After carefully going through the NAC’s framework of the proposed National Food Security Bill, we have outlined our views and concerns below.

The NAC framework has suggested that the APL and BPL categories be replaced by a “general category” and a “priority category” and has recommended that 85% of the rural population and 40% of the urban population is covered in the first phase and provided rice, wheat and millets at subsidised prices.

LRS is of the opinion that the division of people into general and priority category is not very different from the division of people into APL and BPL, which has generated widespread anger and resentment among the people and allowed vested interests to deprive the people of their legitimate entitlements.


We believe that the basic principle guiding the proposed national food security bill should be that the right to food is universal and inalienable. The right to life defined in Article 21 of the Constitution can have full meaning only if it includes the right to food in adequate quantity and quality for all citizens of India.

So, instead of dividing citizens into the general and priority category, the proposed Bill should provide for the right to food for all citizens.

We also feel that the right to food should be given a modern definition by which all citizens should be ensured the provision of all essential food items required for a healthy living, which includes not only staple grains such as rice, wheat and millets but also pulses (dhals), vegetables, cooking oil, cooking fuel, sugar, salt, spices and other essentials which are required to prepare wholesome and nutritious food.

The NAC has estimated that the total PDS requirement to cover 90% of the rural population and 50% of the urban population, assuming an offtake of 90% will be about 56 million tonnes, is well within the capability of the government, including an additional 8 million tonnes for non-PDS requirements.

We think that in the light of the fact that 89 MT of rice and 81 MT of wheat were produced in 2009-10 by our farmers, it should be possible for the government to provide universal PDS. A similar calculation for other essential food items will definitely reveal that it is entirely possible for the government to finance a modern and universal PDS system which provides all essential food items in adequate quantity and quality to all citizens of India.

The observations in the NAC’s explanatory note that “the PDS, while important and essential, is only one of several interventions needed to ensure food security for all” and the recommendation for adopting a “life-cycle approach” to food security are welcome.


This means that the proposed Food Security Bill should allocate funds to implement a time-bound programme for modernising the storage of foodgrains, revitalisation of agriculture and food production through affordable inputs, remunerative prices, credit, irrigation, crop insurance and technical assistance, prohibition of diversion of land and water away from food production.

The NAC has recommended that “PDS should have a transparent structure, where food transactions can be tracked all the way to the cardholders and Fair Price Shops will be managed by community institutions accountable to their customers. It has suggested that the proposed Act “should mandate comprehensive reforms in procurement,  distribution and management”. Given the availability of modern technology and the huge resources at the disposal of the government, this should be entirely possible. But for this to become a reality, LRS is of the view that the domination of wholesale traders and large retailers over food production and distribution should be broken. The government should take over foreign trade and wholesale internal trade in all goods. It must further take over large scale retail trade in food commodities. What we are suggesting is born out of life experience of our people over the centuries. The present inability of the government to control prices of food commodities including vegetables and fruits shows that this vital sector should not be left in private hands whose aim is to maximise their profits and not the interests of people. The government has been allowing export of 7-14 MT of cereals every year as well as other food commodities. It has followed an export/import policy on food items which have served the traders in these commodities, not the farmers and people who consume. This has to be changed. The needs of providing food in adequate quantity, affordable prices, and good quality to all the working people, must take precedence over everything else. Exports and imports must serve the needs of society (must profit the whole of society) not a handful of greedy traders. In the light of the fact that procurement of rice and wheat decreased from 59.1 MT in 2008-09 to 54.0 MT in 2009-10, the recommendation to decentralise production and not centralising it in the hands of FCI is welcome. The states should be given all technical and managerial support in revitalising agriculture and procurement & distribution so that food-deficit states can turn into food-surplus states and all areas of the country become selfreliant in food production.

The NAC framework notes that “nutritional outcomes depend on a wide range of factors, including not only adequate food intake (in quantitative and qualitative terms) but also health care, safe drinking water, adequate sanitation, and so on”. LRS fully agrees with this observation and points out that for all citizens to lead a healthy life, the proposed Bill should incorporate enabling provisions s well as mechanisms for ensuring these factors.

The NAC framework observes that “a rights-based legislation requires robust and reliable systems of enforcement and accountability through institutions that are credible and independent”. LRS is of the view that this needs a complete transformation of the existing political process. The current political process excludes the common man from decision making and from playing a central role in day-to-day affairs such as ensuring food security for all. Apart from the right to vote in elections from time to time, the common man does not have the right to select and elect representatives of his choice, the right to recall them if they do not perform and the right to initiate legislation. He has no control over the state, district and block level administrators. Such provisions as the Right to Information Act, grievance redressal mechanisms, transparency, appellate bodies, etc have not been able to bring about people’s control over the implementation of government programs.

People’s Samitis in villages, mohallas, residential colonies should be provided with enforcement mechanisms and police powers to ensure that procurement and distribution of food commodities.

We do hope that members of the NAC will give due consideration to our views.

Yours Sincerely,
S. Raghavan, President



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