previous communication we already pointed out that current fortification schemes will create a market of over 3000 crores for just 5 big companies (Jitendra 2019).

A worrying long-term consequence of fortification is that it creates reliance on packaged foods and removes the focus from local foods, their production systems and eating practices. Dependence of large and diverse communities on packaged foods, means a regular source of income for corporate actors which will have no qualms in hiking prices.

Will the government be able to reverse fortification and its consequences once large-scale vitamin and mineral deficiency is resolved? Will the government be able to reverse manufactured dependence on cereals which can intensify large scale diabetes and hypertension, both a result of heightened triglycerides and insulin resistance from too much carbohydrate consumption?

There are already functioning and cost-effective alternatives like supplementation programs that already exist and can be made available right at the local level. Many experts have made recommendations on how to improve on-going supplementation programs to achieve better impact and this is a better strategy than irreversible interference with our food systems.

Conflict of interest in some of the quoted studies and need for more independent studies
Three of the authors of the meta-analysis cited as Reference 5 in your letter (Keats et al. 2019) are from GAIN (Global Alliance for Improved Nutrition) which is a front for food companies and whose focus is on promoting fortification. Indeed, the study was funded by GAIN, which points to a strong conflict of interest. The study cited as Reference 6 in your letter was funded by the Nestle Nutrition Institute, which is an arm of a corporation that sells fortified foods and will directly benefit by such studies (Das et al. 2013). In various sectors, companies with vested interests often conduct studies that promote their own products, whether it be soft drinks, infant milk formulas, or tobacco. The FSSAI appears to be wilfully ignoring such conflict of interest by industry before promoting their products in the form of mandatory policy without any independent studies.  There is a need for more independent studies not only on fortification but also comparing it with other solutions mentioned here.

Holistic solutions

It is clear that the solution to malnutrition and vitamin and mineral deficiency has to be centred on protein-based adequate calorific intake from animal and plant-based diets. There are many holistic solutions that are easily scalable. Such solutions empower local communities themselves to improve their nutrition and don’t create dependencies on external or global market players. This preserves local food sovereignty, even as solutions are biocultural.

Localization of diets should be an important first step approach from a nutrition standpoint. Instead of promoting homogeneous cereals across the country, it would be more effective to tap into the appropriate varieties of staple foods in a particular region, which are naturally rich in vitamin and minerals. For example, among plant-based foods, there exist at least 68 indigenous varieties of rice with very high (20 – 300 ppm) iron content (Deb et al. 2015; Sen Gupta et al. 2017). Several millets and vegetables are a rich source of iron, zinc and B vitamins. A wide range of vegetables (e.g. tender leaves of taro yam, amaranth, mustard, radish, Ipomea aquatica) and fruits such as pumpkin, papaya, mango etc. are known to contain a copious amount of beta carotene (Pritwani & Mathur 2017; Wall 2006). There are also a range of uncultivated food plants with high amounts of beta carotene and B vitamins (Deb 2018; Gupta et al. 2005), and most of these are available at no cost to the rural poor (Deb 2018). Several B vitamins have also been detected in more than 300 folk rice varieties (Roy et al. 2020). These same rice varieties and vegetables also contain calcium, zinc and phosphorus – vitamin and mineral s not even addressed in the fortification program document.

Even more important are nutrient-dense animal-based foods like eggs, meat, dairy, fish and even insects which are eaten in several parts of India.  Instead of promoting these fully, but in a holistic and sustainable fashion that does not base itself on factory-farming of animals, the Government of India as well as state governments are thrusting a selective dietary approach into the existing food schemes of the Government, apart from this thrust on corporate-friendly fortification.

Locally made fortificants or food-to-food fortificants are another effective intervention to address vitamin and mineral deficiency. These include syrups, biscuits, porridges, powders and various products made from locally available ingredients like starchy foods, insects, green leafy vegetables, other vegetables, fruits, flowers, nuts, oils, and animal products (Kruger et al. 2020). Studies show that such food fortificants, when added to food, can improve nutritional status of consumers, while supporting local livelihoods and small local businesses (Chadare et al. 2019).

