Letter to Shri Yashwant Sinha, Hon'ble MP

Sri Yashwant Sinha, MP                                                                         Date: 17 July 2013

The Hon’ble Chairman

Parliamentary Standing Committee on Finance

Parliament of India

New Delhi

Respected Sir,

Amendment to NABARD Act, 1981

It is learnt that a Bill titled "National Bank For Agriculture And Rural Development (Amendment) Bill, 2013" purporting to bring about certain important and pernicious amendments to the NABARD Act, 1981 is being referred to the Standing Committee (Finance) headed by you, after the bill being presented in the Lok Sabha by Sri P. Chidambaram, Hon'ble Minister of Finance, Govt. of India towards the end of the Budget Session 2013 on 6 May 2013.

We give below our considered collective opinion on the following sections/clauses of the National Bank for Agriculture and Rural Development (Amendment) Bill, 2013, which is only illustrative in nature, but not exhaustive:

INSERTION OF SECTION 2(d)

As per this new section of the proposed new amendment, the meaning and objective of the Central Cooperative Bank (DCCBs) are widened empowering them to utilise the services of other cooperative societies in districts (say, for example, Primary Agriculture Cooperative Societies or PACS) by DCCBs on agency basis.  This may pave the way for winding up of PACS and treat them as Business Correspondents (BC) and/or Business Facilitators (BF) of DCCBs as recommended by “The Expert Committee To Examine Three-tier STCCS Structure” formed by RBI and headed by Dr. Prakash Bakshi, Chairman, NABARD which submitted its report to RBI on 15 January 2013. In fact, if this insertion is allowed it would completely destroy and do away the democratic set up of cooperative movement at the grass root level.

AINBOA suggestion: The clause should not be amended in such a way so as to give “agency status” to democratically elected cooperatives bodies like PACS operating at the grass root level.

INSERTION OF SECTION 2(oa) AND REDEFINING SECTION 21(1)(A)

The definition of “Producer Organisation” is included here so that they are made eligible for NABARD finance/refinance as enshrined in subsequent proposed amendment to Section 21 of NABARD Act, 1981. This, we presume, will pave the way for corporate sector headed by profit oriented big business houses to have access to meagre resources of NABARD which otherwise are being made available to Rural oriented banking and at times to non banking institutions such as StCB , DCCBs, RRBs and MFIs. This will seriously dilute the mandate of NABARD to serve small, poor and marginal farmers of our country.

AINBOA suggestion: Section 2(oa) of the proposed amendment should be dropped. Section 21(1)(A) should be so worded not to make “Producer organisation” eligible for NABARD finance/refinance.  Instead the present system of providing financial services by to NABARD to only those organisations/bodies which are approved by RBI should continue as also further strengthened.

AMENDMENT TO SECTION 3

The amendment proposed for omission of the words “and in consultation with the Reserve Bank” in Section 3(4). This will seriously erode the authority and superintendence of RBI on NABARD, as RBI will no longer have say over where NABARD should establish its offices, branches, agencies in India. NABARD , being a Financial Institution should , like all other such Institutions , be allowed to continue functioning under overall authority and superintendence of the Central bank of the country only.

AINBOA suggestion: The words “and in consultation with the Reserve Bank” should be retained.

AMENDMENT TO SECTION 4

Under this amendment, the authorised share capital of NABARD is sought to be enhanced. In sub-section (1), for the proviso, the addition of words “Provided that the Central Government may, by notification, increase the said capital up to twenty thousand crores of rupees” in place of five thousand crores of rupees as obtaining earlier will pave the way for off-loading of NABARD shares into the market leading to gradual privatisation of NABARD, as the Central Government has not made any provision for inclusion of amendment to increase Central Government shares in NABARD beyond 51% of the subscribed capital. Rather, the Central Government authorises NABARD to issue capital to such institutions and persons in such manner as may be notified by the Central Government.

The substitution of the sub-section 4(2) leading to immediate transfer of RBI shares in NABARD  valued at twenty crores of rupees to the Central Government should not be allowed as it will see the end of RBI subscription to the share capital of NABARD and cutting of umbilical links between the RBI and NABARD, quite in contravention of the recommendations of the “Committee To Review Arrangement For Institutional Credit For Agriculture And Rural Development (CRAFICARD)" headed by Sri Sivaraman that gave birth to NABARD from the womb of the RBI in 1982. Incidentally, at the time of formation of NABARD in 1982, the bill presented to the hon’ble parliament of this country clearly mentioned and was approved too that NABARD will function under the overall supervision and linkage with the RBI.

