May 16, 2023

MOST URGENT & MOST SERIOUS

Subject: 1. To follow the law of ‘Informed Consent’ and to fix

the liability upon Government Authorities, school
Authorities, Principal etc. who are violating the law and
forcing the children to take MR vaccines and thereby
puttingtheir life in danger.

2. To follow the precedent set by the Hon’ble High

Court in the case of Master Haridan Kumar Vs.
UOI 2019 SCC OnLine Del 11929 by not vaccinating
those students whose parents have refused to give
consent for vaccination and displaying quarter page
advertisements indicating the contents and adverse
events of the MR vaccines in all newspapers.

Reference:

(i) Hon’ble Supreme Court Order in the case of Jacob

Puliyel Vs. Union of India 2022 SCC Online SC 533,
Decided on 2nd May, 2022.

(ii) Hon’ble Supreme Court Judgment Common Cause

Vs. Union of India (2018) 5 SCC 1.
(iii) Registrar General, High Court of Meghalaya
Vs. State of Meghalaya 2021 SCC OnLine Megh
130.

(iv) Re Dinthar Incident Vs. State of Mizoram 2021

SCC OnLine Gau 1313.

(v) Master Haridan Kumar Vs. UOI 2019 SCC

OnLine Del 11929.

(v) Section 52, 304-A, 115, 120(B), 34, 109, etc. of

Indian Penal Code.
Dear Sir/Madam,

1. That, In the context of present on-going vaccination drive against

Human Papillomavirus (HPV), we appeal to you to ensure the law
of informed consent and the right to choice of parents which is
needed as per law for any medical intervention. Weighing the pros
and cons of the HPV vaccines the parents should have free choice to
either to vaccinate or refuse vaccinations for their children.

2. That few authorities are treating government circulars and

promotions as mandates and forcing parents to vaccinate their
children in order in order avail education.

3. It is an incorrect and completely wrong assumption. In fact, the HPV

vaccine is completely voluntary and in no manner can be made
compulsory either directly or indirectly.

3.1. Children cannot be given vaccines or any treatment without written

consent of their parents. Explaining Informed consent in the RTI
reply dated 05.08.2021 to Shri Sitaram Kumar, AIIMS Bhubaneswar
has replied as under:

“Question: What is informed consent for vaccines ?

Answer: A Consent Form is a document, in which the

beneficiary needs to read, understand and sign before taking
the vaccine.

This Consent Form has information such as:

Name and Type of Vaccine, Manufacturer

Route and Site of Administration, Doser

 Risk and Benefits of Vaccination

Side effects if any and whom to contact and what to do in case

of any side effect

Any additional source information related to the vaccine, etc.

Thus, after reading it (Consent Form) and understanding, a

beneficiary needs to sign the document and thereafter should
get the vaccine. The beneficiary may or may not sign the
informed consent form”

Link:https://drive.google.com/file/d/1fKQWK6biFEPQW3
TE1cveMp476eZnVMnu/view?usp=sharing

3.2. Human papillomavirus (HPV) is a sexually transmitted infection

(STI) that is passed between people through skin-to-skin contact
during sexual activity. HPV infection causes genital warts, some of
which can turn into cancer. For the most part, however, HPV
infection is benign. More than 90 percent of HPV infections cause
no clinical symptoms and are self-limited, meaning the virus is
cleared by the body via natural immunological defenses. Infection
with a high-risk HPV type is associated with a higher chance of the
development of cervical cancer but, by itself, HPV infection is not
the sole risk factor to cause cancer. There are many other factors.

4. There are a catena of judgements which have ruled that

A. No one can ask the parents their reason for refusing

consent for administering MR vaccines to their children

B. Authorities and doctors administering the vaccines

are duty bound to take informed consent from parents
 as well advertise widely about the contents and adverse
events of the MR vaccines.

4.1. In Master Haridaan Kumar Vs. Union of India 2019 SCC

OnLine Del 11929, it is ruled as under;

“14. The contention that indication of the side effects and

contraindications in the advertisement would discourage
parents or guardians from consenting to the MR campaign
and, therefore, the same should beavoided, is unmerited.
The entire object of issuing advertisements is to ensure that
necessary information is available to all parents/guardians
in order that they can take an informed decision. The
respondents are not only required to indicate the benefits of
the MR vaccine but also indicate the side effects or
contraindications so that the parents/guardians can take an
informed decision whether the vaccine is to be administered
to theirwards/children.

15. In view of the above, it is directed as under:

(4) MR vaccines will not be administered to those students

whose parents/guardians have declined to give their
consent. The said vaccination will be administered only to
those students whose parents have given their consent either
by returning the consent forms or by conforming the same
directly to the class teacher/nodal teacher and also to
students whose parents/guardians cannot be contacted
despite best efforts by the class teacher/nodal teacher and
who have otherwise not indicated to the contrary.

(1) Directorate of Family Welfare shall issue quarter page

advisements in various newspapers as indicated by the
 respondents, namely, The Hindustan Times, The Times of
India, The Hindu, The Pioneer, The Indian Express, Delhi
Tribune, Mail Today, The Asian Age, Navbharat Times,
Dainik Jagran, Punjab Kesari, Hindustan, Amar Ujala,
Navodaya Times, Hamara Samaj, Pratap, Daur-e-Jadeed,
Jathedar, Jan Ekta. The advertisements shall also indicate
that the vaccination shall be administered with Auto Disable
Syringes to the eligible children by Auxiliary Nurse
Midwifery. The advertisement shall also clearly indicate the
side effects and contraindications as may be finalised by the
Department of Preventive Medicine, All India Institute of
Medical Sciences.”