Community level nutrition approaches, like kitchen gardens, fish ponds, backyard livestock are proven methods in improving household nutrition security. Local households, women’s groups, farmers collectives, small businesses can easily be supported via such approaches to play a role in feeding their communities especially in times of crises like the recent pandemic. Several kitchen garden efforts have successfully reduced vitamin and mineral deficiencies, improved dietary diversity and protein consumption, and led to deep community level education around nutrition (Bamji et al.2020).

Reducing processing from polishing or refining is another important recommendation that FSSAI must make. For rice, the obvious solution is unpolished/less polished rice which has more nutrients. For edible oil, promoting unrefined cold pressed or filtered oils which are known to be more nutritious must be promoted. It is a tragedy that first vitamins and minerals in oils and rice are removed via polishing or refining and added later on at a huge cost in the name of fortification. The FSSAI should not have a discriminatory approach against unpolished rice or unrefined oils by mandating fortification.

It is evident from the current dismal indicators around nutrition in the country, that isolated deficiencies are not the problem, but the poor access of most people to nutrient dense foods in adequate quantities. Addressing individual deficiencies with mandatory fortification is not a solution but only a way of routing public funds to the corporate sector.  The government has to increase investment into local food systems that includes animal source foods (meat, milk/dairy, eggs, poultry, fish), pulses, vegetables, legumes etc. as a way of improving sustainable food production as well as local livelihoods.

We would like to continue this dialogue with the FSSAI and urge that reductionist, pro corporate, irreversible, and unnecessary steps like mandatory fortification are not taken at the expense of our food sovereignty and dietary diversity.

Endorsed by:

