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Research & Reviews: Journal of AYUSH

Volume 1, Issue 2, August 2012, Pages 50-62

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ISSN: 22782214 STM Journals 2012. All Rights ReservedPage 50

Patenting of Siddha Formulations: Scope and Issues

Dr . G. S. Lekha*Patent Attorney (IN/PA), Indian Patent Office, India

*Author for Correspondence:E-mail:[email protected],Tel: + 91-9940557147

1. INTRODUCTION

Siddha, one among the indigenous systems of

medicine, owes its origin to medicinal ideas

and practices of a class of Tamil sages called

siddharsperfectedor holy immortals. It

is a way of life that emphasizes positive health

and explains the human body as a miniature of

the universe. The fundamentals of the system

embrace five elements and three humors,

emphasize emotional, mental, spiritual and

physical elements of a person and claim to

treat the person as a whole in this context. The

system is routed in social context that sees the

world in terms of social and spiritual relations

between all life forms.

Siddha medicine system unlike other systems

is a complex system of science in so far as it

has included in the works of medicine,

alchemy, yoga, rejuvenation, Varma,etc., with

a view to elevate them in the long run to the

level of spiritualism.

The siddha system of medicine is a living

science system which has survived through

centuries and cannot be condemned as

unscientific only because we are ignorant of its

scientific basis. We may discover and explain

with reference to scientific terminology for the

appraisal of modern world. Knowledge in this

system is not static and is inherently dynamic

in nature and evolves in response to challenges

posed by the environment. Application of

ABSTRACT

Siddha system, one among the indigenous systems of medicine, is being practiced in India since time

immemorial. It includes principles of positive health and therapeutic measures relating to physical,

mental, social and spiritual welfare of human beings. While it is a good sign that western countries

began to appreciate this ancient wisdom integral to the Indian heritage, the recent past has witnessed

attempts from corporate world and pharma business outfits trying to misappropriate this knowledge

and resources associated with Indian traditional practice. Moreover, countries worldwide have been

striving intensively, many a time by unfair means, to mine the plant wealth of our country on account of

its high demand as a major source of potential drugs and the economic significance of these plant-

based compounds. Hence, conservation of biodiversity and protection of knowledge associatedtherewith inter alia various aspects of traditional medicine practices have become very significant and

critical for us. Protection of traditional knowledge has become a topic of national and international

debate owing to inflated bioprospecting and the issues regarding depletion of biodiversity. This

manuscript highlights the scope of research in the field and the issues on patenting of indigenous

products; discusses noteworthy defensive endeavors such as resolution made by the government of

India and WTO suggestions in this regard. The aim of this review article is to advance theresponsiveness in respect of indigenous knowledge protection.

Keywords: Misappropriation, prior informed consent, access benefit sharing, biopiracy,

bioprospecting, bioequilibrium, alchemy
http://c/Users/AppData/Local/Desktop/[email protected]://c/Users/AppData/Local/Desktop/[email protected]://c/Users/AppData/Local/Desktop/[email protected]://c/Users/AppData/Local/Desktop/[email protected]

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current intellectual property (IP) protection

norms for an element of traditional knowledge

having inherent adaptation to cultural

characteristics and community goals is an

issue and necessitates a legal mechanism for

protection of traditional knowledge.

This paper discusses the concept of

formulations in siddha system and addresses

the issues regarding westernization of

indigenous medicine. Further, the allied scope

of research and the issues on patenting of the

natural products have been exemplified and

the endeavors being made for the protection of

indigenous medicine from misappropriation

are highlighted.

2. CONCEPT OF FORMULATIONS

The source of pharmaceutical preparations in

siddha system comprises herbs, metals,

minerals and living things. It includes a

complex system of medicine providing all

obligatory elements to the human body. As per

the key sorting in siddha texts, 32 varieties of

internal medicines and on account of modes of

application 32 varieties of external medicines

are being elucidated and practiced since years

[1].Lakhs of formulations are available in

siddha literature; though a few are

documented; countless others are still in the

form of scripts and palm leaves, classified in

nature.

