Publications
 
INTELLECTUAL PROPERTY RIGHTS AND HUMAN WELLBEING 
Position Paper on India
 
Veena Ravichandran
COMMITTEE ON SCIENCE AND TECHNOLOGY IN DEVELOPING COUNTRIES(COSTED)
COSTED Central Secretariat, Chennai - 600 025
in Intellectual Property Rights held at the M.S.Swaminathan Research Foundation
 


Introduction 

 Intellectual Property Rights  (IPRs) have the potential to influence almost every sphere of human creativity. In recent times   this  topic     has been  generating   wide - ranging discussions and debate.  In India, there is an increasing awareness on the issues and implications of the new trade regime brought about by the World Trade Organisation (WTO) and the inclusion of Intellectual Property Rights (IPRs) within its purview.  

India is currently continuing her efforts towards globalisation and liberalisation of trade. The consequent readjustments in the economic, industrial, legal and R&D policies are generating a wide range of concerns and speculations. The issues relating to biodiversity, genetic engineering, environmental safety, agriculture and food security have been widely debated and yet, many aspects in these areas remain unclear and underestimated.  These issues are yet to be fully understood and therefore the process of policy response has to rely on case studies, public debates and impact assessments. 
  
This paper will confine itself to intellectual property rights as applied to the use of biological resources and their implications for human well being and will not deal with the goods and manufacturing sector. The paper begins with some basic information on India and her and natural resources in the context of IPR, her present status in the various international conventions related to IPR, and her efforts to readjust national policy and governance.  The paper discusses the issues and challenges to be addressed in dealing with IPRs pertaining to biological resources without compromising on human well being.  Lastly, a few options and guidelines are put forth. 
  

India - Some Basic Facts and Figures 

 India’s population has crossed 1 billion by the dawn of this millennium.  Despite the wide socio-economic range of this large population, India has a significant resource of science and technology personnel.  The national investment in R&D is 82% of GNP of which 73% comes from the Government (Central and State) and only 16% are funded by private industries.   

 Over 64% of India's population is directly engaged in agriculture and a good proportion of the population is indirectly dependent on agriculture which in this country is more than an economic activity.  It is a way of life and the basis for the social fabric of rural India. Agricultural production accounts for 31% of the GDP. Globally, India is the largest producer of tea, second largest producer of rice, fruits, vegetables and sugar, third largest producer of cereals, fourth largest producer of wheat and major oilseeds and fifth largest producer of cotton.  

  India is one of the 12-mega diversity of the sites in the world. The country is known to have over 47,000 plant and 75,000 animal species.   About 15,000 species of plants have been identified as very important from the point of view of medicinal and economic value.  Over 400 formulation of different herbal medicines are already in the market.  The country is a repository of not only biodiversity, but also a rich diversity of traditional knowledge and alternate systems of medicine.  These systems have played a significant role in conserving the natural biodiversity and in diversified agricultural practices 

Historical perspective of IPR in India  
  
The basic elements of IPR in India were introduced as early as 1856 on framing the Act on Protection of Inventions based on the British Patent Law of 1852.  The act was modified several times subsequently.  The most important development was the patent act of 1970, which came into force in 1972.  In 1994, an ordinance was framed to amend the patents act 1970 wherein the concept of exclusive marketing rights was introduced.  The bill is yet to be passed by the Government. 

The Indian contribution to the global pool of patents is insignificant while there are about 33 million patents published worldwide and about half-a million is added every year.  As Dr.R.A.Mashelkar, Director General of CSIR puts it, there has been no culture of patenting in India. Today, the patent awareness in India is on the rise. This is largely due to the imperative to comply with the provisions of WTO. It is not surprising therefore that the last five years has seen a vigorous drive on patenting and encouragement of innovative R&D. The country as a whole recognises an urgent need to foster innovation and creativity to meet the challenges of this new regime. 

