Those who have signed the letter to the chief secretary include representatives of the Right to Food Campaign-Karnataka, and Action Aid, Bangalore.
APF has been supplying food to 2,814 schools in Karnataka as part of the midday meals scheme (MDM), fully funded by Government of India (GoI) and GoK. The scheme aims at providing students studying in the schools a nutritious meal containing “locally and culturally relevant” food, which children should find tasty enough to eat in adequate quantity.
Things took a strange turn following the Karnataka State Food Commission (KSFC) and civil society groups taking exception to onions and garlic being excluded from the Midday Meal menu despite the fact they are part of the traditional foods like sambhar in Karnataka. Despite the KSFC view, the GoK asked NIN and Central Food Technical Research Institute (CFTRI) for “technical inputs” on nutritional adequacy, bio-availability, diet diversity, taste and food safety and hygiene.
In its response, CFTRI refused to comment on the nutritional quality, taste, diversity and safety of food supplied by APF, even as seeking “sufficient time and resources to do a proper assessment”, while NIN praising APF without carrying out any systematic scientific study.
According to activists and experts, “No empirical data was collected on the quantity and quality of ingredients used or amount consumed and amount wasted by children to certify food supplied by APF as nutritionally adequate. Instead, a paper menu submitted by APF, was considered evidence enough to comment on an aspect of the scheme which have nutritional impact on lakhs of children!”
“Even more shockingly”, they argue, “Without visiting a single school or speaking to children consuming the food, NIN has taken the unwarranted liberty of commenting on the taste and safety of the food even which fly in the face of observations by State Food Commission of monotony of the food supplied by APF or media reports of children vomiting after consuming the food on some occasions.”  Click HERE for the group’s response to NIN and CFTRI arguments.

Letter to the chief secretary:

