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Akshaya patra foundation (APF), a sister concern of the International Society for Krishna Consciousness (ISKCON), has been supplying mid-day meals (MDM) in Karnataka, since its inception in 2002-03. However, the CEO of the zilla panchayat, Bangalore urban refused to sign the MoU for 2017-18 stating that norms and guidelines were being violated by the organisation. The Food Commission in the State, the Joint Director (MDM, Karnataka) as well as the Right to Food and Right to Health campaigns have raised some concerns. These are

• Bland, tasteless and monotonous meals which do not meet standards of nutrition and being consumed in less than the required amounts by children.
• Meals provided by APF do not include garlic or onion as they prepare only ‘satvik’ food.
• Inspection in government schools across the state revealed that APF appears to serve less quantity of food as opposed to the norms prescribed by the state government.
• Milk being served to the children violated the Ksheera Bhagya (hot milk) scheme because it was cold and in some cases spoilt.
• Mid day meals should not be provided through a centralised agency, especially one like APF that applies limits to the food on the basis of religious beliefs. The NGO has also not been providing eggs in the MDM as part of its ‘satvik’ diet.

In response, APF has refused to change the menu. They submitted a report from a private laboratory in January 2019, which claimed that all standards were being met. The Food Commission rejected this and asked for a government laboratory report.

The Joint Director (JD), MDM scheme, Karnataka then sent a letter to the National Institute of Nutrition (NIN) and Central Food Technology and Research Institute (CFTRI) requesting for technical inputs into the quality of food provided by APF. NIN responded with a letter on 14^th February 2019, and CFTRI on 2019.

Some of the main components of the letters are presented below.

On the issue of bioavailability of minerals, the director of NIN states that it is well established that inclusion of seasonal and fresh vegetables and the use of turmeric, lime, curry leaves, cumin seeds, tamarind and green leafy vegetables also improve the bioavailability of nutrients apart from additional health benefits and are also effective substitutes of onion and garlic. The use of variety of fresh vegetables and above ingredients by Akshaya patra ensures absorption and bio-availability of minerals and nutrients”.

CSIR –CFTRI’s response is that they agree that the contribution of onion and garlic towards macro and micro-nutrients is negligible. They also say that the claim by APF that sambar without onion is nutritious cannot be validated unless the vegetables used for substituting onion is known.

They agree that there are alternatives to substitute onion and garlic. “The ingredients listed (viz turmeric, drum stick, lime, green leafy vegetables- GLV, jeera etc) are known for enhancing the bioaccessibility of micronutrients. These are not only excellent promoters of bioavailability but also providers of nutrients. Acidulants which provide organic acids such as citric acid, ascorbic acid, maleic acid are the best enhancers of bioaccessibility”.

This statement by CFTRI is shocking because it contradicts a study conducted by CFTRI itself on how onion and garlic improve the bioavailability of zinc and iron from cooked food,^[1] especially as bio-availability of iron and zinc from plant foods is usually very low. Given the  high levels of anemia in India, it is unfortunate that CFTRI, instead of standing by their own research findings and promoting proven ways of increasing absorption of iron and zinc, are presenting a rather garbled opinion about drumsticks and lemons.  In fact, green leafy vegetables (GLV) have high fibre (oxalates and phytates) which inhibit iron and zinc absorption. Neither do NIN and CFTRI give references for their assertions nor do they give details of quantities of the alternative food. It also doesn’t take into account that most of the suggested foods are expensive/seasonal as compared to onions and garlic which are available throughout the year.

Surprisingly, neither of these national institutions mention the cultural significance of onion and garlic in the eating habits of the communities that are being given the MDM. Isn’t ‘nutritional value’ closely linked to people’s traditional eating habits? Does this mean that people in Punjab should be given anna sambar because it has equivalent bioavailability to what is culturally eaten there?

