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In a hard-hitting five-page submission to the Joint Secretary (Seeds), Ministry of Agriculture, eminent public policy expert and seed rights campaigner Dr. Narasimha Reddy Donthi has accused the Government of India of once again succumbing to multinational seed companies while drafting the “Hybrid Seed Regulation Bill, 2025”. He has described the proposed law as the fourth pro-industry version in 21 years (after 2004, 2010, and 2019) that completely ignores the daily reality of lakhs of farmers who continue to receive fake, sub-standard, illegal, and over-priced seeds.
Dr. Donthi has linked the rising cost of seeds directly to increasing farmer suicides and agrarian distress, pointing out that poor-quality hybrid, HYV, and Bt seeds, uncontrolled pricing, and near-zero regulation have turned seed into one of the biggest cost components in farming while delivering diminishing yields and nutrition. He has cited the continuing Bt cotton catastrophe: pink bollworm resistance has rendered both BG-I and BG-II technologies ineffective, yet companies still collect trait fees and insist on identical pricing. The illegal spread of herbicide-tolerant BG-III (HTBt) cotton across Maharashtra, Telangana, Gujarat, and Andhra Pradesh has caused colossal losses to small and marginal farmers, with state governments repeatedly writing to the Centre admitting regulatory failure, but no action has been taken against errant companies.
The submission charges that successive drafts of the Seed Bill, including the present one, have been shaped to protect corporate interests rather than farmers. Seed companies routinely drag state agriculture departments to High Courts and the Supreme Court to escape accountability, yet the 2025 Bill remains silent on the mountain of litigation and deliberately keeps all powers centralized with the Union Government, sidelining states even though agriculture is a State subject.
In an attached 28-page clause-by-clause analysis titled “Seed Bill, 2025: Problems and Challenges,” Dr. Donthi dissects the draft’s shortcomings and proposes targeted amendments to prioritize farmers’ rights and sustainability. He argues that farmers’ rights are inadequately protected, as Section 1(2)(c) could allow seed inspectors to harass farmers selling unbranded seeds, and recommends fully operationalizing the Protection of Plant Varieties and Farmers’ Rights Act, 2001, to clearly delineate rights and liabilities between the two laws. He calls for revising the Bill’s objective to focus solely on regulating private and public seeds for cropping, excluding farmers from its scope.
Dr. Donthi criticizes the gender-biased language throughout the draft, which uses “his” and “he” exclusively, failing to recognize women as farmers and seed savers, and suggests replacing it with gender-neutral terms like “his/her” or “the person.” He objects to Section 1.3 allowing different notification dates for provisions without specificity, proposing that key provisions be explicitly listed for immediate enforcement and a clear notification procedure be established.
On definitions, he finds Section 2(a) on “agriculture” incomplete and recommends expanding it to encompass farming in all branches, including cultivation, dairying, aquaculture, floriculture, horticulture, livestock raising, forestry, and related operations performed by farmers. For “container” in Section 2(i), he advises removing the phrase “without affecting its quality” and introducing container certification provisions. He proposes refining “farmer” in Section 2(l) to explicitly include small and marginal cultivators while excluding corporate entities, and adding a definition for “consumer” as someone buying seeds for direct use.
Dr. Donthi highlights ambiguities in “dealer” under Section 2(j), noting it conflates roles like marketing agents and distributors, and suggests clarifying it to mean those procuring and selling from registered companies, while removing exporters from this category. He recommends eliminating the separate “distributor” definition in Section 2(k) and integrating it into dealer, and adding distinct definitions for “exporter” and “importer” requiring state registration and compliance with international treaties like the Biological Diversity Act, 2002, ITPGRFA, and Nagoya Protocol, with no exports or imports allowed without such registration.
For “national seed varieties” in Section 2(q), he argues administrative boundaries ignore agro-climatic factors and proposes redefining them as varieties suitable for multiple agro-climatic areas, with registration starting at the state level and national status granted only for those approved in multiple regions. He suggests adding a definition for “farmers’ seed varieties” as traditional or locally adapted plants registered under the PPVFR Act to clarify exclusions from this Bill.
Dr. Donthi questions the “plant nursery” definition in Section 2(s), noting it excludes flowers and vegetables without explanation, and recommends defining “horticulture” broadly to include cultivation and sale of fruits, nuts, vegetables, ornamentals, and services like conservation and landscape management, plus a specific “horticulture nursery” as any place selling, producing, or propagating such plants.
He proposes linking “import” in Section 2(m) to the Foreign Trade (Development and Regulation) Amendment Act, 2010, to cover goods, services, and technology in international seed trade. Finally, he calls for a new definition of “seed” in Section 2.24 as the reproductive structure containing an embryo, nutrients, and protective coat, explicitly removing “synthetic seeds” from its scope.
Dr. Donthi has demanded that the Bill be renamed the “Hybrid Seed Regulation Bill” to reflect its real focus, and has called for sweeping changes: strict price control including royalties and trait fees, time-bound and locally decided farmer compensation within one month, mandatory multi-locational trials for all imported seeds instead of accepting foreign certification, limited validity (3–5 years) for hybrid registration with compulsory performance re-validation, a decentralised and transparent seed traceability system, and criminal penalties for marketing fake or unapproved seeds. He has also insisted that State Seed Committees must get primary powers, including the right to de-register varieties and enforce compulsory licensing of seed companies.
Warning that the current draft risks legitimising monopoly through the back door and enabling biopiracy of India’s genetic wealth, Dr. Donthi has strongly objected to excessive delegation of powers to the Centre, blanket research exemptions, and clauses that shield government policy decisions from judicial scrutiny. He has stressed that the Bill in its present form fails to address the four core issues farmers face — quality, accessibility, affordability, and product liability.
The activist has urged the Ministry to immediately release the full text of the draft Bill and all previous versions in all Indian languages and open it up for genuine public debate. Civil society groups and farmer organisations have hailed the submission and demanded that the Ministry withdraw the present draft and start afresh after wide-ranging consultations with farmers, state governments, and independent experts.
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