Date: 02-08-2022

To,

Sub: Seeking urgent steps towards improvement in functioning and quality of Mid-day Meals in Karnataka

Dear Sir/Madam,

We are a group of nutritionists, activists, researchers, doctors, and concerned citizens of Karnataka who are concerned about children’s right to food for the past several years. We are writing to you to urge you to take some urgent steps to ensure the nutritional entitlements of the school-going children in Karnataka as enshrined in the National Food Security Act 2013 and provided for by various directions by the Hon’ble Supreme Court in the Right to Food Case (People’s Union of Civil Liberties vs Union of India WP 196/2001).

1. Provisions of Eggs in Mid-day Meals:

The decision of the government to provide eggs as part of the Mid-day Meals Scheme in Karnataka is a welcome step. Inclusion of eggs in the mid-day meals has been a consistent demand of school-going children and their parents in Karnataka. It enhances the nutrient density of the food and improves the quality of what is otherwise a very cereal heavy diet. The introduction of only 46 eggs/year is less than the recommended consumption of 5 eggs per week. (See Note in Annexure 1). Additionally, children studying in classes IX and Xth have not been included within the egg distribution programme..

We are also concerned that certain NGOs operating centralized kitchens are refusing to serve eggs to children quoting religious reasons. It should be noted that propagation of one’s own religious practices is prohibited under the Revised Guidelines 2017 for engagement of Civil Society Organizations/ Non Govt. Organisations (CSO/NGO) in Mid Day Meal Scheme) (Annexure 2a) issued by MHRD:

“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.”

Hence, we urge to take the following steps in this regard:-

1. The provisioning of eggs under the Mid-day meals should be extended to students of Class IX and X and to 5 days in the week.
2. If any NGO refuses to implement the egg distribution programme, their contract should be canceled. If school based kitchens are not possible, local women’s self help groups can be trained to prepare the MDM in keeping with the prescribed norms and standards.

2) The introduction of centralized-kitchens in rural areas is illegal

It has come to our notice that there are plans to hand over functioning school-based kitchens in rural areas to centralized kitchens which is completely illegal. Section 5 of the National Food Security Act (No. 20 of 2013) (NFSA 2013)which provides for the mid-day meals in government run and government-aided schools allows for centralized kitchens ONLY in urban areas.

5. (1) Subject to the provisions contained in clause (b), every child up to the age of fourteen years shall have the following entitlements for his nutritional needs, namely:—

(b) in the case of children, up to class VIII or within the age group of six to fourteen years, whichever is applicable, one mid-day meal, free of charge, everyday, except on school holidays, in all schools run by local bodies, Government and Government aided schools, so as to meet the nutritional standards specified in Schedule II.

2) Every school, referred to in clause (b) of 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 the guidelines issued by the Central Government.

In keeping with the National Food Security Act 2013, we demand that no school based kitchen in rural areas should be shut down and handed over to centralized kitchens run by NGOs. Additionally, those schools in rural areas that have been handed over to NGOs, should restart school based kitchens.

3) The large scale handing over of school-based kitchens in urban areas is undermining the nutritional entitlements of children

Even for urban areas, Section (5) of the National Food Security Act 2013, provides for school-based kitchens as a general rule, and the option of centralized kitchens have been provided as an exception to this general rule in cases where there are space constraints for building of kitchens (Annexure 2b: Guidelines for engagement of NGOs). Instead of following this prescription, we have seen indiscriminate closing down of school-based kitchens and their replacement by centralized kitchen. In Bangalore Urban district for example, as per the Annual Work Plan and Budget for Year 2019-20, out of 2133 schools, centralized kitchens were operating in 2021 (95%) schools. Thus, an enabling exceptional provision under the Act has been used to subvert the general principle prescribed by the Act. The consequence of these policy actions are being borne by the children studying in these schools. The nutritional entitlements prescribed in Schedule II of National Food Security Act 2013, which are required to be met through the Mid-day Meal scheme for school going children are being denied because of excessive reliance on centralized kitchens by the department as we explain below through government data, reports and observations during field visits to over 30 schools across 5 districts of Karnataka made by us during June 2019 (Detailed Report at Annexure 3).