Unlike other systems of medicine, which arepredominantly synthetic in nature, siddha

formulations are in natural form and contain in

unison the active principles, inactive fibers,

debris, etc.; they do not attempt to haul out the

active principles and are disinclined to the

concept of employing drugs as chemicals. This

adds an additional value to these drugs by way

of either neutralizing the toxic material, if any,

or facilitating the excretion of unwanted

chemicals by entrapping them with fibers,

debris, etc. The inorganic substances occurring

in nature have to be brought into atomic form

for their effective usage as medicines. The

siddhars developed the knowledge of

transforming inorganic substances into atomic

and ionic form via organized processes, which

can be easily absorbed in the system and result

in highly efficacious products.

The ideology behind the customized

formulations which is being practiced in

siddha is the circumvention of side

effects/after effects; administration of a

synthetic compound (a chemical)

indiscriminately results in further imbalance of

physical system, while the natural products

containing five elements in a balanced ratio

assist the physical system in a positive way.

Hence, the westernization of our indigenous

medicine may result in some of the grave

consequences like adverse drug reactions as

that of modern system of medicine.

3. SCOPE OF RESEARCH

As per the concept of Indian medicine, mindand body are interlinked, which is in conflict

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with the modern methodology as these

systems are holistic in approach. The

formulations and treatment methods in siddha

system are tailor made and should be modified

in accordance with the climate, habitat and

individual body conditions. The

phytochemical contents of the plants also

show discrepancy with the climatic condition,

soil. etc., and hence fluctuation in the

phytochemical ratio is also one of the reasons

for inconsistent efficacy of the drug and

reduction in success rate; the quality control of

the final product as well as individual

components is an exigent task of this system.

Research in this field is the obligation for

better understanding of mechanism of action

of drugs being used and chemical reactions

taking place during drug processing to

determine the chemical nature of the final

product as well as to ascertain the active

principles responsible for the particular action

of the drug and the molecules responsible for

toxicity reduction. It is worthwhile to

incorporate proper portfolio of retrospective

study in the pharmacological field of

indigenous medicine owing to grey areas in

the pharmacological aspect of research and

commercialization which includes

modification in route of administration,

modification in the form of drug (for

portability and palatability), enhancement of

shelf-life of the drug, etc.

Standardization of siddha formulations is alsomandatory in order to conquer the

secondary/toxic effects while drug

processing/large scale production. Even

though there are guidelines for GMP (good

manufacturing practices), suitable drug

consistency measures and phytochemical

analysis may be employed so as to obtain

viable and efficacious products. However,

there are improved technological interventions

for quality production, processing, packaging,

storage, transport, delivery and other related

parameters for commercialization of the

products; standardized commodities are

limited in the field.

There is no bar on researchers to take out a

patent on the substantially improved version of

indigenous knowledge or on development of

new drugs based on traditional medicine

principles. In that way, a few Indian patents

were also awarded and commercialized. In this

domain, the patent on reconstituted product of

curcumin (BioCurcumax) is granted on the

basis of relevant inventive step enhanced

bioavailability and efficacy; shortly, the

product was licensed and exported to the

United States and Japan.

4. PATENTING

The basic principle of patent system is to

create an incentive to innovation and grant of

limited monopoly to true and first inventor as

a reward for launch of new invention and

useful innovation which benefits the public. In

the context of patenting the products oftraditional knowledge, there is a strong

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objection imposed by Section 3(p) of Indian

Patents Act, 1970. However, the product or

process which comprises proper inventive

step, i.e., technical advancement as compared

to the existing knowledge such as

enhancement of efficacy, discovery of new

industrial application or the innovation having

economic significance is patentable as per

Indian Patents Act.

Despite inclusion of the IP regime and modern

commercialization techniques to these

traditional systems, securing patents for such

products is a complicated task; suitable legal

arrangements for the prevention of

misappropriation and protection of traditional

knowledge must be put in place. The main

aspiration is the creation of an incentive to

innovation in the field of traditional

knowledge; protection and conservation of

biodiversity and deed of commercial interest

out of our own biodiversity; and finally the

assurance of the countrys heritage in this

regard.