  1. Usha Soolapani, Save our Rice Campaign, Kerala
  2. Dr Veena Shatrugna, Former Deputy Director at the National Institute of Nutrition, Hyderabad
  3. Dr Debal Deb, Basudha Laboratory for Conservation, West Bengal
  4. Dr Vandana Prasad, Technical Advisor, Public Health Resource Network
  5. Dr Arun Gupta, Convener, Alliance Against Conflict of Interest
  6. Dr. Umesh Kapil, Professor, Department of Epidemiology and Clinical Research, Institute of Liver & Biliary Sciences, New Delhi
  7. Dr. Richa Kumar, Associate Professor of Sociology and Policy Studies, Indian Institute of Technology Delhi
  8. Kapil Shah, Concerned citizen and Jatan, Vinoba Ashram, Vadodara
  9. Dwiji Guru, Nutrition conscious Millet Processing consultant & Sustainable Food Systems activist, Karnataka
  10. Radha Holla Bhar, Independent researcher on food systems, nutrition and conflict of interest
  11. Dr Sylvia Karpagam Public health doctor, Karnataka
  12. Kavitha Kuruganti, Convenor of Alliance for Sustainable & Holistic Agriculture (ASHA)
  13. Krishna Prasad, Director, Desi Seed Producers Company Ltd ,Mysore, Karnataka
  14. Dr Jayati Ghosh, Professor of Economics, University of Massachusetts at Amherst, USA
  15. Avik Saha, National Convenor, Jai Kisan Andolan
  16. Dharmendra Kumar, Bhartiya Kisan Union
  17. Karnataka Rajya Raitha Sangha
  18. South Indian Coordination Committee of Farmers Movements
  19. Meera Sanghamitra, National Alliance of People’s Movements (NAPM), Telangana
  20. Dr. Mira Shiva, Public Health Physician, Delhi
  21. Ulka Mahajan, Social Activist, Maharashtra
  22. S. Ashalatha, Rythu Swarajya Vedika, Hyderabad, Telangana
  23. Siddharth Jaiswal, Independent Researcher and Social Entrepreneur, Jharkhand
  24. Arun Dike from Rangwasa Jaivik Gram Sansthan Indore
  25. Dilnavaz Variava, The Sahayak Trust, Maharashtra
  26. Karthik Gunasekar, Volunteer, Chennai Climate Action Group, Tamilnadu
  27. Vijay Jhardhari, Beej Bachao Andolan
  28. Anuradha Talwar, Paschim Banga Khet Majoor Samity, West Bengal
  29. Nachiket Udupa, Mazdoor Kisan Shakti Sangathan, Rajasthan
  30. Dr. M.L Sanyasi Rao, Watershed Support Services and Activities Network, Telangana
  31. Dr SS Roy, BAIF, Pune
  32. Uma Shankari, Farmer-researcher-activist, Venkatramapuram, Andhra Pradesh
  33. Aruna Rodrigues, Sunray Harvesters, Mhow, M.P India
  34. Jayesh Joshi, Vaagdhara, Rajasthan
  35. K V Biju, Swadeshi Andolan
  36. Aysha Khan, Right to Food Campaign
  37. Sreedevi L, Anantha, Coimbatore
  38. Sridhar Radhakrishnan, Food activist, Kerala
  39. Ananthoo, coordinator, Safe Food Alliance/ ASHA, Tamil Nadu
  40. Dr Ramanjaneylu, Center for Sustainable Agriculture, Hyderabad
  41. Jacob Nellithanam, Convenor, Bharat Beej Swaraj Manch.
  42. Pallavi Sobti Rajpal, Utthan, Gujarat
  43. Nafisa Barot, Gujarat
  44. Karavali Karnataka Janabhivriddhi Vedike, Karnataka
  45. Citizens Forum for Mangalore Development, Karnataka
  46. Indian Social Action Forum (INSAF)
  47. Growthwatch, Karnataka
  48. Karavali Karnataka Janabhivriddhi Vedike, Karnataka
  49. Citizens Forum for Mangalore Development, Karnataka
  50. Indian Social Action Forum (INSAF)
  51. Growthwatch, Karnataka
  52. Parvatiy Tikau Kheti Abhiyan Himachal Pradesh
  53. Gouranga Ch. Mohapatra, State convener, Jan Swasthya Abhiyan
  54. Anil Pradhan, Convener, Odisha RTE Forum. Odisha