We, the undersigned, are activists, doctors and researchers working on issue of Right to Food and are deeply concerned about the continued inaction of the State government on the serious issue of Akshay Patra Foundation’s refusal to comply with directions (Annexure 1) and contractual obligations (Annexure 2a, 2b) to include onion and garlic in Mid-day meals.
Akshaya Patra Foundation (APF) which is linked to International Society for Krishna Consciousness (ISKCON), a religious organization which holds the belief that ingredients like onion and garlic are not ‘sattvik’ and should not be consumed. By not including these ingredients in the food supplied as part of Mid-day Meals scheme in Karnataka, it is imposing its religious beliefs on children studying in publicly funded (government-run and government-aided) schools which is expressly prohibited by Guidelines issued by Ministry of Human and Resource Development (MHRD) under the National Food Security Act (NFSA) 2013. Sec 5 (2) of the NFSA 2013 states that
“(2) Every school, referred to in clause (b) in sub-section (1), and anganwadi shall have facilities for cooking meals, drinking water and sanitation: 
Provided that in urban areas facilities of centralised kitchens for cooking meals may be used, wherever required, as per guidelines issued by the Central Government.” 
The Revised Guidelines 2017 for engagement of Civil Society Organizations/ Non Govt. Organisations (CSO/NGO) in Midday Meal Scheme) (Annexure 3) issued by MHRD states in para 2.11 that
“2.11 The CSO/NGO should not discriminate in any manner on the basis of religon, caste and creed, and should not use the programme for propagation of any religious practice.”
Despite this clear provision in the Guidelines, APF is being allowed to impose its “sattvik” food through a government scheme. As a result, as noted by Karnataka State Food Commission during its visits to schools where food is being supplied by APF, the food is bland and monotonous.
Consequently, the quantity of food being consumed by children is less than the prescribed quantity, defeating the purpose of the scheme. Bengaluru, Dharwad and Ballari, where APF has been supplying mid-day meals through its centralized kitchens are among the five worst performing districts in terms of coverage of the scheme (Annexure 4).
Similar concerns were raised in 2013 by the Programme Approval Board (PAB) following which Bengaluru (Urban) and Dharwad were designated as Special Focus Districts (Poor Utilization of Foodgrains and and Low coverage of Children) (Annexure 1) because as noted by the then Commissioner:
“The NGOs which are involved in implementation of Mid-day Meals scheme across the state are supplying same kind of food every day to schools, using same kind of vegetables every day and instead of using food ingredients as per the local food customs, are preparing food following their own organization’s food practices and supplying it to children. Because of this, not only are children not eating the food with enjoyment but monitoring institutions have also raised objections. Not only that, during visits to schools, the opinion sought from children also supplements this.” 
Because of the concerns raised, a specific menu was prescribed for contracting parties to follow. APF is one of the largest suppliers to both these special focus districts but it has consistently violated the prescribed menu norms, even as the Department failed in its duty to enforce these directions.
APF has been trying to divert these serious issues by claiming that its food meets nutritional requirements prescribed by Ministry of Human Resource Development (MHRD). Instead of enforcing the prescribed menu, the department has gone along with these diversionary tactics by asking for technical reports from National Institute of Nutrition (NIN) and Central Food Technological Research Institute (CFTRI).
A scientific evaluation of nutritional quality of the food supplied under MDM scheme would require following proper protocols of sampling, measuring and ascertaining the quantity and quality during actual process of preparation and consumption of food along with discussions with various stakeholders involved, especially the children eating the food.
No such detailed analysis has been done by NIN. They have made recommendations based on a menu provided by APF which doesn’t even mention the quantities of ingredients used to prepare the meals. In absence of this information, it is scientifically impossible to estimate nutritional value of food prepared.
In view of such serious lapses, it is clear that the conclusions reached by NIN are unscientific and biased, void of any basis in any systematic study and have been provided only to give a clean chit to APF.
CFTRI, in its response has rightly expressed its inability to answer questions pertaining to nutritional value of food supplied, its taste and diversity etc in absence of a systematic study.
On the question of alternatives to onion and garlic, CFTRI seems to suggest that onion and garlic can be replaced by other ingredients like turmeric, drum stick, lime, green leafy vegetables (GLV), jeera etc. But CFTRI has failed to provide any details of the quantities of these ingredients or take into account the seasonal nature and cost of these ingredients.
More importantly, it has not challenged the basic issue which is – why should onions and garlic which are traditionally used in cooking in Karnataka, particularly for sambar, be denied to children in government schools? Why should the religious beliefs of the contractor be given preference over that of the children, especially when the MDM guidelines clearly state that the scheme cannot be used for religious propaganda by the contractor?
Why are these suggested ingredients being treated as alternatives? Why can’t they be provided along with onion and garlic? Why should school-going children be denied a a normal sambhar with onion and garlic for taste, just because an NGO’s private religious beliefs go against it? We have provided a detailed critique of the ‘reports’ submitted by NIN and CFTRI along with this letter (Annexure 5).
Several of these concerns were raised with you in our Memorandum dated March 2, 2019 (Annexure 6) but these violations seems to have continued unchecked. The lack of will of the government to hold Akshaya Patra Foundation accountable for adhering to the directions issued by the government itself, indicates government’s approval of the religious agenda of Akshaya Patra Foundation which is not just in violation of Mid-Day Meals Guidelines issued by MHRD but is in violation of the basic values of the Constitution of India as well.
We urge you to put the interest of children studying in government schools ahead of the interest of a religious organization and not to delay taking a decision in this matter. The government should either seek a firm commitment from APF that they would be following the prescribed menu including onion and garlic in the next school year or make alternative arrangements for provision of mid-day meals to the schools catered to by APF.
Along with this, we also note with concern, the move away from supplying hot-cooked food under Mid-day Meal Scheme through decentralized kitchens. Centralised kitchens, which were introduced as exception to the general rule of decentralized kitchens are increasingly been relied on by the government.
This not only deprives children of locally-cooked hot meals but also bypasses Supreme Court Orders in People’s Union for Civil Liberties vs Union of India (WP(C) 196/2001) passed on 20th April 2004 regarding preference to be given to Dalits, Scheduled Castes and Scheduled Tribes in appointment of cooks and helpers. We urge the government to start moving towards decentralized kitchens and away from Centralised kitchen-based provision of food.
Lastly, we reiterate our demand for inclusion of eggs in the Mid-day meals scheme in view of the nutritional guidelines prescribing consumption of 5 eggs per week, especially considering high rates of malnutrition in Karnataka.

Signed by:
1. Right to Food Campaign-Karnataka
2. ActionAid, Bangalore
3. Adv. Vinay K Sreenivasa, Bengaluru
4. Dr. Ramamurthy, Community Medicine
5. Dr. Sylvia Karpagam, Public Health Doctor
6. Dr. Gopal Dabade, President, All India Drug Action Network, Dharwad
7. Gee Iman Semmalar, Activist, Bengaluru
8. Issac Arul Selva, Editor, Slum Jagatthu
9. Kshithij Urs, Activist
10. Malarvizhi, ActionAid
11.Mohan Rao, former Professor, Jawaharlal University
12. Narsimappa T V, Alternative Law Forum, Bengaluru
13. Neelaiah C, Right to Food Campaign-Karnataka
14. Raghavendra Rao, ActionAid
15.Reshma, ActionAid
16. Siddharth Joshi, Independent Researcher, Bengaluru
17.Sharada Gopal, Jagruthi
18. Sr. Celia, Janapriya Seva Kendra
19. Swarna Bhat, GRAKOOS,
20. Vinay Baindur