 Following the signing the GATT agreement in 1994 and the Convention on Biological Diversity in 1992, India is pursuing efforts to put in place the necessary legal framework. At the same time, India is also examining the implications of this convention vis-a-vis other agreements executed earlier such as the TRIPS and avoid inconsistencies. 
  
 India's Position in International Conventions 

 India is a signatory to the following conventions relating to IPR.   

Bern Convention for Copyright                  1886 
Paris Convention for the Protection           1967 (last revised) 
of Industrial Property 
Strasbourg Convention on International    1971 
Patent Classification   
Convention on Biological Diversity             1992 
General Agreement on Trade and Tariff     1995 
Patent Cooperation Treaty (PCT)                 1998 

  
Present status of governance and policy development 
     
India has successfully put in place legal instruments to conform to WTO with respect to the following IPRs: Copyrights, Trade Marks, Geographic indications, Industrial designs, Integrated circuits and Trade secrets. 
The following legal instruments (bills) are pending consideration by the Parliament: 
Patents    :   Patent Amendment Bill, 1999 
Plant  varieties  :   Bill for the Protection of Plant Varieties  and Farmers' Rights, 1999 
Biodiversity  :   The Biological Diversity Bill, 2000 

India is a founder member of WTO and is therefore a party to TRIPS agreement under GATT, which came into force on 1.1.95. Being a developing country India was entitled to a transition period of five years up to 1.1.2000 for most provisions of TRPS. An important exception is the introduction of product patents in areas of technology not covered so far, for which time is available up to 1.1.2005. The patent amendment bill, 1999 is the second amendment to the Indian Patent Act, 1970 and is expected to fulfil these requirements. 

  The Indian Patents Act 1970 does not allow the patenting of plants or animals or microorganisms. Although it does not contain any such specific exclusion, the definition of an invention seems to exclude microorganisms.  However, under the article 27.3(b) of the TRIPs agreement, India is obliged to introduce patents for new varieties of plants or have an effective sui generis law to protect them.   For product patents on microorganisms and non-biological processes, India has time up to 1.1.2005. These requirements are not consistent with the requirements of CBD of which India is a signatory. 

   The Biological Diversity Bill, 2000 has been introduced to implement the provisions of the CBD in India.  This Bill is pending consideration shortly at the monsoon session of the parliament. The salient features of this Bill include: 
 

  • Regulation of access to biological resources of the country with the purpose of securing equitable share in benefits arising out of the use of biological resources and associated knowledge relating to biological resources.
  • Conservation and sustainable use of biological diversity
  • Respecting and protection of knowledge of local communities related to biodiversity
  • Securing sharing of benefits with local people as conservers of biological resources and holders of knowledge and information relating to the use of biological resources
  • Conservation and development of areas important from the standpoint of biological diversity by declaring them as biological diversity heritage sites.
  • Protection and rehabilitation of threatened species
  • Involvement of institutions of self-governments in the broad scheme of the implementation of the act through constitution of committees.

The protection of plant varieties (PPV) and Farmers' Rights Bill is also pending consideration by the Parliament at its monsoon session.    This bill strives to stimulate investments for the growth of the seed industry, ensure plant breeders' rights as well as farmers' rights. 

Debatable Issues 
 

1. Biodiversity and genetic resources  -  Private  protection  versus Communal rights
Developing countries are generally biodiversity - rich countries and developed countries are biodiversity- poor countries.  The value of biodiversity is now very well recognised and that bioresources and biodivesity essentially serve as feed stock of medicine, industry, health care and social development.   The fundamental issue here is to balance the imperatives between equitably sharing the benefits of biodiversity and the responsibility of preserving and sustainably using biodiversity.  There are certain inherent contradictions and often-conflicting objectives between TRIPS and CBD that challenge this balancing act. This is not only true for India, but also for the over 130 countries that are signatories to both TRIPS and CBD. 