  55. Bijaya Biswal, Citizens’ Collective for Public Health, Odisha
  56. Sameet Panda, Co-Convenor, Odisha Khadya Adhikar Abhijan, Odisha
  57. Dr A Vatsala, Bangalore
  58. Vanmala Hiranandani (citizen of India), Associate Professor, Global Nutrition and Health, Copenhagen University College
  59. Ashok Joshi, Himalayan Organic Produce Company, Uttar Pradesh
  60. Sudha Nagavarapu, Researcher & Activist, Independent, Karnataka & UP
  61. Vasant  Futane, Sanwad, Amrawati, Maharashtra
  62. A.K John, Chairman, Fair Trade Alliance Kerala, Kerala
  63. Tomy Mathew Vadakkancheril, Elements, Kozhikode, Kerala
  64. Himakiran, Trustee. Thondaimandalam Foundation, Tamilnadu.
  65. Parthasarathy, Coordinator, Thiruvallur Organic Farmers Group, Tamilnadu
  66. Bindu Mohanty, Concerned citizen, Auroville, Tamil Nadu
  67. Rajeswari S Raina, Professor, Shiv Nadar University, NCR India
  68. Ananthoo, Safe Food Alliance, Chennai
  69. Balaji Shankar, Tharchaarbu Iyakkam
  70. Pamayan, Thaalanmai Uzhavar Iyakam
  71. K.Jagadeesan, Advisor, Federation of Tamil Nadu Rice Mill Owners Association
  72. Radhika Rammohan, Restore, Chennai
  73. Usha Hari, Restore gardens, Chennai
  74. Dhamodharan, Vizhuthgal, Chennai
  75. Sivakumar, Nalla sandhai, Thiruvellore
  76. Raman, Tula India
  77. Suresh L, GoOrganicLife
  78. Gopi Deva, OFM-Organic Farmers Market
  79. Seethalakshmi, Safe Food Sundays;
  80. Alladi Mahadevan, Organic Terrace Gardening ( fyi- this group has 35k members in FB)
  81. Subha Bharadwaj, Mahatma Seva Sangam
  82. Anita Paul, Pan Himalayan Grassroots Development Foundation, Uttarakhand
  83. Jaya Iyer, Khaadhya Nyaaya Abhiyan, Delhi
  84. Puran Bartwal, People’s Science Institute, Uttrakhand
  85. United Artists Association, Orissa
  86. Ajay Rastogi, Majkhali, Ranikhet, Uttarakhand,
  87. Anshuman Das, Food Activist, West Bengal
  88. Rakesh Kumar Pandey, CEO, Shramik Bharati, Kanpur, Uttar Pradesh
  89. Dr V Rukmini Rao, Executive Director, Gramya Resource Centre for Women, Telangana State
  90. Seema Purushothaman, Concerned citizen and professor, Karnataka
  91. Uzramma, Malkha Trust, Hyderabad
  92. Amita Shah, Researcher, Centre for Development Alternatives, Ahmedabad Gujarat
  93. Janchetna Sansthan, Rajashthan
  94. Rudra Narayan Mishra, Assistant Professor, Gujarat Institute of Development Research
  95. Kamayani Bali Mahabal, Co-Convenor, Jan Swasthya Abhiyan- Mumbai
  96. K P Ilias, President, Organic Farmers Association of India
  97. Dr S Santhi, Ecologist and expert on biodiversity
  98. Veena M, Eco Solutions, Trivandrum
  99. Suma Josson, Film maker
  100. Dr A Bijukumar, University of Kerala
  101. Mr Ponnambalam, CREATE Trust, Tamilnadu
  102. Ayu Sattva Organic Group, Chandigarh
  103. Fr. Cedric Prakash SJ, Human Rights and Peace Activist, Ahmedabad
  104. Niranjan Demanna, Greenie Conservatory India Pvt. Ltd, Maharashtra
  105. Scientific Awareness and Social Welfare Forum, Sangrur
  106. WPO Organic Community Cooperative Society, Jalandhar
  107. Sarvahara jan Andolan
  108. Mukta Srivastava, Anna Adhikar Abhiyan Maharashtra
  109. Soumik Banerjee, Independent Researcher, Madhya Pradesh
  110. Akash Naoghare, Beejotsav, Nagpur
  111. Rupinder Nanda, Concerned Citizen, Nagpur
  112. Dr Satish Gogulwar, Aamhi Amchya Arogyasaathi
