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Critique of West Bengal Food Security Rules 2016

The West Bengal Food Security Rules 2016 have been declared on 3rd January 2017 with the express purpose of ensuring better functioning of the National food Security Act 2013. However there are gross lacunae in these rules, so that much improvement cannot be expected. The problems are given below:-
1.       Non-formation of the State Food Commission
Under Section 16 of the NFSA 2013, the State Government is required to form a State Food Commission. The Commission is to monitor and evaluate the implementation of this Act; inquire into violations of entitlements provided; hear appeals against orders of the District Grievance Redressal Officer; give advice to the State Government, and other agencies for the effective implementation of food and nutrition related schemes and Act; and, prepare annual reports which shall be laid before the State Legislature.
It is now 4 years since the Act has been passed , but no State Commission has been formed. The Rules (Rule 8(5)), however, mention that if the complainants or officers are dissatisfied with the DGRO’s orders they may appeal to the State Commission. The entire Grievance Redressal process under the Act is therefore incomplete.

2.       Inclusion Of All Concerned Departments
The NFSA is not just a law for Public Distribution System (PDS) . It is a law with the following provisos:-
         i.            provisions for nutritional support to pregnant women and lactating mothers through provision of cooked food in anganwaris, and through a maternity entitlement of Rs.6000 (Section 4);
       ii.            provision for nutritional support to children through anganwaris  and cooked food at school(Section 5);
      iii.            provision for prevention and management of  severe child malnutrition(Section 6);
     iv.            right to receive food security allowance (Section 8);
       v.            provision to make special provisions for food security for people living in remote, hilly and tribal areas.(Section 30)
     vi.            provisions for steps to further advance food and nutritional security. (Section 31)

The NFSA also clearly stipulates that the State Government is responsible not for just PDS but also for other welfare schemes under the Act. Thus, as per Section 24, the State Government is not just responsible for the monitoring of the PDS, but it is “responsible for implementation and monitoring of the schemes of various Ministries and Departments of the Central Government……for ensuring food security to the targeted beneficiaries in their State.”
As per Section 28, the State Government is also responsible for “periodic social audits on the functioning of fair price shops, Targeted Public Distribution System and other welfare schemes...”
As per Section 29, Vigilance Committees formed by the State Government are to “perform the following functions, namely:—
(a) regularly supervise the implementation of all schemes under this Act;”
The Act therefore goes much beyond the PDS and would involve departments other than the Food and Civil Supplies Department such as the Women and Child Welfare Department (for anganwaris), Health Department (for maternity benefits) and the Education Department (for school meals).
However, the Rules have been formulated as if only the Food and Civil Supplies Department are involved. The Rules must be changed to include all departments. 
In particular we would like to draw attention to the following:-
Rule 6 (2) limits the powers of the DGRO to inquire into complaints related to issuance and cancellation of ration cards; non distribution of food grains and any other matter related to the PDS. Similarly, Rule 6 (3) limits the filing of complaints to the DGRO to the above-mentioned matters alone and mentions that the complaints field before the DGRO must concern only “matters mentioned in sub rule (2) of Rule 6.”
The rules regarding monitoring and vigilance committees specifically refer to monitoring of ration shops and the PDS at all levels and do not mention other welfare schemes at all.

3.       Social Audit
Rule 10 mentions that “the State Government may entrust a local authority “ or “if it considers necessary, entrust other bodies such as research organisations, civil society organisations, NGOs or Gram Sansads etc. to conduct social audits on such terms and conditions as may be specified.” Looking at the abysmal record of weeding out corruption in the public distribution system, it is suggested that it should be made mandatory to involve non-government bodies like research organisations, civil society organisations and NGOs in social audit. Also, social audit by Gram Sansads and their recommendation should be made mandatory for renewal of fair shop licenses, for continuation of service of anganwaris workers, midday meal cooks and self help groups and schools teachers who manage the midday meal scheme.

4.       Monitoring and Vigilance Committees
Under Rules 11 to 14, Monitoring and Vigilance committees are being formed from the state level to the district, block and fair price shop level. In the past, these Committees have failed in their task of improving the functioning of the Fair Price Shops and other welfare schemes because they are often unaware of their responsibilities. Similarly, meetings of these committees at all levels are irregular and sometimes do not take place at all for years. A process of training for committee members , and a system of supervising and monitoring the functioning of these committees must be set up.

By
Anuradha Talwar

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