A secure structural framework with well-defined categories is the need of the hour for CSR to make any sustainable impact
This paper is part of a series ‘This is not CSR’ to discuss the purview of corporate social responsibility in India. DTE brings you the series along with ‘Partners in Change’ and 'Corporate Responsibility Watch'.
The introduction of the Corporate Social Responsibility (CSR) law in 2013, created a pool of resources for civil society organisations to execute social impact projects. However, an analysis of data for the seven years made by experts has shown that desired outcomes are yet to be achieved.
While quantitative data is limited, there is subset of activities done under CSR, which either skirt the rules or do not purport to the spirit of the law. A qualitative analysis of CSR projects exhibits the tendency of companies to treat CSR funds an expense account for marketing and lobbying.
This paper argues that this tendency is not simply subjected to corporate decision-making but emerge due to deep structural issues in the regulatory framework itself. This combined with the government’s proclivity to change the rules with arbitrary and / or short objective has created a situation where it is difficult to identify the ‘spirit’ of CSR law. This creates an environment which encourages legalistic creativity but stifles innovation in line the spirit.
On August 29, 2013, the Indian government introduced a new Companies Act. In this new Act, a noteworthy amendment had been the compulsory law of CSR. Section 135 (1) of the Act illustrated the following:
Every company having net worth of rupees five hundred crore or more, or turnover of rupees one thousand crore or more or a net profit of rupees five crore or more during any financial year shall ... spends, in every financial year, at least two per cent of the average net profits of the company made during the three immediately preceding financial years, in pursuance of its Corporate Social Responsibility Policy
- Ministry of Corporate Affairs, 2013, p. 87
Alongside, Schedule VII of the Act listed down all the possible areas eligible for CSR spending. Over the course of 7 years, CSR laws of the Companies Act, 2013 have undergone frequent amendments with the most recent ones being made on 24th August 2020 (Jayaswal, 2020).
However, despite all the measures taken by the Union Ministry of Corporate Affairs (MCA) to make companies conduct their business responsibly, the impact of mandatory CSR is yet to achieve sustainable development in the country.
As PushpaSundar (2018) opines, CSR projects are rife with fundamental issues off or going “imaginative, risky but potentially big payoff ideas” and, most importantly, approach taken by companies to shrug off social responsibility by simply putting in money — or as Sundar calls it “guilt money”.
In this paper by highlighting various problematic CSR projects, especially by public sector units (PSU), and conducting the review of changing legal framework we argue that, the issue of spirit of CSR is not limited to the boardrooms of companies.
There are structural issues namely lack of clarity in the Act (along with the multiple FAQs and clarifications issued) and loosely defined categories of Schedule VII of the Act, which are the main cause of poor selection and implementation of CSR projects.
This leads to both creativity in misapplication of CSR funds and stifling of innovation which are “imaginative, risky but potentially big payoff ideas” (Sundar, 2018).
One of the challenges in studying the impact of CSR law in India is the lack of information regarding CSR activities of private companies. Although private companies reveal data to MCA, which is showcased at the National CSR Portal, data for numerous companies is either non-existent or contradictory.
Moreover, CSR implementation agencies are often bound by non-disclosure agreements with companies. Furthermore, from the T-Social Impact Group (T-SIG) experience, multinational private companies have shied away from nominating themselves for CSR Awards conducted by the MCA to avoid the basic question ‘What is the company’s annual CSR budget?’
At the other end of the spectrum, data of PSUs is easily available due to routine audits conducted.
T-SIG, the official CSR cell of Telangana, has been initiated by Department of Industries & IT, Government of Telangana. Surge Impact Foundation, a Section 8 non-profit acts as the project management unit (PMU) to the department to manage this platform. The objective of the platform is to make CSR interventions across the State effective and sustainable by connecting all relevant stakeholders and creating synergies.
Data represented here is a mix of experiential narratives from T-SIG, publicly available data and review of the CSR laws and rule.