  113. Gramin Yuva Pragatik Mandal, Bhandara, Maharashtra
  114. Umendra Dutt, Kheti Virasat Mission, Punjab
  115. Paschima odisha krushak sangathan samanaya samiti, Odisha
  116. Deshi bihan suraksha mancha, Odisha
  117. Rajkumar Rai, Project Health & Nutrition, Madhya Pradesh
  118. Anil Kumar, Sahodya Trust, Bihar
  119. Dr. Manab Chakraborty, Partners in Prosperity, Delhi
  120. Shambhu Ghatak, Senior Associate Fellow, nclusive Media for Change Project, Delhi
  121. Fayaz Dar, sagg eco village | mool sustainability research and training center, Kashmir
  122. Deepika Joshi, concerned citizen, Chhattisgarh
  123. Parul Chaudhary, Ekal Nari Shakti Sangathan, Rajasthan
  124. Nirmal Chandel, National Forum for Single Women’s Rights, Himachal Pradesh
  125. Pratibha Shinde, Lok Sangharsh Morcha, Maharashtra
  126. Suman Vasava, Adhyksh, Lok Sangharsh Morcha, Gujarat
  127. Yash Agrawal, concerned citizen, Maharashtra
  128. Swetal Nayak, concerned citizen, Goa
  129. Chandrakant Gadge, NSS, Madhya Pradesh
  130. Vishwambhar Nath Tripathi, Vikas Samvad Bhopal, Madhya Pradesh
  131. Rakesh Kumar Pandey, Shramik Bharti, Uttar Pradesh
  132. Adesh Bhai Preshan, Adarsh Manv Vikash Yuva Gramin Seva Sansthan, Rajasthan
  133. Sachin Jain, Vikas Samvad, Madhya Pradesh
  134. Ramesh Prakash Pandey, Sonanchal Vikas Manch, Madhya Pradesh
  135. Sandip Naik, Concerned citizen, Madhya Pradesh
  136. Chinmay Mishra, Concerned citizen, Madhya Pradesh
  137. Ajay Yadav, बदलाव संस्था पोहरी जिला शिवपुरी, Madhya Pradesh
  138. Rekha Shridhar, Social worker, Madhya Pradesh
  139. Guru Sharan Sachdev, Madhya Pradesh
  140. Ramkumar, Rashtriya Yuva Sangathan, Madhya Pradesh
  141. Aarti Parashar, Vss, Madhya Pradesh
  142. Farhat Nasheen, Public Health Nutritionist, Madhya Pradesh
  143. Ram Naresh Yadav, Social Worker, Madhya Pradesh
  144. Javed Anis, Right to Food Campaign, Madhya Pradesh
  145. Upasana Behar, Madhya Pradesh Lok Sabhagi Sajha Munch, Madhya Pradesh
  146. Jaba, SMOKUS, West Bengal
  147. Ramkalyan Singh Bais, स्वामी विवेकानंद शिक्षा समिति भोपाल, Madhya Pradesh
  148. Deepak Pachori, Mamatva Sewa Sanstha, Madhya Pradesh
  149. Shivraj Kushwaha, सहारा साक्षरता एज्यूकेशनल एण्ड सोशल वेलफेयर सोसायटी भोपाल, मध्यप्रदेश
  150. Prateek kumar gupta, Concerned citizen, Madhya Pradesh
  151. Amitabh Pandey, Daily Akhand Doot, Madhya Pradesh
  152. Vipul Kumar, Rupayaan, Odisha
  153. Sameet Panda, Odisha Khadya Adhikar Abhijan, Odisha
  154. Pranay, Concerned citizen, Odisha
  155. Samira Mallick, Sameer, Odisha
  156. Sharanya, Rangmatipadar Adivasi Commune, Odisha
  157. Rajaraman, Rangmatipadar Adivasi Commune, Odisha
  158. Ramgulam Sinha, Prerak, Chhattisgarh
  159. Dr. Simran Bagwan, BHMS, Urban Farmer, Maharashtra
  160. Subas Chandra Sahu, Odisha
  161. Sreeharsha Thanneeru, KisanMItra Helpline, Telangana & AP
  162. Jawahar Mehta, Vikas Sahyog Kendra, Jharkhand
  163. Amita Singha, Concerned Citizen, West Bengal
  164. Balu Gadi, Rythu Swarajya Vedhika, Andhra Pradesh
  165. Rajesh Bhadoria, Vikas Samvad, Madhya Pradesh
  166. Ganga Ram Paikra, चौपाल ग्रामिण विकाश प्रशिक्षण एवं शोध सस्थान, Chhattisgarh
  167. Rahul Saxena, बैक तो बेसिक्स नैचुरली LLP, Himachal Pradesh
  168. Bhoopedra Singh, Sangata Purkhauti Agro Farmers Producer Company Limited, Chhattisgarh


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