PPP and the subversion of Democracy: Some observations on the Adoption Program by DOT


Department of Tourism (DOT) was inspired by the ‘Campaign Clean India’ launched by the Govt of India and wanted to improve the basic infrastructure and undertake promotion and publicity with private investment.

DOT had identified  46 destinations including Venkatappa Art Gallery subsequent to the  recommendations of Karnataka Tourism Vision Group (KTVG) report and further discussions with Government of Karnataka and KTVG.  DOT made made a request to the govt to create a committee to approve proposals from the Corporate sector to provide the to provide facilities such as basic amenities, signages, interpretations centres, tourist friendly vehicles, proper guides etc., under the adoption programme.

What were the protocols followed in this identification? On what basis were these 46 destinations decided?Where are the records? In the preamble to Govt Order No. TD 98 TTT 2014 it also states that “the list is not an exhaustive one and corporates/PSUs can suggest any destination they want to adopt.” Are Corporates more than equal citizens of Karnataka?

On the basis of this request from Tourism Department Govt Order No. TD 98 TTT 2014 Bangalore, Dated 16-09-2014 was issued.

Annexure II lists the initiatives/activities envisaged under the programme stating that other things could be added on with the approval of the Project Implementation Committee. This list doesn’t include transfer of management or exclusive curating of programmes, exhibitions or removal of existing facilities benefitting the public or existing users or co-branding. Was approval for this sanctioned by the committee?

KTVG members have stated in the press and on social media that the adoption program is an initiative of the government and came into being on 16.09.14. The Expression of Interest document issued by iDeck on behalf of KTVG dated 19.01.2015 states that the projects were identified based on the inputs from KTVG and Govt on 30.04.14 soon after KTVG released its recommendations.

Approval of Tasveer Foundation and others – The process

The Govt order states that there will be a 13 member Project Implementation Committee set up to examine and approve proposals. It does not name Mr Mohandas Pai or any vision group members or KTVG or iDeck  so why is iDeck handling the whole bidding process on behalf of KTVG? Please note it is on behalf of KTVG not Government of Karnataka.

Conflict of Interest:

iDeck’s document soliciting expression of interest clearly states that “It shall be deemed that by submitting the Application, the Consultant has:  acknowledged that it does not have a Conflict of Interest” (2.5e EOI 19.01.15) and “A Consultant shall not have a conflict of interest that may affect the Empanelment Process or the Services (the “Conflict of Interest”). Any Consultant found to have a Conflict of Interest shall be disqualified.” (2.12b EOI 19.01.15)

“iDeCK / DOT may reject the Application, withdraw the LOE, or terminate the Contract, as the case may be, without being liable in any manner whatsoever to the Consultant, if it determines that the Consultant has directly or indirectly or through an agent, engaged in corrupt practice, fraudulent practice, coercive practice, undesirable practice or restrictive practice in the Empanelment Process. In such an event, iDeCK / DOT shall be entitled to reject the Application submitted by agency.”

Four of the six MoUs signed have links to the members of the KTVG.

Abhishek Poddar – Tasveer Foundation – Venkatappa Art Gallery – It has been made public now that Kiran Mazumdar Shaw, a member of KTVG, is a board member of MAP, a division of Tasveer Foundation. Abhishek Poddar and Kiran Mazumdar Shaw had previously discussed setting up a private museum to display their private collections (Barthelemy)

Sangita Jindal – JSW Foundation – Bengaluru Museum

Sangita Jindal – JSW Foundation – Sandur Manganese Ore – Ranganathittu.  (Sattiraju Seshagiri Rao is a director on the boards of Sandur and 3 JSW companies.)

BCIC Representative – BCIC – Lalbagh

Is there not a conflict of interest wherein KTVG invites the bids and gets to decide who the bid goes to?


  1. Why is iDeck handling this process? Is there a circular out stating how iDeck was hired to manage this process? iDeck consists of the Govt, IDFC and HDFC. Were they hired because Mohandas Pai and HDFC Directors sit on the board of his company Manipal Global Education Services Private Limited?
  2. iDeck in its document (Plan for Coastal Karnataka) states that 50 crores has been allocated by the govt to conduct this process. This money and the spending of it has to be accountable to the public and yet this whole process has been done with a secrecy that is appalling. It seems that the accountability is only towards KTVG. (1.1.2 Preparation of Coastal Master Plan, Request for Proposal document)
  3. Proposals are invited only in English even though this is an initiative of the Government of Karnataka. It puts local organisations at a disadvantage.
  4. ‘This would be popularised either by one to one meeting with Corporates or by having road shows’(Govt order No. TD 98 TTT 2014) Was this process really open then? Or was it just for friends of KTVG?