  Specifically, TRIPS promotes individual, private property rights over products and processes whether they are biodiversity- based or not.   On the other hand, CBD recognises the collective rights of local communities on the biodiversity.  It is well recognised that the survival of human well being depends on the conservation and free availability of biodiversity and not its protection by private property rights. Thus, in the area of biodiversity, CBD must take primacy over TRIPS and the amendments at the forthcoming TRIPS review must incorporate provisions of equity and ethics.  All life forms and  related knowledge from traditional systems must be excluded from TRIPS 

Legislation for access to genetic resources must ensure privileged access for non-commercial research and development efforts, particularly in critical areas for developing countries. The ensuing example illustrates the kind of conflicts that are likely to arise in providing free access for non-commercial R&D 

There are over 1300 gene banks holding over 6 million accessions of genetic resources all over the world.  These gene banks provide access to plant genetic resources for food and agriculture.  The CGIAR system has one such gene bank supported by policies of unrestricted availability to bona fide users.  This is a public funded facility held in trust for human kind by FAO through an agreement in 1994 to support research of benefit to developing countries. In spite of this agreement, there have been several cases of material from CGIAR system finding its way to commercial breeders in industrialised countries who have tried to patent it.  Consequently, in 1998, the Chairman of the CGIAR called for an immediate halt to the granting of any form of plant breeders’ rights or any other form of IPRs on the varieties held by the CGIAR’s International Agricultural Research Centres.   
 
  

2. Protection of Traditional knowledge 

The Convention on Biological Diversity came in to existence in order to protect the hitherto unprotected genetic resources in the public domain, which was freely accessible to everybody.   The bioresources are accompanied by rich traditional knowledge on the use of these resources. This knowledge is also in the public domain.  However, from a legal point of view, traditional knowledge and innovation are non-existent and therefore unprotected.  This is in sharp contrast to the protection of industrial innovations, which, under certain conditions can be protected by Intellectual Property Rights. 

 In recent years, there is an increasing market shift to products from bioresources. A majority of these products are derived from public domain knowledge, including traditional knowledge, usually patented by a minor inventive step. It is one thing to patent a product ab initio from its raw material but quite another to free ride on public domain knowledge that has seen the test of time and generations of human innovation. Suggestions have been made at the WTO committee on Trade and Environment that for patents based on traditional knowledge, the country of origin must be disclosed and prior informed consent be sought. This suggestion was rejected for its impracticability. Nevertheless such solutions are necessary in international intellectual property law if developing countries are to be notified and fairly and equitably compensated for commercial use of their resources and traditional knowledge. There is a need to build international consensus on this issue.  

  A pioneering effort in this direction was made by the M. S. Swaminathan Research Foundation in 1998 through a report to the UN outlining a conceptual framework for equitable sharing of benefits from plant genetic resources.  In a country where much of the traditional knowledge is in the oral realm handed down over generations by word of mouth, there is a need to consolidate and record this information in a form suitable for legal use.  Above all, there is an urgent need to provide a legal recognition and status for traditional knowledge, thereby paving the way for protection through property rights 

 There are many grey areas that need to be understood- the nature of the knowledge, its patentability, definition of the community holding the knowledge, inter-generational equity and so on. 
  

3. Agriculture and Food Security 

 Given the importance of agriculture in the Indian economy, there have been extensive public debate and speculation on the legal amendments relating to the agricultural sector.  The newly introduced PPV bill has been bitterly criticised as framed on the lines of the UPOV convention.  It is seen as being exclusively in favour of private enterprises and commercial plant breeders and against the interest of the farmers.  UPOV has left the onus of farmers' rights to be framed by the sovereign nations. 