On nutritional compliance, the director of NIN says that Akshaya patra’s cyclic menu of ’15 different combinations and ingredients’ were evaluated by NIN keep MDM prescriptions in mind. She writes “The nutritive values of menus with ingredients used in the mentioned amounts, certainly meet and often exceed the prescribed energy (Kcal) and protein requirements prescribed by MHRD for the MDM. Moreover the micronutrients (calcium, magnesium, iron and zinc) are also more than what actually can be achieved through prescribed MDM menu by the government of Karnataka”

The menu submitted by APF is on paper and doesn’t even mention the quantity of ingredients used, but the NIN director says that this menu not only meet but often exceed the prescribed energy (Kcal) and protein requirements prescribed by MHRD for the MDM. Is this a scientific method of assessing the nutritional quality of food?

CFTRI at least has the credibility to say that “the organisation would be in a position to comment on the nutritional compliance, food safety measures, meal taste and diversity plan of Akshaya patra MDM, only after conducting a study on their meals, which would require 4 – 6 months with additional resources.”

On the query of whether AP meals meet or exceed the energy and protein norms of MHRD, CFTRI states that “details of food served under MDM would be necessary for calculation of protein and energy as well as samples drawn and studied from all the regions where AP meal is served” and that is that “the menu planner is necessary to verify the claims” of whether APF meals meet or exceed government prescribed norms.

This observation by CFTRI makes good research sense. It gives the evaluating team more objectivity and also prevents undue influence from either the contractor or the government.

With regard to food safety measures, NIN says “Akshaya patra kitchens are ISO certified which meals a certain standards are already met. In addition, some of our scientists who visited their kitchens in Telangana and Karnataka have given convincing personal accounts about the high safety standards practiced by the organisation”.

When the Joint director, MDM, Karnataka has officially requested for a report on the functioning of a centralised kitchen that serves MDM to thousands of children, the director of NIN responds by talking about ‘personal accounts’ of scientists. What locus standi does a personal account have for an issue of such serious concern as children’s nutrition? The director should have asked for a formal visit and issued a formal report or said that she would not be able to comment. This need to bend over backwards to accommodate a contractor when concerns have been raised by a government official who the contractor is accountable to, is deeply concerning.

On meal diversity, NIN opines that APF provides ‘varied meal combinations of local dishes’, which “enhances MDM consumption and also aids the sensory development of child. NIN says that APF has “designed multiple variants of sambar and rice which are rotated on a periodic basis to add variety. Their resultant difference in its palatability adds variety to the organisation’s mid-day meal. The cyclical menu plans and the ingredients used by Akshaya patra Foundation in fact ensure diet diversity needed for the meal”.

The letter goes on to say “Although the meal taste is very specific to local palate, the menus with considerable diversity in variety, usage of different food groups, spices and seasonal vegetables certainly cannot give rise to any monotony in taste”

This confident assurance by the Director takes no cognizance of concerns raised by children consuming the MDM, the mothers, the Food Commission, the Zilla Panchayat office, Bangalore urban or  the JD MDM.

At least CFTRI acknowledges that it would be difficult to comment on whether the APF meals are diverse, tasty, spicy and not monotonous  without having the sufficient data available.

It is also not possible to make ‘multiple variants’ of sambar, which seems to be present in 10 out of the 18 menus shared by APF. Onions and garlic are particularly important to make traditional sambars.

In conclusion the NIN director  says “Akshaya patra Foundation is implementing in compliance with MDM norms. The menu follows the nutrition guidelines suggested by MHRD. The recipes are found to be inspired by local food habits and menu combination”.

How can a centralised kitchen be inspired by local food habits? Then it should have been inspired to provide eggs and use onion and garlic in the food.

She also says “Quality and hygiene are strong aspects of Akshaya patra program and are maintained throughout the implementation process”. How did the director reach this conclusion sitting in her office in Hyderabad? The complaint that food travels long distances and is often cold and smelly is a serious implementation gap. Hot food that is transported long distances in closed containers spoils quickly. It is well known that those schools which are well connected and close to the central kitchen may receive hotter and fresher food than those located more than 40 km away. Is there absolutely no standard that one should follow when making a statement that implementation process has been maintained throughout? Can this be assessed in any way other than visits to multiples sites and objective observations? Even this has gaps because it is well known that quality of food improves drastically on the days of supervisory or evaluation visits, and keeping these a surprise is often difficult.

