Competition Commission of India,

HT House,

New Delhi

Date :9/04/17


Dear Sir,

SUB: Information for cancelling of Dow/DuPont merger in India


After reviewing the CCI document on Dow/Dupont merger we Navdanya, a network of organic farmers and seeds savers, write you seeking the rejection of the application for the merger between the Dow and Dupont based on the objective of the Competition Act which is

which is to protect the interests of consumers and to ensure freedom of trade carried on by other participants in markets, in India.

India is a land of small farmers . They are the “other participants in markets in India “ producing diverse , healthy food to India’s citizens and consumers .The right to seed , right to life and livelihood , and the right to produce healthy and safe food of our small farmers will be directly impacted by the merger of Dow Dupont . By


1. Misleading and incorrect information due to Conflict of Interest

The complete data submitted to the CCI and put in public domain is created by the corporations themselves and is not from a “third independent party”. The dossier says “Note: The market shares are based on 3rd party independent database, i.e., CropLife India (for value shares) and GfK Sigma’s Agrowin dataset (for volume shares).”

CropLife cannot be categorised as independent third party since Dow, Dupont are both members of the CorpLife. Hence there is a direct conflict of interest. (please find document attached).

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About Navdanya

Navdanya means “nine seeds” (symbolizing protection of biological and cultural diversity) and also the “new gift” (for seed as commons, based on the right to save and share seeds In today’s context of biological and ecological destruction, seed savers are the true givers of seed. This gift or “dana” of Navadhanyas (nine seeds) is the ultimate gift – it is a gift of life, of heritage and continuity. Conserving seed is conserving biodiversity, conserving knowledge of the seed and its utilization, conserving culture, conserving sustainability.

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