4.2. That the provisions of Universal Declaration on Bioethics and

Human Rights, 2005 also mandate for informed consent. Relevant
Articles reads thus;

Article 6 – Consent.

1. Any preventive, diagnostic and therapeutic medical

intervention is only to be carried out with the prior, free and
informed consent of the person concerned, based on
adequate information. The consent should, where
appropriate, be express and may be withdrawn by the person
concerned at any time and for any reason without
disadvantage or prejudice.

2. Scientific research should only be carried out with the

prior, free, express and informed consent of the person
concerned. The information should be adequate, provided in
a comprehensible form and should include modalities for
withdrawal of consent. Consent may be withdrawn by the
person concernedat any time and for any reason without any
disadvantage or prejudice. Exceptions to this principle
should be made only in accordance with ethical and legal
standards adopted by States, consistent with the principles
and provisions set out in this Declaration, in particular in
Article 27, and international human rights law.

3. In appropriate cases of research carried out on a group of

persons or a community, additional agreement of the legal
representatives of the group or community concerned may be
sought. In no case should a collective community agreement
or the consent of a community leader or other authority
substitute for an individual’s informed consent.

Article 7 – Persons without the capacity to consent

In accordance with domestic law, special protection is to be

given to persons who do not have the capacity to consent:

(a) authorization for research and medical practice should be

obtained in accordance with the best interest of the person
concerned and in accordance with domestic law. However,
the person concerned should be involved to the greatest extent
possible inthe decision-making process of consent, as well as
that of withdrawing consent;

research should only be carried out for his or her direct health
benefit, subject to the authorization and the protective
conditions prescribed by law, and if there is no research
alternative of comparable effectiveness with research
 participants able to consent. Research which does not have
potential direct health benefit should only be undertaken by
way of exception, with the utmost restraint, exposing the
person only to a minimal risk and minimal burden and, if the
research is expected to contribute to the health benefit of
other persons in the same category, subject to the conditions
prescribed by law and compatible with the protection of the
individual’s human rights. Refusal of such persons to take
part in research should be respected.

4.3. That, Supreme Court in Common Cause Vs. Union of India (2018)
5 SCC 1, it is ruled as under;

“517. The entitlement of each individual to a dignified

existence necessitates constitutional recognition of the
principle that an individual possessed of a free and
competent mental state is entitled to decide whether or not
to accept medical treatment. The right of such an individual
to refuse medical treatment is unconditional. Neither the
law nor the Constitution compel an individual who is
competent and able to take decisions, todisclose the reasons
for refusing medicaltreatment nor is such a refusal subject
to the supervisory control of an outside entity;

202.9. Right to life and liberty as envisaged under Article 21

of the Constitution is meaningless unless it encompasses
within itssphere individual dignity. With the passage of time,
this Court has expanded the spectrum of Article 21 to
include within it the right to live with dignity as component
of right to life and liberty.
 306. In addition to personal autonomy, otherfacets of human
dignity, namely, “self-expression” and “right to determine”
also support the argument that it is the choice of thepatient
to receive or not to receive treatment.”

4.4. In Montgomery Vs. Lanarkshire Health Board [2015] UKSC

11, it is ruled as under;

“77. These developments in society are reflected in

professional practice. The court has been referred in
particular to the guidance given to doctors by theGeneral
Medical Council, who participated as interveners in the
present appeal. One of the documents currently in force
(Good Medical Practice (2013)) states, under the heading
“The duties of a doctor registered with the General
Medical Council”:

“Work in partnership with patients. Listen to, and respond

to, their concerns and preferences. Give patients the
information they want or need in a way they can
understand. Respect patients’ right to reach decisions with
you about their treatment and care.”

78. Another current document (Consent: patients and

doctors making decisions together (2008)) describes abasic
model of partnership between doctor andpatient:

“The doctor explains the options to the patient, setting out

the potential benefits, risks, burdens and side effects of
each option, including the option to have no treatment.
The doctor may recommend a particular option which they
believe to be best for the patient, but they must not put
pressure on the patient to accept their advice. The patient
weighs up thepotential benefits, risks and burdens of the
various options as well as any non-clinical issues that are
relevant to them. The patient decides whether to accept any
of the options and, if so, which one.” (para 5)

In relation to risks, in particular, the document advises that

the doctor must tell patients if treatment might result in a
serious adverse outcome, even if the risk is very small, and
should also tell patients about less serious complications if
they occur frequently (para 32). The submissions on behalf
of the General Medical Council acknowledged, in relation
to these documents, that an approach based upon the
informed involvement of patients in their treatment, rather
than their being passive and potentially reluctant recipients,
can have therapeutic benefits, and is regarded as an integral
aspect of professionalism in treatment.

82. In the law of negligence, this approach entails a duty

on the part of doctors to take reasonable care to ensure that
a patient is aware of material risks of injury that are
inherent in treatment. This can be understood, within the
traditional framework of negligence, as a duty of care to
avoid exposing aperson to a risk of injury which she would
otherwise have avoided, but it is also the counterpart of the
patient’s entitlement to decide whether or not to incur that
risk. The existence of that entitlement, and thefact that its
exercise does not depend exclusively on medical
considerations, are important. They point to a fundamental
distinction between, on the one hand, the doctor’s role when
considering possible investigatory or treatment options and,
on the other, her role in discussing with the patient any
recommended treatment and possible alternatives, and the
risks of injury which may be involved.

