A public policy expert has written to Union Health Minister J. P. Nadda raising a series of concerns regarding the national Human Papillomavirus (HPV) vaccination campaign launched on February 28 for 14-year-old girls.
In a detailed letter dated March 1, Dr. Donthi Narasimha Reddy described the objective of reducing cervical cancer incidence as “commendable” but questioned the scientific basis, operational preparedness and public health prioritisation of the programme in its current form. The campaign rollout follows a directive issued by the Ministry of Health and Family Welfare to implement HPV vaccination using Gardasil-4 for adolescent girls.
The representation highlights seven broad areas of concern.
Field Preparedness and Infrastructure
The letter argues that the operational framework outlined in the government circular presumes uniform availability of cold chain systems, digital connectivity through U-WIN, trained personnel, adverse event following immunisation (AEFI) management capacity, and 24x7 helplines at sub-centres and primary health centres (PHCs). According to the author, ground-level realities in several states may not match these assumptions.
It contends that training conducted at state headquarters does not automatically translate into field-level preparedness among Auxiliary Nurse Midwives (ANMs), Accredited Social Health Activists (ASHAs), and facility staff responsible for administering vaccines and monitoring recipients. Questions are also raised about the feasibility of mandatory 30-minute post-vaccination observation and anaphylaxis management in high-volume campaign settings.
Adverse Event Reporting and Accountability
The letter calls attention to what it describes as structural gaps in adverse event reporting. It states that no district-level officer has been publicly designated with time-bound responsibility for AEFI investigation and that reliance on digital reporting platforms may result in underreporting in areas with limited connectivity. The author has sought mandatory public disclosure of aggregated adverse event data to ensure transparency.
Vaccine Coverage and HPV Strain Diversity
The campaign uses Gardasil-4, a quadrivalent vaccine covering HPV types 6, 11, 16 and 18. The letter notes that types 16 and 18 account for approximately 70 per cent of cervical cancer cases in India, leaving other oncogenic strains outside the vaccine’s coverage.
Citing published Indian studies, the representation points out that additional types such as 31, 33 and 45 have been detected in cervical cancer cases, and that multiple genotypes circulate in different regions. It references research suggesting that a nonavalent vaccine such as Gardasil-9 could potentially offer broader coverage. The author also questions why alternatives, including India’s domestically developed quadrivalent vaccine Cervavac, were not adopted or publicly evaluated in the decision-making process.
The letter further argues that most available HPV genotype data in India is derived from hospital-based cancer case series rather than systematic surveillance among healthy adolescent populations, which form the target group of the vaccination campaign.
Absence of Baseline and Evaluation Framework
A key concern raised is the absence of publicly available baseline data on cervical cancer incidence, HPV prevalence, or state-wise age-disaggregated data prior to the campaign rollout. Without baseline metrics and clearly defined outcome indicators, the author contends, it would be difficult to measure the long-term effectiveness of the programme, estimated to involve an annual expenditure of approximately Rs 1,300 crore.
Consent and Language Accessibility
The letter states that information, education and communication (IEC) materials have been prepared in Hindi and English, with states expected to translate them into regional languages. Given India’s linguistic diversity, the author argues that meaningful informed consent requires locally contextualised materials and community participation rather than centralised templates.
Concerns are also raised about paper-based consent mechanisms in areas lacking digital access, which may reduce auditability and documentation.
Nutritional and Health Context
Pointing to high rates of anaemia among adolescent girls in several states, the representation questions the absence of any recommended nutritional or immunological screening prior to vaccination. It argues that vaccine efficacy and adverse event profiles in nutritionally compromised populations may differ from those observed in clinical trial settings.
Vaccination Versus Screening Priority
The letter concludes by questioning the policy prioritisation of adolescent vaccination over expanded cervical cancer screening among women aged 30–49, the demographic currently at highest risk. It notes that screening coverage in India remains below 3 per cent in that age group and suggests that scaling up low-cost screening methods such as Visual Inspection with Acetic Acid (VIA) could yield more immediate mortality reductions.
According to GLOBOCAN 2022 estimates cited in the annexure, India records approximately 1.2 lakh new cervical cancer cases and 80,000 deaths annually, making it the second most common cancer among women in the country.
Dr. Reddy has requested that the Health Minister commission an independent scientific review before the programme proceeds to full national scale. Copies of the letter have been marked to senior officials in the Ministry of Health and Family Welfare and to health authorities in Telangana.
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