AINBOA suggestion: The amendment should be so worded to retain the essence of the original NABARD Act, 1981 regarding share capital of NABARD with twenty thousand crores of rupees to be subscribed on a fifty-fifty basis by both the Central Government and RBI. Central Government’s and RBI’s retaining and enhancing of share capital of NABARD will further enhance the capability of NABARD’s financial muscle to serve its clientele better during the present Agrarian crisis in India. Moreover, RBI’s presence in the Board of NABARD with a strong ownership status as enshrined by Sri Sivaraman’s “Committee To Review Arrangement For Institutional Credit For Agriculture And Rural Development (CRAFICARD)", which formed the genesis for carving out NABARD from its parent organization, the RBI, will become handy for RBI to design and control the Monetary Policy of the country effectively by contributing to designing the loan products of NABARD. So, this can be a dynamic Monetary Policy tool for the RBI and it will augur well for Rural India as also the GoI.

AMENDMENT TO SECTION 5

The amendment proposes to substitute wordings of Section 5(3) for the words “Managing Director” with “Chairman and Managing Director” to merge the post of Chairman and Managing Director of NABARD on the lines of Commercial Banks.

AINBOA suggestion: The posts of Chairman and Managing Director should continue as at present in NABARD, as apart from concentrating too much power into the hands of a single individual, now called Chairman and Managing Director (CMD), this blind copying of style, ethos and culture of commercial banks for NABARD can only be viewed as an attempt to push NABARD further down the line of commercial banking away from “Development Banking” mandate of NABARD. Further, Ganguly Committee set up by RBI on corporate governance as also the recent advocacy by the DoPT , GoI has indicated that organiastions headed by a CMD tend to have diluted focus on policy issues and the top most person gets bogged down in day to day operations of the organisation. Further the splitting of the role of the Chairman and Managing Director in Banks and Financial Institutions is now being advocated even by the present RBI Governor that will pave the way for clear demarcation of work for the Chairman and Managing Director with the former concentrating on framing of policies and the later with day to day administration under the direction and guidance of the Chairman.

AMENDMENT TO SECTION 6

In clause (f) of the section 6, the words “the Reserve Bank” is sought to be omitted.

AINBOA suggestion: These words “the Reserve Bank” should be retained as RBI should continue to hold 50% of authorised/paid up share capital of NABARD, with the balance 50% be held by the Central Government.

AMENDMENT TO SECTION 7

In the sub section (1), for the word “Chairman”, the words “Chairman and Managing Director” are sought to be substituted. In sub-section (1A), similarly for the word “Chairman”, the words “Chairman and Managing Director” are sought to be substituted. In sub section (1B), it is told that in case of vacancy in the office of the Chairman and Managing Director, one of the whole-time directors as specified by the Central Government shall perform the functions and duties of the Chairman and Managing Director during such vacancy. In sub-section (3) and (4), similarly for the word “Chairman”, the words “Chairman and Managing Director” are sought to be substituted.

AINBOA suggestion: In respect of sub section (1), (1A), (3), (4), the word “Chairman” should be retained and should not be substituted by the words “Chairman and Managing Director” as NABARD should continue with separate posts of Chairman and Managing Director for the reason adduced above. In respect of sub-section (1B), the earlier wordings as obtaining in the present NABARD Act, 1981 should be retained. So, sub-section (1B) may continue to read as: “In case of a vacancy in the office of the Chairman, the Managing Director shall perform the functions and duties of the Chairman during such vacancy”.

AMENDMENT TO SECTION 8

Under sub-section (1), for the words “The Managing Director and any whole-time director”, the words “Any whole-time director” is sought to be substituted. In the proviso, the words “Managing Director and any such” are sought to be omitted. In sub-section (2), the words “in consultation with the Reserve Bank” are aspired to be omitted altogether. Then, the words “the Managing Director” are sought to be omitted. In sub-section (3), the words “the Managing Director or of” are to be omitted. The proviso is sought to be omitted.

AINBOA suggestion: The entire language of the present NABARD Act, 1981 as enshrined under section 8 should be retained and should not be substituted.

AMENDMENT TO SECTION 11

In section 11 of the NABARD Act, 1981, for the words “Managing Director”, at both the places where they occur, the words “whole-time directors” are sought to be substituted.