Evaluation Criteria for Tasveer Foundation:

  1. There is no public info available on Tasveer foundation including its financial capacity to undertake such a project. It lacks transparency.
  2. It is also new. It has no track record of doing any work.
  3. On what basis was it chosen since it is separate from Tasveer gallery? What was the criteria applied in the selection?
  4. Where is the DPR put forward by Tasveer Foundation?
  5. The govt order states that “a proposal needs to be submitted and a joint inspection would be conducted by Joint Director (PMU) the Nodal officer of the dept and the nominated member from corporate/psu.” Was this done for any of the sites where the MoUs were signed? Where are the minutes/ reports by the Nodal Officer?
  6. How many people will lose their jobs? How many new jobs will be created? In the CAG Report it states that over 5 years only 2500 jobs were created as against target of 29-41 lakh. What measures will be taken not to repeat it? The CAG Report states “neither the quantum of investments nor creation of employment opportunities as promised by private sector had translated into reality.” for the period 2010-2015 and “employment generation was not even one per cent of the target fixed under the policy.” (p37. CAG)
  7. As per the order ‘Corporates under CSR programme shall earmark the funds separately for implementation and maintenance of programme and financial and physical progress of the programme shall be reported to the Director of Tourism.’ – Tasveer Foundation is not a corporate entity and yet entered into the MoU. Did other similar trusts and voluntary groups not miss the opportunity as this was announced only as ‘in collaboration with corporates’? On what criteria was this condition put forward – because most members of the KTVG are corporates?

MoU – Issues:

  1. In Point No 3.5 in the MoU it is stated that funds from the ticket collections will be invested back. What about other funds that are generated such as when works of art that belong to Venkatappa Art Gallery are loaned to other museums?
  2. Risk: If anything is damaged – the Collection for example – why is the govt and in turn the public having to pay for it?
  3. Period: The MoU states that parties have the right to negotiate extensions to the adoption time which means they can have it in perpetuity. Please note that the +5 years extension is a minimum and not a maximum.
  4. In Govt order No. TD 98 TTT 2014 it states ‘Co-opt members and stakeholders whose consent or expertise is required for approval of the project.’ Were any stakeholders or anyone’s expertise solicited for the Venkatappa Art Gallery adoption?


  1. In the govt order no.TD 176 TTT 2014, dated 1st Jan 2015 it is stated that “Tourism Department has the advantage of being the owner of land at prime tourist locations, which if utilized appropriately can optimize private investment.”
  2. In the govt order no.TD 176 TTT 2014 dated 1st Jan 2015 Karnataka Tourism Infrastructure limited was approved to be set up. It came into being on 27th July 2015.  The blurb on the company states that it is into real estate activities with own or leased properties. The Tourism Policy states the intention for the creation of this company – “All land assets that are currently under the governance and administration of the Department of Tourism would vest with the Company. Further, the Company would become responsible 
for the, leasing, renting, concessioning, etc. of these land assets. (p19 Tourism Policy 2015-2020)
  3. Why does the govt have only a 26% stake in it? Does this then mean that the private players with a 74% stake have more ownership of land that is actually the commons? Is this not what you call a sell off? The State is supposed to be a custodian of public spaces not a real estate dealer.


MAY 2013 Congress government formed
OCT 2013 KTVG Formed, met over 7 sessions
DEC 2013 KTVG Meetings ended.
JAN 2014 Recommendations of KTVG released
APR 2014 GoK and KTVG identify 11 projects for adoption
MAY 2014 CSR Policy for Sua Explosives comes into effect
SEP 2014 Govt circular on Adoption (Order No TD98 TTT 2014 Dated 16.09.14)
JAN 2015 Establishment of KTIL (Karnataka Tourism Infrastructure Limited) circular issued. (Order No TD176 TTT 2014 Dated 01.01.15) Govt has only 26%s take.
19 JAN 2015 Expression of Interest solicited by iDeck on behalf of KTVG.
26 MAR 2015 Tourism Policy 2015-2020 comes into effect
30 APR 2015 Karnataka Tourism Trade (Facilitation and Regulation) Act 2015 comes into force.
16 JULY 2015 Mou signed between Tasveer Foundation, Department of Archaeology, Museums and Heritage and Department of Tourism
16 JULY 2015 Press release about MoUs signed.
27 JULY 2015 Karnataka Tourism Infrastructure Limited comes into being.

2 thoughts on “PPP and the subversion of Democracy: Some observations on the Adoption Program by DOT

  1. Pingback: Missing the Heritage Bus | Illegibilities

  2. Pingback: A Broke Government of Karnataka And Other Myths: Has Funding Always Been The Red Herring? | Illegibilities

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