4.1. Challenges and Issues in Patenting

Whilst discussing the protection of traditional

medicine within the current IP norms, plenty

of challenges are being posed, as the

knowledge in this system evolves over a long

period of time, stretching over generations and

may not meet the criteria of novelty or

inventive step required for patenting.

Moreover, it is a collective or community

resource and this knowledge may be held bymultiple communities and it becomes difficult

to determine title holders, critical in accessing

the traditional knowledge via scientific

methods and assessments. Hence, IP-based

protections are limited in this field [2].

Above all, patenting of indigenous products

results in several issues like undesirable effect

on biodiversity and bioequilibrium. Patent

rights over the products of indigenous

community may even prevent the local

communities from accessing it. At that point,

local communities feel undermined and

exploited [3]. Principally,creation of IP rights

on knowledge acquired from biodiversity will

result in bioprospecting, which is the rigorous

process of depleting natural resources with no

guarantee of successful results.

Bioprospecting, however, is often just a handy

term used by researchers to obtain unlimited

access to valuable genetic resources at a

throwaway price [4]. Bioprospecting results in

depletion of biodiversity and has a great

impact on bioequilibrium of the environment

either directly or indirectly [3].

4.2. Issues on Commercialization

While attempting to commercialize a product

belonging to siddha system, the issues

regarding portability of the drug and shelf life

of the drug arises, as most of the herbal

medicines are in unsophisticated form, having

short shelf life and the addition of

preservatives for the purpose of marketing

results in the reduced efficacy of the drug.

Meanwhile, in the case of preparations likeBhasma, Chendoora,Karuppu,etc., there is no

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eccentricity of the natural products also

recedes and palatal pleasures often lead to

mental agony. Therefore, there is an immense

necessity for the prevention of

misappropriation and protection of our

traditional medicine.

4.4. Examples of Misappropriation

There are many instances of patenting of our

wellknown herbs turmeric, neem, hoodia,

pepper,bitter-gourd, brinjal, etc., in US Patent

and Trademark Office (USPTO) and European

Patent Office (EPO). There are a few sagas of

successful revocation of some of those patents;

the turmeric case was a landmark judgment

case which was successfully challenged by

CSIR and the USPTO revoked this patent in

1997. Litigation against these granted patents

results in loss of several billions of dollars. In

the face of that, any conservative measures

may be extended to prevent the monopoly

holders from enforcement of their rights in the

place of our own biodiversity.

Here is a short account of patents granted/filed

on wellknown siddha formulations, which are

not yet revoked or opposed/withdrawn by the

submission of prior-art evidence. The patents

cited on this prospect, for all intents and

purposes thrash out the patenting activity of

natural products per se or the minor

modifications thereof and the knowledge

associated therewith.

4.4.1.Aloe vera

Aloe vera is a wellknown herb of indigenous

system of medicine and has a wide range of

dermal and ophthalmic applications. While

describing the general characteristics of the

plants in siddha text, various modes of

application ofAloe vera pulp for skin diseases

have been mentioned. The exudates from the

gel of Aloeshave ophthalmologic application

for quite a few eye diseases and it is one of the

components of multiple ophthalmic

preparations in siddha [8].

The published works in India in this arena

include positive influence of Aloe veraon the

synthesis of glycosaminoglycans (GAGs) and

thereby beneficially modulate wound healing

[9].

A number of cosmetic preparations based on

Aloes are being patented and commercialized.

A US patent numbered 5487899, granted on

January 30, 1996, claimed the usage of Aloe

veramucilage preferably withAloepulp fibers

in the ratio of approximately 1:1 in a

bandaging mixture for its wound healing

property. Another US patent numbered

6013259 granted on January 11, 2000, claimed

an ophthalmic composition comprising Aloe

Vera gel, diluted in ophthalmological

acceptable carriers for the treatment of the dry

eye syndrome, inflammations, ulcerations,

alkaline or acid burns and infections in eyes.

In these cases, it is obvious that there is no

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4.4.4. Shi laj it

Asphaltum or shilajit is a wonder drug of

indigenous system of medicine having wide

range of therapeutic and nutraceutic

applications [14]. A US patent numbered

5405613,granted onApril 11, 1995, claimed a

composition comprising iron shilajit in a

multi-vitamin and/or mineral preparation in

which shilajit makes up between 0.4% and

10% by weight of the total composition and

the composition is in the form of a solid

formulation for oral administration.