Mandatory CSR has led to growth of private CSR consultants guiding the companies. According to the New Indian Express daily, to avail CSR funds of Rs 33 lakhs for a CSR project, Karnataka Welfare Association for the Blind from Bengaluru, paid close to Rs 14 lakh to a social activist as ‘consultation fees’ to avail the larger fund reservoir from a Dubai-based company, Etisalat Software Solutions Pvt Ltd (Yathiraju, 2018).
Although such cases question the spirit associated with CSR, there are also CSR projects that can be characterised by poor selection of project areas.
Bharat Heavy Electricals Limited:
On December 1, 2019, Bharat Heavy Electricals Ltd inaugurated a toy train at the Nehru Zoological Park in Hyderabad as part of the 55th Zoo Day celebrations. In their monthly newsletter (November 2019), BHEL mentioned that the repairing work for the toy train “was completed with CSR Funds” (Pepnews, 2019, p. 6).
According to the New Indian Express, BHEL utilised Rs 4 lakh to complete this renovation work (Express News Service, 2019). This CSR project comes as a baffling decision because this step is not outlined in any of the categories under Schedule VII of the Companies Act, 2013 and cannot even be classified as a heritage site.
Court Order Restitution:
One interesting example from T-SIG experience has been the request to facilitate court mandated restitution. A while ago, a certain trade association had been ordered by a court to restore lakes which had been polluted through activities of its members in Telangana.
To seek guidance from a government CSR platform, T-SIG had been approached by the association, requesting to facilitate the restoration project in a manner that the concerned money spent would be accounted as CSR expenditure for the member companies.
This is in clear violation of letter and spirit as court orders have effect of law and the MCA Circular of 2014 clearly states: “Expenses incurred by companies for the fulfilment of any Act / Statute...would not count as CSR.” (page 2).
REC Ltd, a Navratna CPSE, partnered with Population Foundation of India (PFI), a research organization to sponsor the third season of an ‘edutainment show’ Main Kuch Bhi Kar Sakti Hoon in 2018-19.
The Memorandum of Agreement was signed off at Rs 10 crore with funds being spent as part of CSR expenditure (Rec Ltd, 2018). However, the MCA Circular of June 18, 2014 clearly mentions “One-off events such as… sponsorships of TV programmes etc would not be qualified as part of CSR expenditure”. Moreover, the exact impact of this CSR project is under-researched and hence shrouded in doubt.
Statue of Unity project:
The project of Statue of Unity, one of the first campaigns of Prime Minister Narendra Modi, cost Rs 2,989 crore. According to a 2018 report by the Comptroller and Auditor General of India (CAG), in the 2016-17, the project saw a shortfall of Rs 780 crore. Five PSUs “contributed a total of Rs 146.83 crore (ONGC Rs 50 crore, IOCL Rs 21.83 crore, BPCL, HPCL, OIL Rs 5 crore each)” (page 75).
All the PSUs rationalised the decision of funding the project under protection of national heritage of Schedule VII. However, as the report clearly mentions, “[c]ontribution towards this project did not qualify as CSR activity as per schedule VII of the Companies Act 2013 as it was not a heritage asset” (page 75).
When the CAG asked for a clarification regarding such CSR expenditure, BPCL, IOCL and HPCL reverted that the companies relied on the ‘liberal interpretation’ of the broad categories of Schedule VII.
In the same report, CAG (2018) also points out welfare activities of “removal of plastic waste in and around Steel Township ...and Maintenance of BSL school buildings” of SAIL ineligible for CSR as these “were beneficial only to the employees of the Company and their families.”
The above CSR illustrate how companies liberally translate the CSR law and execute projects. As explained in the next section of the article, such CSR projects can be subjected to the lack of clarity accentuated by the multiple versions and clarifications of the Act itself.
One of the significant issues with the CSR provision is that constant changes are made to its provision through primary and secondary (delegated) legislation, ie changes in law and rules governing the law and by administrative acts like issuing clarifications. Since 2013, there have been 10 amendments to rules governing CSR activities in Schedule VII – an average of 1.25 per year.
In addition to these amendments, one needs to factor in the multiple Clarifications and FAQs issued on various points; some of these in effect change the application of the law, if not amending the law itself.