The NIN concludes “Based on our review of MHRD guidelines, prescribed menu chart, Akshaya patra’s report on nutritional compliance and bioaccessibility, CFTRI report on efficacy of MDM in Mysore and scientific literature published by NIN, we conclude that Akshaya Patra Foundation’s MDM are nutrition compliant as per the MHRD prescribed MDM guidelines and norms”.

When an evaluation report is being submitted about a scheme as crucial to the children of the state as the MDM, it requires at least some basic steps. These include

1. A list of schools being served meals under the scheme with a break up of centralised and decentralised followed by random selection of a representative sample size. These schools should be visited by a team of people from different backgrounds and ideally with a representative from civil society.
2. The centralised kitchen should be visited and different aspects of the process should be assessed – quantity of ingredients used, adherence to prescribed guidelines, storage etc.
3. Calculations should be made to check if the food is meeting the required norms of providing 450 – 700 kcal and 15 0 20 gm of protein at source as well as at the time of serving.  Time between food arrival and served should be noted. Food should be observed for freshness and how hot it is.
4. 4 Even if the food meets the requirement at point of preparation, the important factor is to assess how much of it is actually consumed and if the quantities delivered meet the needs of all the children in the school. When schools are visited, the team should carry out an institutional diet survey (which is taught to home science graduates). Details of number of children (with age break up) enrolled for the meal and present on the day of the visit as well as numbers of all faculty and guests who had eaten that day should be made available. Raw and cooked quantities of food, amount left over and wasted will give a reasonable estimate of what the children have consumed.
5. The process of reconstitution of milk should be assessed in the kitchen. The time taken between preparation and serving should be noted. The quality of milk – taste, freshness and whether it is hot should be assessed at the schools and just prior to being served to the children.
6. Details of who handles the food and the health status of food handlers should be noted.
7. The transport facility should be assessed for the longest distance travelled by the food and keeping quality of the food at the time of being served.
8. Care should be taken to look out for children being asked to eat later or separately or any form of discrimination. Indian communities are notorious for discrimination particularly around meals based on caste, religion, occupation etc. It is therefore particularly important that any team visiting the schools is sensitive to issues of exclusion and discrimination.
9. Focus group discussions should be conducted with teachers and children to assess what they like or dislike about their food. The suggestions are very important and should be accurately documented. Mothers should be spoken to address their concerns. It is important that these interviews are done sensitively and without fear of consequences for the respondents.
10. The chain of responsibility for the MDM as well as the budget should be tracked since it varies with different states and also gives an idea of larger administrative level gaps and loopholes. For instance the MoU with Akshaya patra was not signed for the year, but the organisation continued to give food and receive funds.

The state government had created a prescribed menu primarily because contractors of the MDM were preparing food as they liked with the ingredients they chose. A prescribed menu was expected to meet some basic nutritional standards and also make costing accountable.

It is therefore of grave concern that government nutrition institutes are issuing ‘report’ sitting behind a desk and having never visited the field area but based on a menu submitted by the contractor. Is this how crucial food schemes for the citizens of the country will be assessed henceforth? Is the opinion of the Director representative of NIN as an organisation? Are these the standards that NIN claims to represent? The state government’s ability to enforce an MoU or address violations will be gravely thwarted by such irresponsible reporting. Who should government officials ask for reports on nutritional quality of food, if the NIN and CFTRI are behaving in such arbitrary, unaccountable and unprofessional ways? When the issue is about children’s nutrition, can a national institute be so unaccountable?

Another concern is why is a contractor being allowed to offer alternatives to onion and garlic when these are mentioned in the MoU and preferred by a majority community. The revised guidelines 2017 for engagement of Civil Society Organisations/Non government Organisations (CSO/NGO) in mid day meal scheme states that CSO/NGO should not…’use the program for propagation of any religious practice.’   Instead of taking a firm step, why are the higher authorities in Karnataka such as the Principal Secretary, the Chief Secretary and the Chief Minister bending over backwards to accommodate the religious agenda of a contractor?

We strongly object to the collusive relationship that NIN primarily, and CFTRI to a lesser extent, seem to have with a food contractor. We demand that highest standards of ethics and integrity be maintained by NIN in the interest of nutritional rights of thousands of citizens.

We demand that NIN and CFTRI withdraw these irresponsible ‘reports’ and conduct a study following basic tenets and principles of good scientific research.