4.4.5. Anti-diabetics

A US patent numbered 6,451,355 granted on

September 17, 2002, Claimed a composition

for treating Diabetes to be taken in oral doses

comprising an effective amount of a

pulverized seed Fenugreek and an effective

amount of bile from the gallbladder of a

Ruminant mammal.

History of use of fenugreek seeds for diabetes

can be traced out from 1550 BC onwards; the

report brought out by ICMR on 1988

elucidates the scientific validation of

fenugreek seeds for diabetes [15]. Animal

products like Gorosanam (ox bile),

Myrosanam (bile of sheep) are indicated for

diabetes and their usage in combination with

other ingredients as a potent anti-diabetic drug

is still in practice in siddha system [1]. The

above quoted patent is only aggregation of

known properties of traditionally known

components and should positively be opposed

on the basis of grounds in Section 3(e) of

Indian Patents Act, 1970.

A US patent numbered 5886029 claimed a

pharmaceutical composition with Pterocarpus

marsupium and Gymnema sylvestre as main

components and smaller quantities of

Cinnamomum tamala, Syzygium cumini,

Trigonella foenum graecum, Azardirachta

indica, Ficus racemosa, and Tinospora

cordifolia for the treatment of diabetes. All

these drugs are well known for hypoglycemic

effect and the claimed invention is only

aggregation of known properties of

traditionally branded components.

Another patent in this line is US 5900240,

granted on May 4, 1999, which claimed an

edible composition for use as a hypoglycemic

agent in mammals comprising 300600 mg of

a mixture of at least three herbs selected from

the group consisting of Syzygium cumini,

Gymnema sylvestre, Momordica charantiaand

Solanum melongena, each of the foregoing

herbs being present in approximately equal

amounts. All these granted patents, which are

publicly known components, aggregation of

known properties can be revoked and the

monopoly rights may be terminated.

Meanwhile, it is extremely difficult and costly

for developing countries to monitor and

challenge IPRs issued all around the world.

4.5. Bio-piracy and Need for Protection

The above quoted patents are a few relevantexamples of bio-piracy appropriation of

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indigenous communities knowledge on bio-

resources by unauthorized users, where no

credit was prearranged to the rightful owners

of the knowledge, as they are sourced mainly

from India; and the enforcement of these

patents can prevent the commercial

exploitation of these indigenous products by

Indians.

Some of the indigenous herbs are being

dynamically exploited for the manufacture of

modern drugs and commercialized by foreign

companies. Examples of these kinds are

Atropa belladona for atropine, Rouwolfia

serpentina for reserpine, Ephedra gerardiana

for ephedrene, Claviceps purpurea for

ergotrene, Cinchona officinalis for quinine,

Digitalis purpurea for digoxin, Pappaver

somniferum for morphine, Catharanthus

roseus for vincristine, Erythroxylon coca for

cocaine [7]. These plants are plagiarized,

commercially abused, exploited to the full

extent and at present they are about to become

extinct.

In reality, busy selling of the green gold of

India for peanuts is on the arena. The debates

about benefit sharing will go on and on, and

the corporations and research institutes will

continue to exploit local communities for their

traditional knowledge [4]. The corporate world

and pharma business outfits trade in the bio-

resources and knowledge associated with

Indian traditional practice, become pioneer in

the manufacture of multiple commerciallyviable products and retail them at a lofty value

even to Indians. The net result is that multi

national companies have become affluent with

the use of Indian traditional knowledge and

bio-resource and India is trailing several

billions, biodiversity and facing adverse

effects in terms of health and environment.

We could have prevented the depletion of

biodiversity and thereby adverse effect on the

environment like global warming, if we had

enacted a proper legislation for protection of

traditional knowledge and conservation of

biodiversity. At present, with respect to

conservation of biodiversity, National

Biodiversity Authority (NBA) can thwart

foreigners from commercial utilization of

biological resources, wherein the Biological

Diversity Act, 2002, does not encompass the

shield for misappropriation of knowledge

associated thereto and hence stealing of

traditional knowledge is still rampant and

ubiquitous.Simultaneously, there is a colossal

necessity to prevent further misappropriation

by enacting proper legislation for protection of

this indigenous knowledge. The urge for

protection results in multiple painstakingness

at the national and international levels though

they are yet completely successful.