The MCA general circular No.21/2014 (June 18, 2014), for example says: “...entries in the said Schedule VII must be interpreted liberally so as to capture the essence of the subjects enumerated in the said Schedule.”
This circular illustrates this point by including under “promoting education” issues related to Road safety awareness, Safety traffic engineering and Consumer protection. But promotion of education is rarely interpreted in this manner.
Another example is the inclusion of the PM Cares Fund, originally also done by Clarification dated 28th March, 2020 and subsequently reinforced by retrospective amendment to Schedule VII dated 26th May, 2020 (MCA, 2020).
Taken together, these rules and clarifications have in effect amended the law passed by Parliament substantially. Moreover, the changes are reactive, ad-hoc, arbitrary and do not consider any specific direction or underlying philosophies. While some of these changes reflect poor drafting; others reflect momentary political or policy priority of the government. No attempt seems to have been made to give a stable, easy to interpret regulatory regime for CSR.
Disaster relief, an important issue, was not even part of the rules till 2019,although it was read into the rules in a Circular dated 18th June, 2014 by breaking down disaster relief into elements like ‘medical aid’ under healthcare, ‘food supply’ under eradicating hunger, poverty and malnutrition.
Even after adding “disaster management, including relief, rehabilitation and reconstruction activities” in May 2019 (Ministry of Corporate Affairs, 2019), during COVID-19 crisis, government issued two clarifications in March 2020 and April 2020 affirming the inclusion of COVID relief under CSR and outlining related CSR activities (Ministry of Corporate Affairs, 2020). This was done to foreground validity of contributions to PM Care and PM Relief Funds instead of contributions to CM Relief Funds.
This highlights how arbitrarily political priority trumps common sense. Specific mention of central funds like Swachh Bharat Kosh, Clean Ganga Fund, etc. in amended Schedule VII reinforces this interpretation (Ministry of Corporate Affairs, 2014).
The original Schedule VII (Appendix I) ranged from broad categories like ensuring environmental sustainability (point VI) to specific ones like immunodeficiency in healthcare (point V). Let us delve into this issue further with the help of two categories — Healthcare and Entrepreneurship (Appendix II).
In healthcare, it begins with broad coverage while making mention of specific disease but subsequent amendments [including corrigenda] changed the focus to ‘promoting health care including preventive health care’ which is at once broad but restrictive category and needs to rely on ‘liberal interpretation’ to provide services like palliative care (MCA, 2014).
In the case of entrepreneurship, from a broad category of social business projects (social enterprises?), it shifts to Centre / PSU approved ‘technology incubators’ in academic institutions’ and later to Centre / State / PSU-funded incubators and contributions to public funded Universities’, with a long list of specific agencies. This was again changed in August 2020 to add “research and development projects in the field of science, technology, engineering and medicine” (Ministry of Corporate Affairs, 2019).
These changes are highly restrictive and potentially prevent innovative schemes like Social Impact Investing through CSR.
Returning to our theme of ‘spirit of CSR’, the question that arises is: In a situation where laws and regulation are constantly changing; are simultaneously vague and restrictive; along with being driven by arbitrary political choices, is it possible to know what is the spirit of the CSR law? Is it even possible to know where the letter of CSR law stands and what is the ordinary meaning of the text?
As seen with above examples, this leads to legalistic / technical creativity but potentially chokes innovation more in line with the ‘spirit of CSR’. The question hence remains: what is the true ‘spirit of CSR’? This dichotomy is intensified in situations where CSR law is linked to other Acts, as exemplified below.
In T-SIG’s work, we frequently encounter corporates requesting clarification on what is permissible and possible under CSR. One such request regarding CSR activity under the Apprenticeship Act sheds light on both the confusion on application of CSR law and its complex interactions and contraindications with other laws.
Our initial instinct regarding the query was against it, as CSR law follows the adage of ‘This Offer cannot be combined with any other’. However, a thorough examination of the complex rules indicated our advice both right and off the mark.
The Apprenticeship Act, a relic of the Socialist era, designates three classes of companies – 1) for whom it is obligatory (designated trades); 2) for whom it is an optional (optional trades) and 3) for whom it is prohibited (Ministry of Human Resource Development — MHRD, 1961).