83. The former role is an exercise of professional skill and

judgment: what risks of injury are involved in an operation,
for example, is a matter falling within the expertise of
members of the medical profession. But it is a non sequitur
to conclude that the question whether a risk of injury, or
the availability of an alternative form of treatment, ought to
be discussed with the patient is also a matter of purely
professional judgment. The doctor’s advisory role cannot be
regarded as solely an exercise of medical skill without
leaving out of account the patient’s entitlement to decide on
the risks to her health which she is willingto run (a decision
which may be influenced by non- medical considerations).
Responsibility for determining the nature and extent of a
person’s rights rests with the courts, not with the medical
professions.

87. The correct position, in relation to the risks of injury

involved in treatment, can now be seen to be substantially
that adopted in Sidaway by Lord Scarman, and by Lord
Woolf MR in Pearce, subject tothe refinement made by the
High Court of Australia in Rogers v Whitaker, which we
have discussed at paras 77-73. An adult person of sound
mind is entitled to decide which, if any, of the available
forms of treatment to undergo, and her consent must be
obtained before treatment interfering with her bodily
integrity is undertaken. The doctor is therefore undera duty
to take reasonable care to ensure that the patient is aware
of any material risks involved in any recommended
treatment, and of any reasonable alternative or variant
treatments. The test of materiality is whether, in the
circumstances of theparticular case, a reasonable person in
the patient’s position would be likely to attach significance
to the risk, or the doctor is or should reasonably be aware
that the particular patient would be likely to attach
significance to it.

89. Three further points should be made. First, it follows

from this approach that the assessment of whether a
risk is material cannot be reduced to percentages. The
significance of a given risk is likely to reflect a variety of
factors besides its magnitude:for example, the nature of the
risk, the effect which its occurrence would have upon the life
of the patient, theimportance to the patient of the benefits
sought to be achieved by the treatment, the alternatives
available, and the risks involved in those alternatives. The
assessment is therefore fact-sensitive, and sensitive also to
the characteristics of the patient.

90. Secondly, the doctor’s advisory role involves dialogue,

the aim of which is to ensure that the patient understands the
seriousness of her condition, and the anticipated benefits
and risks of the proposed treatment and any reasonable
alternatives, so that she is then in a position to make an
informed decision. This role will only be performed
 effectively if the information provided is comprehensible.
The doctor’sduty is not therefore fulfilled by bombarding
the patient with technical information which she cannot
reasonably be expected to grasp, let alone by routinely
demanding her signature on a consent form.”

4.3. In the case of Jacob Puliyel Vs. Union of India 2022 SCC Online
SC 533 the Supreme Court propounding that no one can be forced to
vaccinated ruled as under;

“(iii) With respect to the infringement of bodily integrity

and personal autonomy of an individual considered in the
light of vaccines and other public health measures
introduced to deal with the COVID-19 pandemic, we are of
the opinion that bodily integrity is protected under Article
21 of the Constitution and no individual can be forced to
be vaccinated. Further, personal autonomy of an
individual,which is a recognised facet of the protections
guaranteed under Article 21, encompasses the right to
refuse to undergo any medical treatment in the sphere of
individual health. However, in the interest of protection of
communitarian health, the Government is entitled to
regulate issues of public health concern by imposing certain
limitations on individual rights, which are open to scrutinyby
constitutional courts to assess whether such invasion into an
individual's right to personal autonomy and right to access
means of livelihood meets the threefold requirement as laid
down in K.S. Puttaswamy (supra), i.e.,

(i) legality, which presupposes the existence of law;

(ii) need, defined in terms of a legitimate State aim;

 and

(iii) proportionality, which ensures a rational nexus

between the objects and the means adopted to achieve
them.”

5. Liability of School & other authorities under Criminal & Civil

Law:

5.1. That Hon’ble High Court in Registrar General, High Court

of Meghalaya Vs. State of Meghalaya 2021 SCC OnLine Megh
130, it is ruled as under;

“………

Thus, by use of force or through deception if an

unwilling capable adult is made to have the flu vaccine
would be considered both a crime and tort or civil wrong, as
was ruled in Airedale NHS Trust v Bland reported at 1993
AC 789 = (1993) 2 WLR 316= (1993) 1 All ER 821, around
thirty years (30) ago. Thus, coercive element of vaccination
has, since the early phases of the initiation of vaccination as
a preventive measure against several diseases, have been
time and again not only discouraged but also consistently
ruled against by the Courts for over more than a century.

In this context, around one hundred and seven (107) years

ago, in Schloendroff v Society of New York Hospitals reported
at (1914) 211 NY 125 = 105 NE 92; 1914 NY Justice Cardozo
ruled that „every humanbeing of adult years and sound mind
has a right to determine what shall be done with their body‟.

This finds mention in decisions of the European

Commission and Court of Human Rights [X vs. Netherlands
 of 1978 (decision rendered on 4th December, 1978); X vs.
Austria of 1979 (decision rendered on 13th December,
1979)] which has become truer in the present times across
the world than ever before. Compulsorily administration of
a vaccine without hampering one‟s right to life and liberty
based on informed choice and informed consent is one
thing. However, if any compulsory vaccination drive is
coercive by its very nature and spirit, it assumes a different
proportion and character.

However, vaccination by force or being mademandatory by

adopting coercive methods, vitiates the very fundamental
purpose of the welfare attached to it.”

5.2. All authorities are bound to ensure that they should not be part of
conspiracy to the offences committed by the authorities.

5.3. The act of omission on the part of any authority also make them
liable for prosecution as that of the main offender. Hon’ble Supreme
Court in State of Odisha Vs. Pratima Mohanty Etc. 2021 SCC
OnLine SC 1222.

