Excerpts from Gujarat Chief Minister Narendra Modi's letter to the Prime Minister on Food Security Bill

'A meeting of chief ministers needs to be called before the [food security matter is finalised by Parliament'

The government of Gujarat has noted with serious concern the final formulation of the National Food Security Ordinance promulgated by the Central government recently. In my clear view, this does not contain the basic tenets which any food security legislation should meet, and is unlikely to achieve the objectives for which the Union government has taken this step. I would like to bring to your notice the following major deficiencies in the ordinance:

One, this is the first time any law has attempted to fix the number of beneficiaries in macro terms first, and then cast on the states the responsibilities to specify eligibility criteria and fix individual entitlements so as to reach the macro figure fixed by law. Any logical legislation should provide for the fixation of criterion first and the identification of the citizens who are food insecure, and then come to a conclusion about the total eligibility at the state level in terms of numbers.

This legislation actually does the reverse by not providing criteria or entitlements to ensure food security of insecure families and individuals. It is clear that each state will lay down identification criteria specific to the state to reach the numbers prescribed by the ordinance.

There could be wide regional disparities. Such variations would be open to judicial scrutiny and would create confusion. I would like to add here that none of the drafts had this provision. Even the standing committee of Parliament had recommended, as recently as January 2013, that the government should formulate eligibility criteria in consultation with state governments.

Two, I have noted with deep concern the fact that the ordinance proposes to reduce the entitlement of BPL families from 35 kg per family to only 25 kg per family of five persons. Surely, this cannot be the objective of any food security legislation, which reduces the entitlement of those who had been identified as being below the poverty line. Without the statutory "right to food", BPL families were so far already getting 35 kg per month, and the food security ordinance proposes to reduce it to 25 kg.

Three, I am further saddened to note that as per the proposed pricing structure for the grain, the BPL family will now have to incur Rs 85 more net expenditure per month for availing 35 kg [of grain], which they were getting without the "right".
Four, I am also pained to note that the food security ordinance does not assure an individual of having two meals a day. I fail to understand how food security for the individual is being assured. The proposed entitlement of 5 kg per month per person implies the supply of only 165 gm per person per day. Persons involved in labour-intensive activities require about 2,500 calories per day, as per NIN 2009 recommendations.

As 100 gm of food grain gives about 350 calories, 165 gm would provide only 500 calories per day, which is hardly 20 per cent of his daily calorie requirements. Even in the midday meal scheme administered by the ministry of human resource development, Government of India, school-going children are entitled to about 150 gm of food grain and 30 gm of dal for one meal, that is, about 180 gm of grain. As against this, an adult food insecure person is proposed to be given only 165 gm for two meals per day. This does not address even the calorific security, not to talk about nutritional security, which is the main objective of food security. This, I am sure you will agree, is totally unacceptable if providing adequate food security is the objective of the ordinance.

Five, I also note that while on one hand, the Central Planning Commission has been claiming the reduction of numbers below the poverty line, on the other, the Central government has deemed it fit to provide food support to about two-thirds of the population. This illogicality is not understandable and is required to be discussed with states.

Looking to the issues raised above, it is clear that the National Food Security Ordinance, 2013, has been brought about with undue haste and has major flaws. As it is going to have far-reaching implications for the citizens of this country and also on the agriculture sector, it would have been more appropriate to have the issue suitably debated and discussed at proper forums. A meeting of the chief ministers of states needs to be called before the matter is finalised by Parliament, a step which should have been taken on such an important Centre-state issue, and which has not been taken so far.
I hope my thoughts above will receive your thoughtful consideration and appropriate action.
Yours sincerely,
Narendra Modi

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