It further mandates that each designated establishment engage apprentices from 2.5-10 per cent (and up to 15 per cent) in one month of the total workforce, including contractual staff and creates a byzantine framework for the same (MHRD, 1992).
Despite its mandatory nature, to the best of our knowledge, CSR compliance with this Act is low. As a recent FICCI report (2019) states:
“Apprenticeships in India had remained stagnant between 2000-2014 due to various old provisions in the Apprenticeship Act 1961 and stood at just 0.28 million in 2014. Operationally, a compliance-heavy process and lack of adequate infrastructure have kept industries away from participating actively in engaging apprentices...it hasn’t achieved the desired results.”
Yet, the government periodically seeks to revive this Act as a mechanism for skilling and employment. Latest attempts have been the amendment made in 2014 to the Apprenticeship Act and National Apprenticeship Promotion Scheme launched on 19th August 2016 (MHRD, 2016).
As stated earlier, the fluid legal nature of CSR rules creates both confusion and opportunity for creative interpretation. This doubt about the implication of the Apprenticeship Act was not limited to corporates who reached out to us. The 2014 MCA circular stated: “Any expenses incurred by companies for the fulfilment of any Act/ Statute of regulations (such as Labour Laws, Land Acquisition Act etc.) would not count as CSR expenditure under theCompanies Act”.
Clearly, there existed confusion and / or request for leniency in relation to the Apprenticeship Act, as MCA issued further clarification, dated 12 February 2016, directly to PMO on request by the Sub-Group of Chief Ministers on Skill Development in December 2015 to examine the option of allowing large industrial clusters to use CSR funds for skill training.
The clarification reiterated that Companies obligated to undertake Apprenticeship training “can also undertake skill training from their CSR funds over and above the requirement under the Apprentices Act. The companies which do not fall under the Apprentices Act can undertake skill training under provisions of Corporate Social Responsibility Act.” (MCA, 2016, page 1) The Same point was again repeated by June 15, 2016 by the Council for Leather Exports.
Yet, the matter was not settled. As mentioned earlier, Category 1 companies clearly cannot use CSR funds directly for Apprenticeship training due to the upper limit on the number of apprentices that can be engaged and category 3 companies are too small to fall under the CSR law since this category contains companies with equal to or less than 3 employees.
A new clarification, issued by the Union Ministry of Skill Development on March 11, 2020, takes 2.5 per cent as obligatory under Apprenticeship Act for designated trades. Funds spent between 2.5 per cent to 15 per cent by designated trades and the entire fund spent by optional traders under the Apprenticeship Act can be counted as CSR spending. As companies falling under class three cannot legally engage apprentices, the amount spent by these companies on such activities is not accounted under CSR expenditure. This is clearly a liberal interpretation of a complex legal scenario.
The Intersectionality approach, a widely accepted paradigm in the development sector, will also be beneficial for the government when it comes to the CSR law. For the apprenticeship matter which was referred to PMO in 2016 in reference to the Sub-Group of Chief Ministers, full clarification only came in March 2020.
This hints at a lack of clarity surrounding the implication of the CSR law and its rules and interactions with other acts on the statue within the government itself. This is coupled with the fact that clarifications issued by the government have limited value and do not have a statutory or binding nature.
Bharat Vasani and Drishti Das(2019) highlight that this point has been made by Supreme Court in a series of judicial decisions, including in Bengal Iron Corporation v. Commercial Tax Officer, where it says, “So far as clarifications/circulars issued by the [Government] are concerned, they represent merely their understanding of the statutory provisions. They are not binding upon the Courts” (Vasani& Das, 2019). They further point out that, “the SC has consistently held that such clarificatory circulars cannot amend or substitute statutory rules itself” (ibid).
Altogether, these reciprocations create more confusion and have a constraining effect on any innovative approach. A conservative approach is deemed safer and creativity is deployed only if one seeks to treat CSR as a marketing budget. This also explains the reason why companies tend to incline towards traditional projects by forgoing “imaginative, risky but potentially big payoff ideas” (Sundar, 2018).