5.4. Every person joining the conspiracy is liable.

In Raman Lal Vs. State of Rajasthan 2000 SCC OnLine Raj
226, has ruled that;

“Conspiracy – I.P.C. Sec. 120 (B) – Apex court made it clear

that an inference of conspiracy has to be drawn on the basis
of circumstantial evidence only because it becomes difficult
to get direct evidence on such issue – The offence can only
be proved largely from the inference drawn from acts or
illegal ommission committed by them in furtherance of a
 common design – Once such a conspiracy is proved, act of
one conspirator becomes the act of the others – A Co-
conspirator who joins subsequently and commits overt acts
in furtherance of the conspiracy must also be held liable –
Proceeding against accusedcannot be quashed.”

6. Under these circumstances it is clear that the Authorities, Principal,

School Management, Ministers etc., who are promoting HPV
vaccines should resist and desist from doing any act which is
violative of the mandates of the law and constitution.

7. Needless to mention here that, any authority or school staff are not
supposed to follow any unlawful or unconstitutional orders by the
senior Government officials or even by the courts if constitutional
provisions are vitiated. If anyone follows unconstitutional and illegal
orders, then he should be held guilty of offence even if the order was
that of the Court. [Nandini Satpathy Vs. P.L.Dani (1978) 2 SCC
424].

8. Once the children are given HPV vaccines, then there is no process
for reversing the effect, if these vaccines prove to be harmful. Some
of the side effects of the HPV vaccine for which compensation has
been awarded include but are not limited to the following:

• Acetabular labrum tear

• Acute Disseminating Encephalomyelitis (ADEM)
• Aggravation of multiple sclerosis (MS)
• Aplastic Anaemia
• Autoimmune limbic encephalitis
• Blood Clots
• Cardiac Arrest
• Cardiomyopathy
• Cardiac Arrythmia
• Cerebral Vasculitis
• Demyelinating disorders
• Demyelinating encephalitis
• Developmental delays
• Dizziness
• Epilepsy
• Epstein Barr virus (reactivated)
• Fainting
• Fatigue
• Guillian-Barre Syndrome (GBS)
• Headaches
• Henoch Schonlein Purpura
• Hip impingement syndrome
• Joint pain
• Juvenile Amyotrophic Lateral Sclerosis (ALS)
• Macrophagic Myofasciitis (MFF)
• Myocarditis
• Neuromyelitis Optica (NMO)
• Neurogenic bladder
• Neurological Injury
• Neutrophilic urticaria
• Optic Neuritis
• Pancreatitis
• Photophobia
• Polyarthritis
• Polyarthralgia pain syndrome
• Rheumatoid arthritis
• Snapping hip syndrome
• Subarachnoid haemorrhage
• Systemic Juvenile Idiopathic Arthritis
• Transverse Myelitis
 • Ulcerative Colitis
• Urticaria
• Vitiligo
• Vomiting
• Weston Hurst disease
• Death