         In India, private seed companies originally initiated plant breeders' rights in the late 80's after the adoption of the New Seed Policy in 1988. The govt. of India then liberalised the import of seeds for joint ventures, including hybrid seeds for several important crops. Such developments, no doubt, could have a positive impact on private R&D in this sector. However, the increasingly propreitary nature of biotechnologies, declining publicly funded R&D in this sector and the diminishing role of international and national agricultural research centres will adversely affect the diffusion of such technologies. This is likely to place developing countries at a greater disadvantage, perpetuating a vicious cycle of dependency on multinational enterprises. The marginal farmer is likely to be marginalised further.  This is primarily due to the fact that under the present conditions, the incentives for generation and diffusion of IPRs are entirely different. 

 The solution lies in understanding clearly, the role of the commercial breeder vis-à-vis the farmer. The latter performs the roles of a breeder, conserver and cultivator. Hence these roles have to be adequately compensated. He is entitled to the rights as any other breeder. In addition his conservation efforts must be recognised and rewarded.  As a cultivator, he must be entitled the privilege of planting back seeds from his harvest and given rights for limited exchange. 

General Guidelines  
   
1. As regards protection of biological resources, it would be advisable to keep options open in relation to art. 27.3 (b) of TRIPS and avoid narrowing down of options. Better still would be to exclude  all life forms  and related  traditional knowledge from TRIPS 

2. To engage multi-stakeholder dialogues and public debates to facilitate understanding of the fuller implications of the legal amendments. The debates and  dialogues must  necessarily be based on  hard evidence  through case studies  and impact assessments 

3. Implementation of  the legislation must involve the lowest  grassroot level communities and must be well balanced to represent all the stakeholders 

4. To formulate and put in place more appropriate incentives for sustained diversified farming systems that safe guard the rights of local communities. 

5. The vigilance  function on access to resources  and  grant of  IPRs in the case of bioreources  must not in anyway hinder  access  for bonafide research  towards basic  human needs 

6. Alongside punitive  measures it would be desirable to eventually  institute economic incentives  for  adherence to  best practices  

7. Definition of bonafide use of genetic resources would facilitate regulation to access.   

8. Need for uniform standards for reference database for effective functioning of the legal instruments. 

9. Capacity building at every level of management of the IPR legislations. 

10. Stimulating the informal sector  to use the vast body of traditional  knowledge in the public domain for the small scale sector 

11. Promote and encourage innovations in socially useful sectors through "Utility Certificates" or "Petty Patents"  (strictly for use within the country).  Japan and Germany used such mechanisms in the 1940's to upgrade and strengthen their innovative capacity. These mechanisms could serve as precursors to legal IPRs. 

12. Strengthen the role of the dispute settlement mechanism 

Conclusion 

      In responding to the imperatives of the global trade regime, it is necessary to re-visit the objectives behind subscribing to the new regime. The objectives clearly go beyond competition based on volume and value of goods and services that a country can place in international trade. They rest on sustaining the human well being. 

Bibliography 

1. Intellectual Property Rights in Indian Agriculture, No.44, ICRIER Report by Ahluwalia Isher, 1998. 

2. Intellectual Property Rights in Biology, Eds.  D. Balasubramanian et al  Proceedings of a seminar organised by the Indian National Science Academy, 1996, Mysore, India 

3. Biodiversity, Biotechnology and Intellectual Property Rights- Implications for intellectual Property Rights,   Jai Prakash  Mishra, World Journal of Intellectual Property, p211 

4.  Trade, Intellectual Property, Food and Biodiversity - A discussion paper by  Geoff  Tansey, Quaker Peace and Service, London, 1999 

5. TRIPS versus CBD - Global Trade and Biodiversity in conflict, Grain Newsletter, no.1. URL: http://www.grain.org/publications/issue1.htm 

6. Legal Protection of Genetic Information and  Related Traditional Knowledge, Susette Biber-Klemm,  NFP 42, National Research Program ' Foundations and Possibilities of Swiss Foreign Policy'  March 2000, URL: http://snf.ch/NFP42/ 

7. Gearing up for the  Efficient Management of Intellectual Property Rights in the 21st Century, N/R. Subbaram and G. Thyagarajan,  1998 COSTED Occasional Paper No.4