Summary
A field assessment by the South Asia Biotechnology Centre, commissioned by the seed industry bodies FSII and NSAI, estimates that 26.2-29 lakh hectares of India's 114.8 lakh hectares of cotton in 2025-26 carry unapproved GM traits.
That is roughly a quarter of the cotton area. The traits include cp4-epsps, which makes the crop tolerant to glyphosate and Vip3A, which targets bollworm. Neither has been approved for any crop in India. Farmers turn to these seeds because of labour shortages, high weeding costs and pink bollworm damage.
The unauthorised seed market has grown to 82-88 lakh packets. For an officer in the field, enforcing biosafety law means penalising distressed farmers, while inaction means tolerating a growing black market.
WHY IT MATTERS FOR UPSC & STATE PCS
A study covering 16 hotspot districts in Maharashtra, Telangana, Andhra Pradesh and Rajasthan found the herbicide-tolerant gene in 72.69% of field samples and the Vip3 gene in 53.74%. It also found that legal Bt cotton seed sales have fallen while glyphosate imports have risen 29%. Together, these findings point to a large and growing illegal GM seed economy that bypasses India's biosafety approval system.
Standard News
A Field With No Weeds
The scenario below is constructed, but every number in it comes from the field study. You are the district agriculture officer in a cotton hotspot. On a field visit, you find a crop that has been sprayed with glyphosate and survived.
That means it carries the cp4-epsps gene, which India has not approved in any crop. The farmer tells you plainly why. Labour is scarce. Glyphosate weeding costs him Rs 750-850 an acre, while manual weeding costs Rs 12,000-15,000.
The legal Bt seed no longer protects him well against pink bollworm. He is not alone. An estimated 26.2-29 lakh hectares, roughly a quarter of India's cotton area, are under such illegal hybrids.
The Easy Answer and Why It Fails
The easy answer would be "the law is the law; destroy the crop and book the farmer." But that would fall on the weakest person in a chain that runs from unknown manufacturers through a "sophisticated supplier network" to his field.
The farmer bought a packet. Someone else made it, moved it and sold it. The other easy answer would be "he is poor and desperate; look away." But looking away makes you part of how a black market of 82-88 lakh packets becomes normal.
It also leaves unmanaged the ecological risks that biosafety law exists to prevent, such as herbicide-resistant weeds and uncontrolled gene spread.
What Each Path Costs
If you enforce at the farm:
- A smallholder loses a season's investment in a crop already in the ground.
- The supplier who sold him the seed loses nothing.
If you do nothing:
- The ecological risk spreads unassessed.
- The law loses meaning in your district.
- Farmers who obeyed the law, buying legal seed and paying for manual weeding, are effectively penalised for complying.
The Frameworks, Applied -
Rule of law (deontological): The biosafety process exists because GM traits can cause irreversible harm. Bypassing it is not a technicality.
- Consequences: Punishing thousands of farmers will not shrink a market driven by labour economics. Only reaching the supply network or the regulator can do that.
- Justice as fairness: Responsibility should follow knowledge and power. The supplier knowingly sells an unapproved product. The farmer is responding to costs he cannot control.
The Resolution Enforce upstream, document downstream and push the regulator.
- Target the supply chain. Trace seed packets to dealers and suppliers and focus seizures and prosecution there.
- Document, don't destroy. Record affected fields and gene presence. Advise farmers on the legal and ecological risks without wiping out a season's livelihood.
- Escalate the policy gap. Send district evidence to the State and press the regulator for a time-bound decision on these traits: either approve them with stewardship rules or reject them with real enforcement and alternatives for farmers.
What this costs: the illegal crop stands this season. The ecological risk continues for now. Farmers who obeyed the law see no immediate reward. That is a genuine sacrifice. It is still smaller than making the poorest link in the chain pay for a failure that runs from the seed network to the regulator.
Quick Facts
Key numbers & takeaways — revise these first
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India legally permits only two GM traits in cotton, the cry1Ac and cry2Ab genes derived from Bacillus thuringiensis.
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The cp4-epsps gene makes cotton tolerant to glyphosate, a herbicide that otherwise kills crop and weeds alike.
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The Vip3A gene is derived from Bt and is said to control a broader range of bollworm larvae.
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India's total cotton area in 2025-26 was 114.8 lakh hectares, of which an estimated 26.2-29 lakh hectares carry unapproved GM traits.
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The study tested 227 geo-tagged samples from the fields of 984 farmers across 16 hotspot districts in four States.
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Legal Bt cotton seed sales fell from 596 lakh packets in 2022-23 to 463 lakh packets in 2025-26, at 450 grams per packet.
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Glyphosate imports rose from 27,721 kilolitres in 2024-25 to 35,642 kilolitres in 2025-26.
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The Genetic Engineering Appraisal Committee under the Ministry of Environment, Forest and Climate Change is the apex body for approving GM crops.
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GM crops are regulated under the 1989 Rules framed under the Environment (Protection) Act, 1986.
Connect the dots for your UPSC preparation.
Standard news covers the event. Log in to read our comprehensive analysis and uncover the hidden constitutional, structural, and ethical dimensions of this topic:
Why the farmer who obeyed the law, buying legal seed and paying Rs 12,000-15,000 to weed by hand, is the hidden third party in this dilemma.
What the fall in legal seed sales, the 29% rise in glyphosate imports and the growth of the illegal packet market together reveal about who profits.
A three-part resolution that separates upstream enforcement from farm-level documentation and why the regulator's silence is the deepest cause.
A caution on reading a study commissioned by seed-industry bodies and why it does not weaken the ethical case.
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