9. List of lawsuits where courts ordered damages for people suffering

from adverse events of HPV vaccines.
• Court awarded over $ 860,000 in lump sum payments, and
several thousand dollars in recurring annual payments, after a
woman suffered neurological injury and/or transverse myelitis
following HPV vaccination (Link:
https://casetext.com/case/good-v-secy-of-health-human-servs)
• Person suffered GBS and/or acute disseminating
encephalomyclitis ("ADEM") as a result of receiving the Tdap,
hep. B, IPV, MMR, hep. A, and HPV vaccines. Court has
directed over $1 million lumpsum & thousands of dollars
recurring annually as compensation (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2012vv0729-74-0)
• Lady suffered from neuromyelitis optica (NMO) following
administration of flu & HPV. Court ordered over $1 million
lump sum and several thousand dollars in recurring payments as
compensation. (Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2012vv0630-164-0)
• A woman developed demyelinating disorders following HPV
vaccines. Court awarded damages, including $1.9 million lump
sum and ~$150,000 in recurring annual payments for life. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2012vv0298-139-0)
• Court ordered over $38,000 in damages after person suffered
from vitiligo following HPV vaccination. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2017vv1096-45-0)
• “Petitioner had proven, by a preponderance of the evidence, that
her sJIA was caused by her HPV vaccinations”. Child suffered
systemic juvenile idiopathic arthritis following HPV. Court
ordered ~1.3 million dollars lumpsum & ~$38,000 in lifetime
 annual payments. (Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2011vv0549-88-0)
• Child suffered from autoimmune limbic encephalitis, intractable
epilepsy & developmental delays following HPV. Court ordered
damages: $1.5 million lumpsum & over $120,000 in recurring
annual payments. (Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2009vv0293-176-0)
• A female suffered ulcerative colitis after HPV vaccination, Court
ordered $800,000 in compensation. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2013vv0529-55-0)
• Petitioner suffered urticaria following HPV vaccine. Court
ordered over $166,000 in compensation. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2013vv0044-74-0)
• Female died of cardiac arrest 3 days after receiving 2nd dose of
the HPV vaccine. Court ordered $175,000 in compensation
following claim by the parents. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2015vv0929-90-0)
• Young child died following receipt of multiple vaccines
including HPV. Court acknowledged vaccines as the cause of
death. (Compensation amount unknown) (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2011vv0206-185-0)
• Female died suddenly after HPV vaccination. Court ordered
compensation of $310,000 to her estate. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2010vv0251-213-0)
• Person died of myocarditis following HPV vaccination. Court
ordered compensation of $200,000. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2015vv0160-47-0)
• Female died from cerebral vasculitis following HPV vaccination.
Court ordered $200,000 compensation. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2010vv0103-145-0)
• Female died from arrhythmia due to cardiomyopathy following
HPV vaccine. Court ordered $40,000 in damages. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.LALOUX.112612.._0.pdf)
• Female died of Weston Hurst disease, Acute Disseminated
Encephalomyelitis (“ADEM”), juvenile Amyotrophic Lateral
Sclerosis (“ALS”) and/or a chronic progressive demyelinating
encephalitis following HPV vaccination. Court ordered $20,000
in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/ZANE
.INCZE121012.pdf)
• Female died due to aplastic anemia following HPV vaccination,
Court ordered compensation of $240,000. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/GOLK
IEWICZ.IBARRA072611.pdf)
• A woman suffered significant aggravation of pre-existing acute
disseminated encephalomyelitis (“ADEM”) and/or multiple
sclerosis (“MS”), following HPV vaccination. Court ordered
$350,000 in compensation. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2010vv0745-146-0)
• Minor child developed optic neuritis as a result of receiving the
HPV, Hepatitis A, Meningococcal, and Tdap vaccinations. Court
ordered over $206,000 in compensation. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2015vv1497-28-0)
• Minor child suffered from transverse myelitis (“TM”),
encephalomyelitis (“ADEM”), neurogenic bladder, and
subsequent conditions following receipt of flu, HPV & Hepatitis
A vaccines. Court ordered $185,000 in compensation. (Link:
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2014vv0572-25-0)
• Woman suffered from chronic neutrophilic urticaria following
HPV vaccine. Court ordered $210,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.WHITING.061913...pdf)
• Person suffered chronic joint pain & fatigue following receipt of
the HPV vaccine. Court ordered $28,500 in compensation.
(Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.SNYDER.050813..pdf)
• Person suffered pancreatitis and blood clots following receipt of
HPV, TDaP & meningococcal vaccination. Court ordered
$25,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.GREGORY.041613...pdf)
• Person suffered from headaches, dizziness, photophobia,
vomiting, subarachnoid * hemorrhage after receiving HPV
vaccine. Court ordered $10,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.JOHNSON.022613...pdf)
• Female suffered macrophagic myofasciitis (“MFF”) after HPV
vaccination. Court ordered $350,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/MOR
AN.RATNER020813.pdf)
• Female died due to cardiomyopathy after receiving HPV
vaccine. Court ordered $40,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.LALOUX.112612.._0.pdf)
• Girl suffered from acute disseminated encephalomyelitis
(ADEM) after receiving HPV vaccine. Court ordered $125,000
in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAST
INGS.SALLACH.103112.._0.pdf)
• Female developed a reactivated Epstein Barr virus infection and
aplastic anemia after HPV vaccine. Court ordered $70,000 in
compensation. (Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2011vv0620-140-0)
• Female suffered GBS after HPV vaccination, Court ruled that
condition was caused by the vaccine and petitioner was entitled
to compensation. (Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2010vv0077-156-0)
• Female suffered from polyarthritis, polyarthralgia pain
syndrome, seronegative rheumatoid arthritis, hip impingement
syndrome, acetabular labrum tear, and snapping hip syndrome
after HPV vaccine, Court ordered $25,000 in compensation.
(Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2014vv0438-40-0)
• Female suffered from GBS after HPV vaccine. Court concluded
vaccine caused the condition and ordered $1.4 million in
compensation. (Link: https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2011vv0140-123-0)
• Female fainted & suffered facial injuries following HPV
vaccine. Court ordered ~$32,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/MOR
AN.VANSCOY100213.pdf)
• Female suffered pancreatitis following HPV vaccine. Court
ordered ~$68,000 in compensation. (Link:
 http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAMI
LTON-FIELDMAN.PARSONS.41613.pdf)
• Female suffered acute disseminated encephalomyelitis (ADEM)
with transverse myelitis, as a result of receiving HPV, Hepatitis
A & flu jabs. Court ordered $90,000 in compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/HAMI
LTON-FIELDMAN.TOCIO_.032813.pdf)
• Female suffered injury Henoch-Schonlein Purpura and other
adverse effects, after HPV vaccination. Court ordered $15,000 in
compensation. (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/MOR
AN.GRIFFIN052711.pdf)
• Female suffered from GBS following HPV & varicella jabs.
Court ordered $125,000 in compensation (Link:
http://www.uscfc.uscourts.gov/sites/default/files/opinions/Millm
an.Nelson 9-73.pdf)
• U.S. court pays $6 million to Gardasil victims
https://m.washingtontimes.com/news/2014/dec/31/us-court-
pays-6-million-gardasil-victims/
• US, 2021: Court awarded over $ 860,000 in lump sum payments,
and several thousand dollars in recurring annual payments, after a
woman suffered neurological injury and/or transverse myelitis
following HPV vaccination.
https://casetext.com/case/good-v-secy-of-health-human-servs
• Court orders over $38,000 in damages after person suffered from
vitiligo following HPV vaccination
https://ecf.cofc.uscourts.gov/cgi-
bin/show_public_doc?2017vv1096-45-0
https://twitter.com/awakenindiamov/status/16123134114334064
66?s=20&t=o5CQ0gBaK8AbMMKQT7-jOA
10. Media reports of vaccine injuries from India
Controversial vaccine studies: Why is Bill & Melinda Gates
Foundation under fire from critics in India
In 2009, several schools for tribal children in Khammam district in
Telangana — then a part of undivided Andhra Pradesh — became
sites for observation studies for a cervical cancer vaccine that was
administered to thousands of girls aged between nine and 15. The
girls were administered the Human Papilloma Virus (HPV) vaccine
in three rounds that year under the supervision of state health
department officials. The vaccine used was Gardasil, manufactured
by Merck. It was administered to around 16,000 girls.
Months later, many girls started falling ill and by 2010 five of them
died. Two more deaths were reported from Vadodara, Gujarat,
where an estimated 14,000 children studying in schools meant for
tribal children were also vaccinated with another brand of HPV
vaccine, Cervarix, manufactured by GSK.
https://economictimes.indiatimes.com/industry/healthcare/biotech/
healthcare/controversial-vaccine-studies-why-is-bill-melinda-
gates-foundation-under-fire-from-critics-in-
india/articleshow/41280050.cms?from=mdr
The HPV vaccine, administered to pre-pubescent girls to prevent
cervical cancer, has received considerable bad press over its 14
years.
Why has the controversy around the HPV vaccine still not died
down?
https://www.business-standard.com/article/health/why-has-the-
controversy-around-the-hpv-vaccine-still-not-died-down-
120021401998_1.html
As many as 120 girls experienced reactions such as epileptic
seizures, severe stomachache, headache and mood swings.
https://www.deccanherald.com/content/63156/were-tribal-girls-
guinea-pigs.html
Besides 7 deaths, over 120 girls experienced severe adverse events
and many continued to do so even after 2 years of follow up. Many
of the girls continue to suffer from stomachaches, headaches,
giddiness, and exhaustion. There have been reports of early onset of
 menstruation, heavy bleeding and severe menstrual cramps and
extreme mood swings, irritability, and uneasiness following the
vaccination.
There were reports of deaths of four girls from Andhra Pradesh and
two girls from Gujarat following the administration of the Human
Papilloma Virus (HPV) vaccine. Sama along with Jan Swasthya
Abhiyan and Anthra conducted a fact finding in March 2010 in
Bhadrachalam, one of the areas in Andhra Pradesh, where the HPV
vaccine was being administered.
https://samawomenshealth.in/fact-finding-of-hpv-vaccine-
demonstration-project-in-andhra-pradesh/
Indian Parliament Comes Down Hard on Cervical Cancer Trial
https://www.science.org/content/article/indian-parliament-comes-
down-hard-cervical-cancer-trial
Trials and tribulations: an expose of the HPV vaccine trials by the
72nd Parliamentary Standing Committee Report
http://test.pharmabiz.com/news/govt-stops-phase-3-trial-of-hpv-
vaccines-after-death-of-6-children-in-ap-gujarat-55908