AINBOA suggestion: The entire language of the present NABARD Act, 1981 as enshrined under section 11 should be retained and should not be substituted.

AMENDMENT TO SECTION 12

The basic purpose of the amendments of this particular section is to substitute the words “Chairman”, “Managing Director” with the words “Chairman and Managing Director”.

AINBOA suggestion: The entire language of the present NABARD Act, 1981 as enshrined under section 12 should be retained and should not be substituted.

AMENDMENT TO SECTION 19

Under this amendment, the scope of institutions and bodies/individuals who can keep deposits in NABARD is sought to be widened to include a central cooperative bank, primary agricultural cooperative society. The amendment also seeks to omit the necessity of approval of RBI for NABARD to invite for such deposits.

AINBOA suggestion: While inclusion of two new classes of institutions viz. a central cooperative bank and primary agricultural cooperative society to make them eligible to keep deposits in NABARD may not be that objectionable, the condition of prior approval of RBI to invite such deposits by NABARD should not be done away with.  

AMENDMENT TO SECTION 21

Herein, the scope of eligible institutions for NABARD finance/refinance is sought to be widened to include new class of institutions viz. producer organisations. In fact , as of now the provisions of this clause are primarily used to provide refinance to Financial Institutions (mainly Public Sector banks and cooperative banks) for financing asset creating activities in rural area leading to Gross capital Formation (GCF) in the rural & agri sector. Keeping in view that GCF in rural areas is already at a very low level, NABARD should further strengthen its Refinance support under this section so that it peps up the term lending through the banks in Rural India. Any dilution in this role of NABARD by including other organisations like PO will not augur well with the farmers of this country in long run.

AINBOA suggestion: The wording of the present NABARD Act, 1981 should be retained in respect of section 21. For example, the existing sub-section (1) of section 21 reads as follows: “The National Bank may provide by way of refinance, loans and advances, repayable on demand or on the expiry of fixed periods not exceeding eighteen months, to State co-operative banks, central cooperative banks, regional rural banks, or to any financial institution or to any class of financial institutions, which are approved by the Reserve Bank in this behalf, for financing……..”.

The entire new sub-section (5) of section 21 should be dropped, as this may push NABARD to direct financing, even to private corporates. This may dilute the basic mandate of NABARD as enshrined in the preamble of NABARD Act, 1981.

AMENDMENT TO SECTION 22

The proposed amendments under this section too seek to widen the scope of NABARD refinance to new class of institutions including producer organisations.

In the second proviso of the existing NABARD Act, 1981, the necessity of “state government guarantee” for rescheduling of loans given for seasonal agricultural operations under section 21 to eligible class of institutions is mentioned. The new amendments want to drop this most important condition of “state government guarantee” to NABARD and preference is shown to other securities in place of state government guarantee.

AINBOA suggestion: The wordings of the existing NABARD Act, 1981 should be kept intact. Care should be taken to exclude institutions like producer organisations, corporates masquerading as “any financial institution” or “any class of financial institution” from the purview of NABARD refinance / direct finance as aspired under several section / clauses of the newly proposed amendments.

The obligation for eligible class of institutions to obtain and furnish “state government guarantee” or ‘sovereign guarantee’ to NABARD for rescheduling of loans should not be diluted.

AMENDMENT TO SECTION 23,24 &25

Under these sections for rescheduling of loans, investment credit etc. the scope of eligible institutions is once again widened to include even “agro industries” (no mention is made whether they are run by big corporate sector or not), “medium enterprises”, “producer organisation”.

A new sub-section named as sub-section (3) of section 25 is proposed to be inserted under the new amendments, which basically entitles NABARD to go in for direct financing to eligible institutions including corporates (?) approved by the “Central Government” (interestingly here the necessity of such institutions having been approved by the “Reserve Bank” is very carefully omitted)

AINBOA suggestion: The wordings of the existing NABARD Act, 1981 for these sections except for making “Multi-state cooperative society including a multi-State cooperative bank” eligible for NABARD refinance should be kept intact.

The new sub-section (3) of section 25 should be dropped outright.

INSERTION OF NEW SECTION 25A

The purpose of this new section seems to entitle NABARD to combine different loan products to create new combo loan products under section 21 or section 24 or section 25. The scope of eligible institutions is once again widened herein too to include “producer organisation” etc. Herein too, the necessity of RBI directions is waived and fully replaced with “Central Government” directions. 

