THE establishment of the National Agri-Trade and Food Safety Authority (NAFSA) is being presented as a major institutional reform intended to strengthen Pakistan’s agricultural trade, food safety system and compliance with international sanitary and phytosanitary (SPS) requirements. The initiative is still trying to emerge through the Pakistan Single Window (PSW) and is being portrayed as a step towards modern regulatory governance. While modernization of the agricultural regulatory framework is a welcome objective, the simultaneous abolition of the Department of Plant Protection (DPP) raises a fundamental legal and operational question: what happens to those functions that continue to exist under the Federal Government’s Rules of Business, 1973?
For decades, the Department of Plant Protection, under various organizational structures since independence, served as Pakistan’s frontline institution against invasive and transboundary plant pests and diseases. As an Attached Department of the Ministry of National Food Security and Research, it carried out highly specialized technical and operational functions essential for national food security, agricultural productivity and safe international trade. Under Schedule II of the Rules of Business, the Ministry’s responsibilities specifically include plant protection, pesticide import and standardization, aerial spray operations, plant quarantine, locust control in its international aspect and the maintenance of locust warning organizations. These are not ceremonial assignments; they constitute the core of Pakistan’s agricultural biosecurity system. With the creation of NAFSA, plant quarantine and pesticide regulatory functions have reportedly been transferred to the new authority. However, the Rules of Business continue to recognize several other critical functions historically performed by DPP, including plant protection operations, aerial spraying, international locust control coordination and maintenance of locust warning services. This raises an important question: who is now legally and operationally responsible for these remaining functions?
If DPP has been abolished and its personnel transferred en bloc to the surplus pool, as reported and officially notified, which institution will conduct nationwide desert locust surveillance and forecasting? Which agency will maintain the country’s locust warning network? Who will coordinate with regional and international organizations during a locust emergency? Who will undertake aerial control operations when agricultural crises demand an immediate response? The Rules of Business appear silent on these questions. More importantly, no corresponding notification appears to have assigned these responsibilities to another institution.
This silence should concern policymakers because locust surveillance, control and plant protection are not routine administrative functions. They require specialized scientific expertise, trained field personnel, surveillance networks, forecasting systems, aircraft support capabilities and international coordination mechanisms built over decades. The desert locust emergency of 2019–2021 demonstrated how rapidly agricultural production can be threatened when pest populations expand across borders through migration of swarms and local breeding. During that crisis, Pakistan’s surveillance, forecasting and control infrastructure became a critical pillar of national food security.
Such institutional capacity cannot be recreated overnight once an emergency has already begun. The matter also extends beyond domestic agriculture. Pakistan is a member of the Food and Agriculture Organization’s Desert Locust Control Committee and the Commission for Controlling the Desert Locust in South-West Asia. These commitments require a functioning national institutional framework capable of surveillance, reporting and coordinated response. Equally alarming is the possible loss of institutional assets and institutional memory. The De-partment of Plant Protection possesses properties and operational facilities spread across Pakistan. Without clear custodial arrangements, such assets risk neglect, encroachment or misuse. Reports already suggest concerns regarding the protection of certain properties. The human resource dimension is even more important. Locust specialists, pest forecasters and operational staff—many trained through international programmes, including those of FAO—represent decades of accumulated expertise. Once dispersed, such specialized capacity is extremely difficult and costly to rebuild. Similarly, valuable operational assets including aircraft, specialized spray equipment, surveillance instruments, vehicles and field infrastructure require proper maintenance and preservation.
Institutional reforms are expected to strengthen governance, not create uncertainty. If NAFSA is intended to inherit all former DPP functions, the Rules of Business should be amended accordingly and without delay. Conversely, if certain responsibilities are to remain with the Ministry or another organization, the government should clearly identify and formally notify the responsible agency. Public administration functions effectively only when authority, responsibility and accountability are clearly defined. Ambiguity in matters relating to agricultural biosecurity and emergency locust response can have serious consequences for food security and the national economy. The government must therefore urgently clarify the legal and operational status of plant protection services, aerial spray operations, locust surveillance, forecasting and warning systems previously performed by the Department of Plant Protection.
Until such clarification is provided, one critical question will continue to linger: if the Department of Plant Protection has disappeared from the administrative landscape, who will protect Pakistan’s crops when the next desert locust swarms arrive? The answer should not remain buried in administrative silence. Desert locusts do not wait for governments to resolve institutional ambiguities. The Rules of Business, 1973, are not merely administrative guidelines; they define legal re-sponsibility within the Federal Government. Ignoring, bypassing or leaving statutory functions unattended creates a dangerous governance vacuum. In the case of desert locust surveillance and control, the consequences of such a vacuum may ultimately be measured not in files and notifications, but in damaged crops, threatened food security and economic losses running into billions of rupees.
—The writer is former Director General, Department of Plant Protection.