The above discussion clearly shows that for CSR law to be implemented in spirit, concrete actions are needed to clarify the legal framework of the law. As the PMU for a state’s official CSR platform, some of our recommendations are as follows:
A clear theoretical framework for CSR law must be established; not one that can be changed in an arbitrary bureaucratic manner based on political or policy immediacy. Furthermore, Schedule VII must set well-defined broad categories and not micro fields subjected to multiple amendments. To achieve this, fixed interpretations by the judiciary are also needed.
While setting broad categories for Schedule VII, aligning them with the framework of Sustainable Development Goals (SDGs) will be highly beneficial. Such a step will assist in companies monitoring and reporting their CSR projects with the help of SDG indicators and aid the nation’s progress in achieving these goals.
Instead of issuing several clarifications on a single topic, the government must deal with complexity and fluidity of legal framework by settling interaction of CSR with other laws like Apprenticeship Act, Income Tax Act in clear format.
The government must introduce the point of liberal interpretation in the rules or law itself but lay down the counters of this liberal interpretation.
CSR funds must be treated as national corpus for social action and development and not as contingency funds that can be utilised during a budget shortfall for government campaigns. This also includes not treating the CSR funds as only available at a national level.
The upheaval created during the novel coronavirus disease (COVID-19) crisis left the companies bewildered as to whether funds transferred to CM Relief Funds accounts for CSR expenditure. The entire focus of PM Cares Fund, specially created for the pandemic situation urged all companies to provide funds at a central level. The role of the government, hence, should be emphasized as trustee of funds and not beneficiaries.
A robust and sustainable public private partnership (PPP) model can be one of the best strategies to monitor CSR activities of a state. Although there should be fundamental changes made to the model as also suggested by the Kelkar Committee, a PPP model like T-SIG should be adopted by other states as well.
This model can guide corporates to spend CSR funds into areas aligning with the priority sectors of the government, assist corporates in interpreting the laws and additionally monitor and report CSR projects. Such an initiative, managed by the skills and knowledge of experienced development professionals, will also help in diverting funds to under-developed districts such as aspirational districts as mandated by NITI Aayog.
Corporates also must treat their CSR funds as a pool beneficial for community-based organisations to execute their social responsibility instead of simply hiring private CSR consultants to research, select organisations and monitor CSR projects on the company’s behalf. As a mandate, companies should employ development professionals to align business objectives with social responsibility, choose projects with high impact potential and report CSR projects according to SDGs.
The Report of the High Level Committee on Corporate Social Responsibility outlines the main thrust and spirit of the CSR law as “not to monitor but to generate conducive environment for enabling the corporates to conduct themselves in a socially, responsible manner, while contributing towards human development goals of the country” (MCA, 2019, page 97).
However, through this paper, it can be concluded that a secure structural framework with well-defined categories is the need of the hour for CSR to contribute sustainable impact.
Council for Leather Exports. (2016, June 15). Corporate Social Responsibility (CSR) – Enlisting of Skill Training under CSR in Companies Act, 2013. No. CLE-HO/POL/CIRCULAR/15-16. Retrieved from https://leatherindia.org/enlisting-of-skill-training-under-csr-in-companies-act-2013/
Express News Service. (2019, December 2). Revamped toy train launched in Hyderabad zoo. The New Indian Express. Retrieved from https://www.newindianexpress.com/cities/hyderabad/2019/dec/02/revamped-toy-train-launched-in-hyderabad-zoo-2070090.html
FICCI. 2019. Implementation of Apprenticeship in India: A Study by FICCI. Retrieved from http://ficci.in/spdocument/23143/Implementation-of-Apprenticeship-in-India.pdf
Indian Audit and Accounts Department. 2018. Report of the Comptroller and Auditor General of India for the year ended 31 March 2017. Report No. 8 of 2018. Union Government (Commercial)
Jayaswal, R. (2020, August 25). Companies now allowed to spend CSR funds in finding drugs, vaccines for Covid-19. Hindustan Times. Retrieved from https://www.hindustantimes.com/india-news/companies-now-allowed-to-spend-csr-funds-in-finding-drugs-vaccines-for-covid-19/story-V8BhbSlY9lgKapsN5jQQxK.html
Ministry of Corporate Affairs. 2013. The Companies Act, 2013. Government of India.