4.6. Highlights on the Horizon

Protection of traditional knowledge is

currently a topic of international debate, and

discussions have been taking place in various

inter-governmental bodies like CBD, WIPO,

FAO, WTO and UNCTAD [16]. On this front,in the WTO forum on TRIPs, five modes of

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traditional knowledge protection have been

advocated: (1) use of existing IP laws to

protect traditional knowledge through

facilitating changes on it; (2) appropriate

benefit-sharing arrangements (includes PIC

and disclosure of utilization of traditional

knowledge); (3) institution of sui generis

system for protection of traditional knowledge;

(4) use of contract laws based on bilateral

agreements on a case-to-case method; and (5)

use of environmental legislations such as

biodiversity legislations for building

provisions for traditional knowledge

protection. The first one clearly involves a

defensive approach to traditional knowledge

protection while the others are carry elements

of proactive protection that entail benefit

sharing [2].

Measures to prevent grant of IP rights to non-

customary holders includes defensive

endeavor made by the central government in

this regard the development of database on

traditional knowledge called traditional

knowledge digital library (TKDL). After

losing several patents on medicinal plants to

the West because of governments reluctance

to share traditional knowledge, India has

decided to allow international patent offices to

access its TKDL for examining patent claims

[17]. India has already entered into TKDL

access agreement with leading patent offices

such as EPO, USPTO, UKPTO in 2009-2010,

and afterwards with Canada (CIPO), Germany

(DPMA), Australia (IP Australia), Japan (JPO)and so on, in order to reveal the codified

traditional knowledge with the obligation to

consider the data as prior artwhile carrying

out search and examination of filed patents.

Prior art is meant to encompass everything that

has been published, presented or otherwise

disclosed to the public on or before the date of

patent application. Consequently, maintenance

of confidentiality in traditional knowledge is

an unsettled issue.

The concept of TKDL includes transcription

of verse and prose which describes the

formulations in Ayurveda and siddha

manuscripts and data relating to postures in

Yoga and is being extended to enable

codification of community-owned traditional

knowledge also. Now the part of traditional

knowledge is in well-structured and codified

form and wires the opposition of unethical

patent claims in order to safeguard the

indigenous knowledge. On the other hand,

codification of traditional knowledge into

digital libraries is not a complete solution to

misappropriation [6]. On this prospect, the

government of Kerala released a sui generis

legislation for protection of traditional

knowledge on 27th June 2008, called as

Kerala IPR policy that endeavors rights

creation on traditional knowledge. But there

was also some debate about the constitutional

validity of the legislation.

At the national level, though there have been

efforts, such as amendment of Patents Act in

1999, highlighting few restrictions onapplication for intellectual property rights

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based on biological resources and associated

traditional knowledge, Biodiversity Bill, 2000,

emphasizing access to benefit sharing, concept

of prior informed consent, policies on

protection of traditional knowledge, systems

of contract, recognition of customary laws,

which are basically concerned with the

intention of protection of traditional

knowledge, they are yet to be completely

successful.

There are international agreements also which

aim at sharing the benefits arising from the

utilization of genetic resources in a fair and

equitable way, adopted by the Convention on

Biological Diversity in the tenth conference of

the parties of CBD inNagoya, Japan, and the

enforcement is on probe.

It is also true that exclusions from

patentability of traditional knowledge-based

products in one country, for instance, would

not exclude others from granting it a patent

[16]. It was notified in the Expert Meeting

Recommendations at the Multilateral Level

held in UNCTAD (United Nations Conference

on Trade and Development) from 30th

October to 1st November, 2000. Therefore,

any national-level mechanisms and legal

provisions to prevent biopiracy require

international recognition for their effective

implementation and enforcement in other

countries.

5. CONCLUSIONS

Patenting the products of traditional

knowledge is a topic of international debate

and hence a comprehensive sui generis

legislation for the protection of traditional

knowledge which includes conservation of

biodiversity and compensation to the

community concerned is the need of the day.