a) Consumption and Wastage: In general, the consumption of food supplied by the NGOs through centralized kitchen is lower than the food cooked at school-based kitchens. In some schools where food was being supplied by NGOs through centralized kitchens, the consumption was as low as 60-80%. The lower consumption was due to the poor quality of rice, the lack of taste and freshness in the meals and cultural inappropriateness of the food being supplied. To save on multiple trips to school, NGOs are combining delivery of milk under Ksheera Bhagya scheme and food under Akshara Dasoha (MDM) scheme which considerably reduces the quality of the milk and food. The Comptroller and Auditor General in their Performance Audit of Mid-day Meal Scheme (2009-10 to 2013-14) (Annexure 4) noted with respect to ISCKON (Akshaya Patra Foundation), one of the largest NGOs in terms of coverage of schools:-

ISCKON utilized lesser quantity of foodgrains than the prescribed scale of 100/150gms for preparing one meal. For the period of 2009-10 to 2013-14, shortfall in utilisation of foodgrains was on increasing trend and ranged between 12.70 to 23.79 per cent resulting in not achieving the prescribed calorie.

Non supply of MDM with prescribed quantity of foodgrains resulted in inadequate nutritional support to children.

Inadequate consumption of nutrient dense food by children violates prescribed protein and calorie requirements under Schedule II of the NFSA 2013. Several schools we visited during our fact-finding visits, had adequate space for construction of kitchens and some even had functioning school-based kitchens before they were handed over to centralized kitchens run by NGOs. Hence, we demand that all the schools which have adequate space for building kitchens or already have kitchens should be brought under school-based kitchen mode and steps should be taken to strengthen their functioning instead of indiscriminate handing over to centralized kitchens.

b) Non-adherence to the prescribed menu: Apart for not meeting the nutritional standards prescribed by the Act, several NGOs do not adhere to the rules and regulations prescribed by the central and the state government; violate the terms of their contracts with impunity. A Programme Appraisal Board meeting designated Bengaluru (Urban) and Dharwad as Special Focus Districts (Poor Utilization of Foodgrains and and Low coverage of Children) in 2013 (Annexure 5) following which a menu was prescribed by state government owing to following reasons as stated by the then Commissioner of Public Instructions, GoK:-

“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.”

To address the above problems, a menu was prescribed by the state government which included like onion and garlic. Despite the notification of this menu, Akshaya Patra Foundation, one of the biggest NGOs supplying food in Karnataka,refused adhere to this menu because of their religious beliefs. As per studies done by Mysuru-based Center for Food and Technological Research Institute, onion and garlic enhance absorption of iron and zinc from plant-based diets (Annexure 6). Children in school-going age group in Karnataka have been found to be deficient in both these micro-nutrients. Equally importantly, over 94% children studying in government-run and government-aided schools belonged to SC, ST and OBC communities whose traditional diets include ingredients like onion, garlic and eggs (ref: UDISE Report for the year 2016-17 (Karnataka)).

Additionally, non-adherence to the menu prescribed by the government was in violation of the terms of conditions of the Memorandum of Understanding signed by Akshaya Patra Foundation over past several years. Moreover, as mentioned above, propagation of one’s own religious practices is also prohibited under the Revised Guidelines 2017 for engagement of Civil Society Organizations/ Non Govt. Organisations (CSO/NGO) in Mid Day Meal Scheme) issued by MHRD.

Hence, we demand that all such religious practice based exemptions granted to NGOs should be withdrawn immediately including the one granted to Akshaya Patra Foundation, and the menu prescribed by the state government should be strictly enforced.

Yours Sincerely,

1. Siddharth Joshi, Independent Researcher
2. Dr. Sylvia Karpagam, Public Health Doctor and Researcher.
3. Prof. Mohan Rao (retd.)
4. Swarna Bhat
5. Dr. Veena Shatrughna, Retd Deputy Director, National Institute of Nutrition, Hyderabad
6. Mamatha Yajman, Anekal
7. Niranjanaradhya V. P.
8. Ashok Kumar S.
9. Vidya Dinker, Mangaluru

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