AINBOA suggestion: While combination of different loan products (short, medium and long term) is not objectionable per se, but it needs further careful study and vetting by experts and by the Hon’ble Parliament of India. In respect of wordings for eligible institutions, AINBOA suggests to follow the pattern as suggested against section 23, 24 and 25 above.

INSERTION OF NEW SECTION 30B

This new section wants to empower the Board of National Bank (NABARD) to grant, open, issue, confirm or endorse letters of credit and negotiate or collect bills or other documents drawn thereunder.

AINBOA suggestion: Here, there is no clear-cut provision, as obtaining in section 30A of the existing NABARD Act, 1981 to the effect that the National Bank may rediscount bills of exchange and promissory notes made, drawn, accepted or endorsed by any company or body corporate concerned with agriculture and rural development presented by a scheduled bank, a State co-operative bank, State land development bank, regional rural bank or any other institution or class of institutions approved by the Board. So, under the new section 30B of the proposed amendment, there is no bar, it seems, for NABARD to grant, open, issue, confirm or endorse letters of credit and negotiate or collect bills or other documents even if they are unrelated to agriculture and rural development. This provision should be qualified to include clear-cut relations with agriculture and rural development or else it may lead to dilution of NABARD’s assigned mandate.

AMENDMENT TO SECTION 38A

Under the present section 38A, the National Bank (NABARD) may, in consultation with the Reserve Bank, promote, form or manage or associate itself in promotion, formation or management of companies, subsidiaries, affiliates, societies, trusts or such other association of persons, as it may deem fit, for the purpose of carrying out its functions under this Act. In the proposed amendment, for the words “in consultation with the Reserve Bank”, the words “with the approval of the Central Government” are proposed to be substituted.

AINBOA suggestion: The earlier wordings of section 38A should be kept intact, necessitating NABARD to consult Reserve Bank while forming subsidiaries and other groups of institutions under section 38A.

INSERTION OF SECTION 42A

Under this section, National Rural Credit (Short Term Operations) Fund is sought to be constituted with contributions from Central and State Governments, Reserve Bank and NABARD.

AINBOA suggestion: This insertion is welcome. But it should be so worded that it becomes obligatory for the Governments and RBI to contribute to such fund. Linking of central government contribution to the annual budgetary contributions towards Agriculture and Rural development sector.

 ENUNCIATION OF BASIC PRINCIPLES FOR AINBOA SUGGESTIONS ON AMENDMENTS

1. Appalling condition of the farm sector – Need for strong NABARD presence and support

A careful study of the proposed amendments will definitely push one to presume that if carried out to its intended conclusion, such amendments will take out the essence of “development banking” ethos from NABARD, quite contrary to the purpose for which this important institution was given birth from the womb of RBI in 1982. These will also put NABARD at the mercy of Private equity and profit oriented market forces that may utilise this unique organisation to further their interest at the cost of millions of Small & Marginal farmers and landless labourers.

Many of the recent agriculture sector surveys (including those conducted by NSSO) , study reports/papers (including those from Swaminathan foundation, RBI etc.) as also NABARDs’ own in-house publications clearly point to the need for forcefully pushing the Fis to cater the legitimate credit needs of Small & Marginal Farmers whose contribution in providing food safety to the country is well acknowledged. NSSO has also pointed out that in spite of low technology, less capital intensive farm operations this segment of the country is forced to undertake, the farm output efficiency ratios of Small land holdings compares much better to that of large land holdings. Over the years, NABARDs’ refinance support to Ground Level credit Flow towards both seasonal Agricultural operations as also the assets based Term loans is dwindling for want of operational friendly financial resources. The fact remains that per hectare average agricultural credit in the country varies from Rs 1200-1800 per hectare in states like Bihar, WB, Chattisgarh, MP etc to Rs. 1.00 lakh and above in states like Tamil Nadu, Punjab, Haryana etc. makes it imperative on part of policy makers to further strengthen NABARD so that it can provide refinance support to Rural Financial Institutions to cater the likely demand in less developed/developing. The future of food security in our country lies in increased level of farm productivity which can be achieved by directed credit and technology dissemination to Small & Marginal farmers and not by ushering in an era of private players in the rural sector.