The existing IP systems of protection and

databases on traditional medicine may act as

excellent defensive measures, but they do not

confer any positive benefit to the community

concerned. On the other hand, a proactive

policy of protecting traditional knowledge can

ensure accrual of benefits to the local

communities. If anyone is really serious about

the protection of traditional knowledge, it

needs to have an open mind to look at the

issue from the perspective of local and

indigenous communities and the appropriate

credit should be given to the community

concerned. Moreover, we should encourage

the conservation and sustainable use of

biodiversity and also enable the communities

to continue using traditional knowledge for

their livelihood in the context of traditional life

style.

In due course, the improvements made on

indigenous medicinal formulations in order to

meet the criteria of patentability may result in

serious consequences to the community with

reference to healthcare.

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Hence, westernization of our indigenous

medicines should be prohibited but its

potential to prove its worth through scientific

tests of verifiability and reproducibility should

be encouraged.

REFERENCES

1. R. Thiagarajan. Indian Medicine andHomeopathy. Vol. 2 and 3. 4363p,

516517p.

2. A. Damodaran. Journal of IntellectualProperty Rights. 13(5). 2008. 509513p.

3. Srividhya Ragavan.Journal of IntellectualProperty Rights. 13(5). 2008. 514522p.

4. Devinder Sharma. In Beth Burrows (Ed.).The Catch: Perspectives in Benefit

Sharing. The Edmonds Institute,

Edmonds, Washington, 98020, USA.

2005.

5. Shahid Alikhan and RaghunathMashelkar. Intellectual Property and

Competitive Strategies in 21st Century.

Netherlands. Kluwer Law International.

2004. 6987p.

6. R. S. Praveen Raj. IPR Policy RightsCreation on Traditional Knowledge.

WIPO Magazine. Issue (4). 2008. 24p.

7. Surender Singh Chauhan. Biodiversity,Biopiracy and Biopolitics: The Global

Perspective. New Delhi. Kalinga

Publications. 2001. Original from the

University of Michigan. Digitized: 3 Aug

2009, 133149p.

8. K. S. Murugesha Mudhaliar., GunapadamMooligai Vaguppu, Volume 1, Indian

Medicine and Homeopathy. Vol. 1., 271.,

788789 p.

9. P. Chithra, G. B. Sajithlal and GowriChandrakasan., Central Leather Research

Institute, Madras., 27 September, 1997.,

Available online 4 March, 1999.

10.Health-Tribune News Service. LudhianaTribune online edition. April 3, 2001.

http://www.tribuneindia.com/2001/200104

03/ldh3.htm#2

11.K. N. Kuppusamy Mudhaliar and K. S.Utthamarayan. Indian Medicine and

Homeopathy. 255256p.

12.Hanumanthachar Joshi and Milind Parle.Evid Based Complement Alternate

Medicine. March, 2006. 3(1). 7985p.

Published online January 16, 2006. doi:

10.1093/ecam/nek014.

13.R. Thiagarajan. Thaeraiyar YamahaVenpa. Vol. 2&3. 3443, 136144p.

14.Nadkarni. Indian Materia Medica. Chap.13. Asphaltum. 2332p.

15.U. V. Enterprise. Health-related webpages. www.uvtherm.com/diabetes.html.

http://news.google.com/archivesearch?q=f

enugreek+%2Bdiabetes&scoring=t&sa=N

&sugg=d&as_ldate=1988&as_hdate=1988

&lnav=dt

16.Protecting Traditional Knowledge. TheInternational Dimension, International

Seminar on Systems of Protection of
http://www.uvtherm.com/diabetes.htmlhttp://www.uvtherm.com/diabetes.html

8/12/2019 56-365-2-PB (2)

13/13



___________________________________________________________________________


Traditional Knowledge. Department of

Commerce, Government of India in

Cooperation with UNCTAD, 35 April,

2002. New Delhi. Background 2, 6p

17.Non-Wood News 13. News and Notes.Times of India. 30 June, 2006.

http://www.fao.org/docrep/009/a0917e/A0

917e02.htm

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