NOTTO’s advisory on organ donation has troubling recommendations, say doctors and experts

A recent 10-point advisory from the National Organ and Tissue Transplant Organisation (NOTTO) to States and Union Territories (UT) to augment organ donation and transplantation in the country has some contentious recommendations. It has proposed to make provisions to grant additional points in the organ allocation criteria for women on the waiting list to address gender disparity, to prioritise a near relative of a previous deceased donor in need of transplant, and wants hospitals to provide data of each donor and recipient for the national registry maintained by it.

NOTTO, in line with the 15^th Indian Organ Donation Day 2025, had sent out the advisory with the approval of the competent authority of the Union Health Ministry. While it stated that States should honour the deceased organ donors, ensuring that they receive a dignified funeral and their family members are felicitated at public functions, it went on to suggest the following: to make provisions to give additional points in the allocation criteria for women patients in the waiting list for deceased donor organ transplants to address gender disparity, and to make provisions that if a near relative of a previous deceased donor needs organ transplant, then he/she may be given priority.

A senior doctor, who did not want to be named, said that these issues must be discussed in detail with all the stakeholders and cannot be implemented as such immediately. Another doctor in the know said: “There are no protocols for prioritising women and near relatives of previous donors. How will you define near relatives and streamline the same? Deceased donations, which run on the basis of altruism, have been happening since 1995, and how are we going to define near relatives of these donors?”

‘Encroaching on State’s role’

J. Amalorpavanathan, former convenor, Cadaver Transplant Programme (CTP) and founder member secretary, Transplant Authority of Tamil Nadu (TRANSTAN), said such an advisory was not necessary. “The powers of the State and Centre are clearly demarcated, and there is no need to infringe upon the role of either. These recommendations can only be seen as a furtherance to Government of India’s ‘One Nation, One Policy’ for organ donation and transplantation. It will lead to encroaching on the State’s role and policies and gradually usurping power,” he said.

He said that when the CTP was debated in 2008, there was discussion about prioritising women. “But then, there were points on also prioritising children, and then working parents. We decided to do away with such categories and take every human being in need of transplant as priority,” he added.

Another contentious point is asking States to issue directions to hospitals/centres performing organ and tissue transplantation/retrieval or tissue banking to provide data of each donor and recipient of organ or tissue for the national registry maintained by NOTTO. In the event of non-compliance, the States may consider taking action as per the Transplantation of Human Organ and Tissue Act, 1994. He viewed this as an example of the Centre encroaching on the right of the State to run matters of public health. Following a similar mandate from NOTTO in 2015, the State wrote back saying that any information required can be provided by the State government, which is fully in control of the transplant programme, he recalled.

The advisory also wanted States to promote adopting a healthy lifestyle and to highlight the role of ayurveda and yoga. Experts, however, objected to their imposition on evidence-based medicine.

While sources in the Health department said the advisory lacks clarity, a health official said these points require more discussion. Responding to a query on the sharing of data, officials clarified it was done through TRANSTAN.