10.1 72nd Parliamentary Report – Chapter XII –

10.1.1 Scathing 72nd parliamentary report, Rajya Sabha, alleging criminal

irregularities by PATH, Bill& Melinda Gates Foundation in
collusion with Indian authorities for HPV Vaccine Trials criminals
handling India’s AEFI system.
Department-Related Parliamentary Standing Committee on Health
and Family Welfare released the 72nd report titled “Alleged
Irregularities in the Conduct of Studies using Human Papilloma
 Virus (HPV) Vaccine by Path in India (Department of Health
Research, Ministry of Health and Family Welfare)” dated 30th
August 2013. The report has concluded that the program was to
serve the ulterior, commercial interests of vaccine manufacturer to
include the said vaccine in universal immunization programme
which would have generated windfall profit for the manufacturer(s)
by way of automatic sale year after year, without any promotional
or marketing expenses.
The committee also concluded that the officers of Indian Council of
Medical Research (ICMR), in an unauthorized manner, had signed
Memorandum of Understanding (MoU) in 2007 even before the
vaccines were approved for use in the country, which actually
happened in the year 2008.

10.1.2 Important recommendations of the Parliamentary Committee asking

for investigation and legal action against, PATH, Bill Gates and
officials of ICMR are as under;

“2.5 The Committee finds the entire matter very intriguing and
fishy. The choice of countries and population groups; the
monopolistic nature, at that point of time, of the product being
pushed; the unlimited market potential and opportunities in the
universal immunization progammes of the respective countries
are all pointers to a well planned scheme to commercially
exploit a situation.”

“3.18. The Committee feels that there was serious dereliction

of duty by many of the Institutions and individuals involved. The
Committee observes that ICMR representatives, instead of
ensuring highest levels of ethical standards in research studies,
apparently acted at the behest of the PATH in promoting the
interests of manufacturers of the HPV Vaccine.”

“4.6 The Committee’s examination has proved that DCGI has

also played a very questionable role in the entire matter.
Initially, it took a call that since human subjects, as part of the
studies, were receiving invasive intervention like immunization,
clinical trial rules must be enforced. However, it remained as a
silent spectator thereafter, even when its own rules and
regulations were being so flagrantly violated. The approvals of
clinical trials, marketing approval and import licenses by
DCGI appear to be irregular. Therefore, the role of DCGI in
this entire matter should also be inquired into.”

“6.17. The Committee, accordingly, concludes that most, if not

all consent forms, were carelessly filled-up and were
incomplete and inaccurate. The full explanation, role,
usefulness and pros and cons of vaccination had not been
properly communicated to the parents/guardians. The
Committee observes that there is a gross violation of the
consent and legal requirement of consent which had been
substantiated by the experts. The Committee takes a serious
view of the violations and strongly recommends that on the
basis of the above facts, PATH should be made accountable and
the Ministry should take appropriate action in the matter
including taking legal action against it for breach of various
laws of the land and possible violations of laws of the Country
of its origin.”