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Ministry of Corporate Affairs. (2019, August). Report of the High Level Committee on Corporate Social Responsibility 2018. Government of India. Retrieved from https://www.mca.gov.in/Ministry/pdf/CSRHLC_13092019.pdf
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Ministry of Corporate Affairs. (2020, March 28). Clarification on contribution to PM CARES Fund as eligible CSR activity under item no. (viii) of the Schedule VII of Companies Act, 2013.eF. No. CSR-05/1/2020-CSR-MCA.Government of India.
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Sundar, P. (2018, August 21). Five Years After CSR Became Mandatory, What Has It Really Achieved?The Wire. Retrieved from https://thewire.in/business/five-years-after-csr-became-mandatory-what-has-it-really-achieved
Pepnews (2019 November). Trial run along with Zoo park officials and glimpses of upgradation works. Retrieved fromhttps://hpep.bhel.com/cpr/15118.pdf
REC Limited. (2018, September 13). REC to Sponsor Season 3 of ‘Main KuchBhiKar Sakti Hoon’ [Press Release]. Retrieved from https://www.recindia.nic.in/rec-to-sponsor-season-3-of-main-kuchbhikarsaktihoon
Vasani& Das. (2019, June 10).India: Ministry Of Corporate Affairs Circulars – Are They Legally Enforceable?Mondaq: Connecting Knowledge & People. Retrieved from https://www.mondaq.com/india/corporate-and-company-law/813344/ministry-of-corporate-affairs-circulars-are-they-legally-enforceable#:~:text=%22So%20far%20as%20clarifications%2Fcirculars,understanding%20of%20the%20statutory%20provisions.&text=But%20if%20the%20Act%20or,the%20Rules%20by%20issuing%20instructions.
Yathiraju. (2018). 45 per cent of CSR funding paid to activist as ‘consultation fee’ to avail funds. The New Indian Express. Retrieved from https://www.newindianexpress.com/states/karnataka/2018/jul/15/45-per-cent-of-csr-funding-paid-to-activist-as-consultation-fee-to-avail-funds-1843525.html#:~:text=BENGALURU%3A%20In%20a%20classic%20case,by%20city%2Dbased%20advocate%20N%20P
Original Schedule VII of Companies Act, 2013
(i) eradicating extreme hunger and poverty;
(ii) promotion of education;
(iii) promoting gender equality and empowering women;
(iv) reducing child mortality and improving maternal health;
(v) combating human immunodeficiency virus, acquired immune deficiency syndrome, malaria and other diseases;
(vi) ensuring environmental sustainability;
(vii) employment enhancing vocational skills;
(viii) social business projects;
(ix) contribution to the Prime Minister's National Relief Fund or any other fund set up by the Central Government or the State Governments for socio-economic development and relief and funds for the welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women; and
(x) such other matters as may be prescribed.
Timeline of Changes in Schedule VII related to Healthcare and Entrepreneurship
|As in act passed by parliament
|(v) combating human immunodeficiency virus, acquired immune deficiency syndrome, malaria and other diseases;
|(viii) social business projects;
|27th February, 2014
|(i) eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation andmaking available safe drinking water:
|(ix) contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government
|31st March, 2014
|‘‘promoting preventive health care’’ read ‘‘promoting health careincluding preventive health care’’.
|11th October, 2019
|(ix) Contribution to incubators funded by Central Government or State Government or any agency or Public Sector Undertaking of Central Government or State Government, and contributions to public funded Universities, Indian Institute of Technology (IITs), National Laboratories and Autonomous Bodies (established under the auspices of Indian Council of Agricultural Research (ICAR), Indian Council of Medical Research (ICMR), Council of Scientific and Industrial Research (CSIR), Department of Atomic Energy (DAE), Defence Research and Development Organisation (DRDO), 7[Department of Biotechnology (DBT)], Department of Science and Technology (DST), Ministry of Electronics and Information Technology) engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).
|24th August 2020
|(ix) (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and
(b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defence Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs)
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