2. Structure
I Overview of Main Points
II Problems in Definitions
III Provisions for Food Security
1. Entitlements under the PDS
2. Entitlements for children, pregnant and lactating
mothers
3. Entitlements of special groups
4. People living in starvation
IV Implementation Issues regarding the PDS
3. V Grievance Redressal Mechanism
VI Issue of Over-centralisation
VII Transparency and Accountability
VIII Provisions for Advancing Food Security
4. Overview of Main points
Absence of provisions related to agriculture- Bill
needs to address production, decentralised
procurement, storage and distribution related issues
Lacunae regarding definition of nutritional security.
Need to ensure access to clean drinking water,
sanitation, health services and safe food
Distribution of food grains is targetted. Exclusion
errors. Needs to be universal along with affirmative
action.
A grievance redressal mechanism that is
decentralised and effective needed
5. Too centralised- no role for the local governments
and panchayati raj institutions
6. Challenging Basic Premises-
Problems in Definitions
‘Food grains’ need to refer to pulse and oils as well,
apart from rice, wheat and other coarse grains
Definition of ‘food security’ not comprehensive
enough. Needs to be ‘food security exists when all
people at all times have physical and economic access
to sufficient, safe and nutritious food to meet their
dietary needs and food preferences for an active and
healthy life” [Source: Voluntary Guidelines to Support
the Progressive Realisation of the Right to Adequate
Food, FAO Council]
7. Need to remove the provision for ready to eat meals
and have a provision for ‘locally produced and cooked
meal’ instead
Bill also needs to come into force within two years of
the passage of the Act and not as and when the
Central Government might decide
9. Entitlements under the PDS
The PDS entitlements need to be made universal
There should be no conditions like linking the
entitlements of the general households to the reforms
in the PDS
Affirmative action needed for de-notified tribes, salt
pan workers, single women, dalits, disabled and
socially excluded groups
Expand scope of PDS to include millets, pulses and
oilseeds
Delink the issue prices from the MSPs to ensure
farmers are not affected by un-remunerative prices
10. Entitlements for Children,
Pregnant and Lactating Mothers
Universalisation of the ICDS
Improve the quality of services under the ICDS-
norms for infrastructure, supplementary nutrition,
training and capacity building in re the anganwadi
workers
Manage malnutrition holistically- growth monitoring,
additional nutritional supplements, nutritional
counselling, health care and appropriate treatment
Universal maternity entitlements at minimum wages
which are inflation indexed
Explicit support for breast feeding
11. Creche facilities for children of working women
Include adolescent girls within the ambit of the Act
Midday meals to be made available to out of school
children as well
Ensure meals are not denied to children on any
grounds
Incorporate safeguards against commercial interests
and promote decentralisation
12. Entitlements of Special Groups
Clause 38 of the Bill gives special focus to the needs
to vulnerable groups in the hill and tribal areas
The mechanisms by which the entitlements may be
claimed(in re migrant families) and the entitlements
themselves (in re destitute and homeless) need to
clearly specified
Include pensions for aged, single women and disabled
as entitlements
13. Persons living in starvation
Define ‘starvation’ with greater clarity- currently
‘prolonged involuntary deprivation of food which
threatens the survival of the persons’ which leaves a
wide latitude for interpretation
Include principles of a Starvation Protocol in the Bill
14. Implementation Issues regarding
the PDS
Problem of identification of the priority and general
households. Linked to the earlier argument as to how
the division should be gotten rid of
Delete the provision which allows for cash transfers.
Food security allowance to be resorted only in the
last instance, clear instances when it might be used
15. Grievance Redressal Mechanism
Create a statement of obligations and citizen’s charter
containing the duties and commitments towards
citizens. Put it in the public domain.
Appoint a grievance redressal officer at the panchayat
or municipal level
Set up independent block level facilitation centres
The District Grievance Redressal Officer needs to
hold open court hearing and be empowered to impose
penalty and compensation. Bill should specify time
limit within which the DGRO needs to act.
16. The time limits for the State and the National
Commissions to dispose of cases also to be included
Empower the Commissions also to impose penalties
and award compensations
17. Issue of Over-centralisation
The Bill confers sweeping powers to the central
government, including,
- Specifying when different provisions of the Act will
come into force
- Prescribing mandatory guidelines for all relevant
schemes
- Prescribing the powers of the National Food
Commission
18. Gram panchayats and local bodies have a limited role.
Should,
- Monitor the implementation of entitlements
- Conduct social audits – open, transparent and
inclusive
- Identify the people living in starvation
19. Transparency and Accountability
Ensure access to all documents to persons who seek it
Institute SMS alert systems and PDS telephone lines
Vigilance committees at the shop level
Bring all information related to the PDS within the
ambit of Section 4 of the RTI Act[]
20. Provisions for Advancing Food
Security
The objectives mentioned in Schedule III need to be
converted to entitlements and not left to be
‘progressively realised’
Ensure access and control over agricultural resources
to agricultural families
Decentralised system of procurement needed
Nutritional security- food absorption dependant- safe
and adequate drinking water and sanitation