“6.26 The Committee observes that the wrongful use of the

NRHM logo for a project implemented by a private, foreign
agency as well as the identification of this project with the UIP
has adversely affected and damaged the credibility of the
programme as well as that of the NRHM.”

“6.27. Besides, the Committee notes that no information had

been provided to Indian authorities about funding of the project
except that it was reportedly funded by Bill and Melinda Gates
Foundation and that the vaccines had been donated by the
manufacturers. The information regarding financial
investments of ICMR and State Governments in the project was
not provided, though the States clearly provided cold chain and
manpower for immunization.”

“6.37 The Committee also noticed lack of firm action on the

part of DCGI, to avoid such irregularities in future. One of the
actions proposed by the DCGI to check any recurrence of such
gross violations was ‘proposal to amend the definition of New
Drug during the next meeting’. The same assurance was given
by DCGI in December, 2012. The Committee, accordingly,
observes that response of the Department and DCGI is very
casual, bureaucratic and lacks any sense of urgency..”

“7.11.. It is surprising that security and intelligence agencies

did not raise an eyebrow on the way a foreign entity entered
India virtually incognito through the backdoor. The Committee
desires that such incidents should not be allowed in future. The
Government should tighten the rules lest one day foreign
citizens, with deep roots in organizations/nations inimical to
India, set up offices in the country to engage in anti-national
and/or unlawful activities.”

“7.13 Coming to the instant case, it is established that PATH

 by carrying out the clinical trials for HPV vaccines in Andhra
Pradesh and Gujarat under the pretext of
observation/demonstration project has violated all laws and
regulations laid down for clinical trials by the Government.
While doing so, its sole aim has been to promote the
commercial interests of HPV vaccine manufacturers who would
have reaped windfall profits had PATH been successful in
getting the HPV vaccine included in the UIP of the Country.
This is a serious breach of trust by any entity as the project
involved life and safety of girl children and adolescents who
were mostly unaware of the implications of vaccination. The
violation is also a serious breach of medical ethics. This act of
PATH is a clear cut violation of the human rights of these girl
children and adolescents.”

10.1.3. Despite there being sufficient evidence of wrongdoings by PATH,

BMGF, officials of ICMR, CDSCO and DCGI no action has been
taken yet by the government of India After 11 years since the death
of 8 girls, countless others injured, there seems to be a lack of
political will to take action against these pharma mafia. This also
clearly shows that the current administration which is promoting the
HPV vaccines will ill intent and cannot be trusted.

11. Countries that suspended/restricted/discontinued HPV vaccine over

concerns

11.1 Japan

• Cervarix vaccine issues trigger health notice

The Japanese health ministry had issued a nationwide notice that
 cervical cancer vaccinations should no longer be recommended
for girls aged 12 to 16 because several adverse reactions to the
medicines had been reported.
https://www.japantimes.co.jp/news/2013/06/15/national/cervix-
vaccine-issues-trigger-health-notice/
• Lessons learnt in Japan from adverse reactions to the HPV
vaccine: a medical ethics perspective
https://ijme.in/articles/lessons-learnt-in-japan-from-adverse-
reactions-to-the-hpv-vaccine-a-medical-ethics-
perspective/?galley=html
• In the spring of 2022, Japan announced it was relaunching its
HPV vaccination drive.

11.2 United States

The original Gardasil(approved in 2006) and Cervarix—are still

used around the world, but both have been voluntarily discontinued
in the United States.

https://www.medscape.com/viewarticle/870853

11.3 Denmark

Documentary on HPV Vaccine Shows Lives of Young Women

Ruined

https://healthimpactnews.com/2015/tv2-denmark-documentary-on-
hpv-vaccine-shows-lives-of-young-women-ruined/

https://oye.news/news/health/vaccines/the-vaccinated-girls-sick-
betrayed/

http://www.wakingtimes.com/gardasil-firestorm-in-
denmark/?utm_content=bufferd0247&utm_medium=social&utm_s
 ource=twitter.com&utm_campaign=buffer

11.4 Israel

Criticism from Israel doctor on HPV vaccine is documented here in

the link below

https://www.ageofautism.com/2013/09/hpv-vaccine-a-strong-
criticism-from-leading-israeli-obgyn-doctor.html

11.5 Australia

The Australian government’s cancer data show the dramatic rise in

cervical cancer in young girls vaccinated with Gardasil. Merck
markets Gardasil as a prophylactic against cervical cancers despite
the company’s own pre-licensing studies that showed a 44.6%
INCREASE in cervical cancers among girls exposed to HPV virus
prior to vaccination (up to 30% may be exposed in the birth canal)

https://childrenshealthdefense.org/news/australian-data-cancer-
epidemic-in-gardasil-girls/

https://changingtimes.media/2019/05/26/hpv-vaccination-more-
than-100-adverse-reaction-cases-excluded-from-public-database-
in-australia/

11.6 Colombia

200 girls were hospitalized following hpv vaccination in Colombia

https://www.youtube.com/watch?v=1307z5xltrU

https://apnews.com/article/43b7d6db765c48d8b88d3f3221351546

https://www.scmp.com/news/world/article/1581501/hundreds-girls-
colombian-town-sick-after-taking-gardasil-vaccine
11.7 Sweden

The Centre for Cervical Cancer Prevention in Sweden has noted in

its annual report a substantial increase in the incidence of invasive
cervical cancer, especially during the two years 2014 and 2015

https://ijme.in/articles/increased-incidence-of-cervical-cancer-in-
sweden-possible-link-with-hpv-vaccination/?galley=html