The fact that even in countries like USA, European Community and Australia etc. the farm sector is highly subsidized by the respective governments, underlines the importance of government patronage and supervision to this sector. Agriculture, Mining and aqua-agriculture constitute the Primary Sector of the GDP pyramid and this sector is the producer of raw material on which the secondary sector (Industries) thrives. Allowing corporate houses and off shore business entities to take control of the Raw material producing sector of the economy will gradually lead to progeny of Colonial Era. The way colonial rulers exploited the raw material resource of the third world countries to benefit their industrial Sector is well recorded in the History. Eminent economist , including Noble laureate Prof. Amartya Sen has advocated strong policy support to Agriculturists and others involved in  Primary Sector activities so as to safe guard them from market exploitation as also to provide them with user friendly Terms of Trade.

In spite of all technological advancements and polity the outreach of formal credit delivery system in rural areas in general and to resource poor citizens of this country in particular remains a cause of worry. “The Report of the Task Force on ‘Credit Related Issues of Farmers’ (Chairman: Shri U. C. Sarangi, ex-chairman, NABARD)”, submitted to the Ministry of Agriculture, Government of India, “…more disquieting feature of the trend was the increase in the share of moneylenders in the total debt of cultivators. There was an inverse relationship between land-size and the share of debt from informal sources. Moreover, a considerable proportion of the debt from informal sources was incurred at a fairly high rate of interest”. The continued dependence of small and marginal farmers on informal sources of credit such as private moneylenders was attributed to constraint in the rural banking network and services arising out of financial sector reforms.

In such a situation, the proposed amendments will dilute the assigned mandate for which NABARD was created and corporate bodies and business houses, who otherwise have many other windows to access credit, at times at even friendly terms, will have access to already very limited resources of NABARD. This will adversely impact the interest Small & Marginal Farmers, landless labourers and other weaker segment of the Rural Society and will further push them to the periphery of institutional rural credit.

As the principal regulator, supervisor and guardian of financial sector of our country, we opine that RBI too can least afford to shut its eyes to such pernicious amendments and allow NABARD to drift to a course not envisaged by RBI or Govt at the time of formation of NABARD as enshrined in the Preamble of NABARD Act, 1981.

Similarly, the Central Government also should give a fresh thought to such amendments and  withdraw or modify them in the light of the suggestions offered by us above in the interest of millions of landless, small and marginal farmers of the country passing through the vortex of unprecedented agrarian crisis that has engulfed the lives of more than quarter of a million of hapless Indian farmers who committed suicides between 1995 and 2011 as per data furnished by the National Crime Records Bureau (NCRB) .

2. Need to maintain a strong umbilical link between RBI and NABARD

The transfer of balance 1% of RBI shares of NABARD into the hands of Govt. of India will lead to cutting of last umbilical link between RBI and NABARD quite contrary to the recommendations as given by Sri Sivaraman’s “Committee To Review Arrangement For Institutional Credit For Agriculture And Rural Development (CRAFICARD)" which formed the genesis for carving out NABARD from its parent organization, the RBI.  NABARD was thus envisaged as an autonomous Apex developmental organisation having strong links and synergy with RBI. That Deputy Governor (RPCD), RBI, used to be the Chairman of NABARD and RBI had 50% stake-holding in NABARD are testimony to this fact.  It is thus, ridiculous that such transfer of partial NABARD ownership from RBI to Govt. of India fully will provide for increased public accountability of NABARD, as if RBI ownership all these years have stood in the way of having larger public accountability of NABARD. In fact, it is a move to make NABARD accountable only to Corporate and private entities instead to the public of this country. Moreover, the snapping of formal, institutionalized umbilical links between these two important institutions having shared work culture, ethos and development orientation will be of mutual disadvantage – for RBI losing an important supervisory eye like NABARD on the goings-on in the rural credit front, losing a dynamic monetary tool to help design the loan products of NABARD sitting at NABARD Board and for NABARD to lose the benefit of sagacity and guidance from such a premier central banking institution like RBI.