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4383348/

https://pubmed.ncbi.nlm.nih.gov/30037785/

11.8 Mexico

Girls convulsed on the floor after receiving hpv vaccines in 2015

https://www.bitchute.com/video/yuNwLqwBJUyB/

11.9 New Zealand

Three New Zealand girls killed following Gardasil vaccination

https://envirowatchrangitikei.wordpress.com/2017/03/15/hpv-
vaccination-gardasil-kills-three-new-zealand-girls-and-debilitates-
hundreds-of-
others/?fbclid=IwAR1Vrm3auFin_lJevMyvBMfphD2_AIDRhqaz0
aEF9fFTo_ndt0hmj76J4QY

11.10 Spain

Concerns raised about Gardasil in Spain

https://www.reuters.com/article/tb-merck-gardasil-suspension-
idUSLA56308620090210

https://www.healthplanspain.com/blog/health-news/414-concerns-
raised-about-hpv-vaccine.html
11.11 Ireland

Almost 650 girls in Ireland reported requiring medical intervention

or treatment after receiving the HPV vaccine

https://www.irishtimes.com/news/health/almost-650-girls-needed-
medical-intervention-after-hpv-vaccine-1.3217346

11.12 Other References:

https://www.youtube.com/watch?v=8dxvXPd8BpE

12. Summary

12.1 Vaccines do not provide lifelong immunity

Though vaccines are claimed to prevent cervical cancer, the truth is

that cervical cancer takes twenty or more years to develop and the
vaccines have just not been around that long to prove their efficacy
in preventing cancer. But what is known with certainty is that if these
vaccines are given to women who already are infected with the virus
then they do raise the incidence of cervical cancer among those
women.

Gardasil was first licensed in the USA in June 2006. This licensing
was done on fast track with numerous conflicts of interests not only
on the review board but also in that that the vaccine patent was held
in PPP and the FDA itself as a part of the health department would
benefit from the sales.

https://journals.sagepub.com/doi/10.1177/0141076819899308

12.2 No long-term studies for HPV vaccine

The vaccines are genetically engineered and their hazards are

unknown even to the scientific communities. Though r-DNA has
 been detected in Gardasil in samples from many countries including
India, in their application for licensing MSD pharmaceuticals
claimed that there was no hazard because there was no r-DNA.
GlaxoSmithKline uses a novel technique for producing Cervarix
which involves the use of insect cells. Their product information
admitted to their vaccine containing insect cells and proteins only in
July 2011 though the vaccine was already in use since 2007. These
residues or adventitious agents enter the blood stream when the
vaccine is injected and are acknowledged to have the capacity to
cause infections, tumours, and cancer.

https://www.tandfonline.com/doi/epdf/10.3109/07853890.2011.645
353?needAccess=true&role=button

12.3 Mortality Rate from HPV virus

In most cases HPV goes away on its own within two years without
any serious health problems and most women with even with high-
risk HPV infection do not develop cancer. When it does not go away
it either leads to genital warts or cancers in the anus, vulva, vagina
which are preventable.

Infection with a high-risk HPV type is associated with a higher

chance of the development of cervical cancer but, by itself, HPV
infection is not the sole risk factor to cause cancer. There are many
other factors.

Survival rate of cervical cancer has been found to be 99.99% in the

US and 99.99% in India.

https://jacob.puliyel.com/paper.php?id=186

12.4 Side Effects of HPV vaccines

 Side effects of HPV vaccines include neurological injury,
myocraditis, ovarian injuries. auto immune diseases, cervical cancer
and death.

Concluding Paragraph:
(i) Authorities should be cautious when conducting mass vaccination of
children when natural immunity has proved to bestow life long immunity.
(ii) No authority can impose any condition to get vaccinated;
(iii) Forcing to get vaccinated to avail certain services is a civil wrong
and criminal offence punishable under Section 166, 188, 341, 342, 109,
323, 336, 511, 115, 120 (B), 34, 52 etc. of IPC and Section 51(b), 55 of
Disaster Management Act, 2005;
(iv) If any children die due to vaccination then concerned doctors &
authorities will be liable for charge of murder punishable under Section
302 of IPC;
(v) Except the written consent of parents, the children should not be
vaccinated. Informed consent of parents is mandatory;
(vi) The Doctors or public authorities promoting vaccination are bound
to explain and publish the death causing and other side effects of vaccines
by giving advertisements in all daily newspapers as well as in web and
electronic media;
(vii) Without such publication and without giving full information if any
children are vaccinated, then it is an offence of cheating punishable under
Section 420, 120 (B) & 34 of IPC;
In the said prosecution, victim parents can demand compensation of any
amount without paying court fee, by invoking section 357(3) of Code of
Criminal Procedure Code;
(viii) As per section 120 (B) all the school authorities, Principal, Doctors,
Nurses, ASHA (Accredited Social Health Activist) workers etc. will be
equally responsible for all the offences for their act of commission and
omission. [Raman Lal Vs. State of Rajasthan 2020 SCC OnLine Raj 226,
State of Odisha Vs. Pratima Mohanty 2021 SCC OnLine SC 1222]
(ix) As per section 52 of IPC nothing can be said to be done in good faith
if it is not done with due care and caution.
(x) Indian Lawyers and Human Rights Activists Association will take
strict legal action against any Public or Private Institution and its
office bearers for violating the law.

Yours Sincerely

A. H. Koiri
National Steering Committee Member
Awaken India Movement