3. Need to strengthen NABARD resources through contribution from Central Government and RBI

The gradual shrinking of institutional funds to NABARD, by way of contribution to share capital, NRC (LTO) and NRC (Stab) funds, curtailment and near stoppage of GLC from RBI as also the levying of Income tax on NABARD has led to unprecedented resource crunch in last 5-8 years. In spite of the resource crunch NABARD has tried to play its allocated role by providing refinance support to eligible institutions over the years (average growth of refinance support ranges between 10-15% (year on year). NABARD has been able to meet this requirement by increased market borrowings 9average growth ranges from 15-20 % during the same period). This increased reliance on costly source of funds has handicapped NABARD to pro-actively pursue its agenda of ‘development through credit’ and to strengthen the rural cooperative sector , which still accounts for almost 50-55% share of total crop loan disbursed and 70-80% of the share of crop loan disbursed to small & marginal farmers. With this backdrop in view, the proposed move of exposing NABARD’s hard earned and limited resources for financing new class of financial institutions approved by Govt. of India may lead to direct financing of NABARD to Private sector entities / companies in a big way - an issue that has already generated enough heat by now leading to huge exposures in the media and strictures from RBI to NABARD about impropriety of such financing under current law / rules and regulations for such kind of financing. This will also lead to exposure of an Apex institution like NABARDs’ resources to market risk and at the mercy of Industrial Houses and Privately owned Entities.. The snapping of umbilical link between RBI and NABARD may also increase the chance of unintended “regulatory forbearance” on the part of RBI vis-a-vis NABARD (in the absence of RBI’s non-representation in the board of NABARD) that may be disastrous for the future of rural credit in our country. More so, it is the RBI which has necessary specialization and prudence in leading the country’s financial institutions as per the overall economic scenario of the country , as such RBI control and supervision over NABARD shall augur well for both NABARD as also the Rural & Agriculture sector in the country.

4. Aftermath of global financial crisis –Need to strengthen NABARD to tune up institutional rural credit

You may be aware that the move for these retrograde amendments has also generated a lot of genuine concern about the future of development banking in India, which has withstood the test of time and has also become handy for the country to weather the recent “Global Financial Crisis”. If we look at the landscape of post-crisis global financial scenario, it has been proved beyond doubt that globally the “member-driven cooperative financial sector” has outperformed the “share-holder driven joint stock multinational banks, insurance and financial institutions” nearly in all countries under all parameters of sound and prudential financial practices as per a latest International Labour Organisation (ILO) report. (Ref. “Resilience in a downturn: The power of financial cooperatives”, ILO, 2013) In such a scenario, these members driven, de-bureaucratized, cooperative structures can be a highly effective tool for India, having a very rich legacy of cooperative movement, to fill-in the gaps of institutional credit left open by commercial banks, especially after the ushering in of Neo-liberal economic reforms in our country since 1991. These institutions need continued and effective financial, supervisory, regulatory support from institutions like NABARD and RBI working hand in hand as envisaged by CRAFICARD.

5. Merging separate post of Chairman and Managing Director as Chairman and Managing Director

The clubbing of the post of Chairman and Managing Director of NABARD into a single entity of Chairman-and-Managing Director (CMD) will push NABARD closer to commercial banks in practice as well as structuring. Ganguly committee formed by RBI on good governance in corporate bodies , as also DoPT , GoI had clearly spelled out the demerits of concentrating all the administrative and policy making powers in the ambit of a single person and CRAFICARD, being a visionary document , in line of this philosophy had therefore recommended creation of two distinctly separate posts in NABARD. More so ,  it may be noted that recently the RBI Governor too strongly opined in favour of separating the posts of Chairman and Managing Director even in commercial banks to allow the Chairman to concentrate basically on policy issues and Managing Director to look after the day to day administration. It may help strengthen the autonomy of PSUs too.

 All India NABARD Officers’ Association (AINBOA) and All India NABARD Employees Association (AINBEA) have separately and jointly opposed these amendments and the Associations have already chalked out their programme of organisational action to this effect beginning on 8 May 2013 last. In such a situation, we earnestly appeal to the Parliament and its committee system, being the guardians of democracy of the largest democracy of the world, to vet these amendments carefully in the interest of the millions of farmers of this country. You along with other Hon’ble members are earnestly requested to utilise your good offices with the Govt. and the powers that be to prevent such pernicious, anti-people and anti-farmer amendments to take effect in the overall interest of economy of our country. We are confident that you will not fail in your mission to render justice to the country, especially to farmers reeling under severe agrarian distress.

We shall be glad if you please grant us an opportunity to submit our views in details and in person to you and other members of the standing committee at an appropriate date fixed by you, for which we will remain ever grateful to you and to the standing committee. 

With kind regards,

Yours faithfully,

(Dr.D.S.Chauhan)

General Secretary

Copy to: All the Hon’ble Members, Parliamentary Standing Committee