10-Point Demand Charter from a Public Health Perspective: Govt of India must ensure an ethical, gender-neutral and people-centred HPV vaccination policy
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Govt of India must ensure an ethical, gender-neutral and people-centred HPV vaccination policy across India
10-Point Demand Charter from a Public Health Perspective
20th May, 2026: India is in the midst of a national HPV (Human Papillomavirus) vaccination programme as a major preventive strategy against cervical cancer. Rolled out since late February and primarily directed at adolescent girls, it aims to reduce the incidence of cervical cancer when they become adults. Considering the many complexities involved in this issue, the National Alliance of People's Movements (NAPM), through the All-India Feminist Alliance (ALIFA) and National Health Rights Forum insists that the Govt. of India and all state governments must ensure an ethical, gender-neutral and people-centred HPV vaccination policy across India. The Govt. also needs to transparently evolve a scientific and comprehensive cervical cancer prevention strategy, re-affirming the principles of free, prior and informed consent and voluntary vaccination.
Although the incidence of cervical cancer has been declining in India, this remains a major public health issue with an incidence of 18.7 per 100,000 women. It is estimated that nearly 80,000 women, predominantly from the poorer and rural populations, die of cervical cancer in India annually. As such, cervical cancer merits public health attention and preventive strategies, provided they remain grounded in broader health needs of the population.
Since 2006, over 500 million doses of HPV vaccines have been administered globally, without major safety concerns. Designed to target high-risk strains of the human papillomavirus, which are causally associated with the development of cervical cancer, vaccination has been used and is being used in multiple countries as a major preventive strategy against cervical cancer. A broad global scientific consensus supports HPV vaccination, as being effective in reducing high-risk HPV infection, one of the most common sexually transmitted infections and precancerous lesions that it would lead to in the affected individuals.
HPV vaccination is strongly recommended in most countries and is also mandated in other countries. While it was initially administered for adolescent girls, with increasing awareness about child sexual abuse as well as sexual relations among men, there is a shift towards a gender-neutral policy. Most experts agree that vaccination is only one part of the comprehensive prevention strategy. Long-term follow-up, regular screening and speedy detection play an equally important role in preventing the development of cancer that can occur any time in the subsequent decades. Prevention of cancer resulting from HPV infections therefore requires an effective public healthcare infrastructure that can undertake these tasks.
Given that the public healthcare infrastructure in India is deprived of personnel, funds, and infrastructure, the All-India Feminist Alliance and National Health Rights Forum, have several concerns about the ethics and effectiveness of this ongoing vaccination programme. They are related to: informed consent, coercion of frontline workers, follow-up and screening after vaccination, women’s health services and primary health care, transparency in evidence and decision-making, and the influence of pharmaceutical and global health actors. These issues are critical to the effectiveness of the comprehensive HPV related cancer preventions.
First and foremost, close attention is required to the informed consent procedures in administering the vaccines. The Parliamentary Standing Committee documented serious violations of the informed consent procedures in relation to the 2009 HPV vaccine demonstration project. Like for any vaccine, consent for this vaccination is also voluntary and not mandatory. The 2009 project, implemented in the rural and adivasi areas, obtained consent from hostel wardens rather than parents of the adolescent girls. We have little evidence to indicate that the consent procedures have been strengthened afterwards.
Significant concerns exist about the adequacy of current operational mechanisms for proper delivery of HPV vaccination. HPV vaccination needs to be near universal in order for the gradual development of herd immunity, as in countries like Australia. In India, unlike the childhood vaccines that are integrated with public health community linkages, HPV vaccine is being administered for school going girls, regarding whom the public health outreach is quite limited. A large number of girls, from marginalized and excluded communities, are also out of school and are likely to be left out of the vaccination.
Some of our major concerns are:
Firstly, there aren’t adequate mechanisms of obtaining informed consent which needs to be done through written and verbal communication in local languages, along with informational videos for parents, guardians and the girls themselves. Using digital privacy platforms raises concerns about data privacy as well as exclusion of marginalized populations.
Secondly, coercion of frontline workers such as ASHAs, ANMs and school teachers to ensure coverage is a real concern. Reports from the ground suggest that in many states, the HPV vaccination is being implemented through the target driven approaches, turning the entire programme coercive rather than a programme of public health care. Frontline workers are being threatened with disciplinary action, rather than being given adequate time, support and remuneration for their role.
Thirdly, there is a lack of robust monitoring mechanism for vaccine related side effects and provision of related support, known as ‘Adverse Events Following Immunization’. As of now, there are no autonomous review bodies at the state or national levels, leave alone dedicated district level hubs to carry out in-depth, time-bound investigation about all serious adverse events / effects. Nor is there a mechanism for the provision of adequate medical and counselling support or provision of compensation for the affected recipients and families.
Fourth, the government has chosen Gardasil, manufactured by the multinational company Merck, setting aside the indigenously developed Cervavac, which is more sustainable, cost-effective and is safe, for reasons that the government has not made apparent. The HPV vaccination policy is being implemented without transparency and might prove to be a financial burden on the public health system.
Fifth, like the ‘family planning’ programme, this vaccination also is directed at the girls, ignoring the boys who also are likely to enter into sexual activity either voluntarily or in some instances, involuntarily. This targeting of the policy towards the adolescent girls will most likely reinforce the existing cultural prejudice about women’s bodies as the carriers of disease, leaving the men unaccountable and also unprotected.
In view of these multiple issues, concerns and problems, All India Feminist Alliance and the National Health Rights Forum places the following 10 demands before the government, as part of developing a comprehensive multi-dimensional strategy which integrates vaccination, screening and guaranteed access to treatment.
1. Public education about HPV:
The government should conduct a massive public education programme aimed at preventing HPV related cancers, along with vaccination programmes. It should spread information about the impact of Human Papillomavirus infections and its links to cervical and other kinds of cancer. Such an education must include the risk factors such as sexual abuse, multiple sexual partners, early marriages, personal hygiene, multiple child births, oral contraceptive usage etc. It should also alert that while women are much more at risk of developing cancers, the men often act as carriers of infection. That both boys and girls, between the ages of 9-14 (up to 26 years if they are not initiated into sexual activity) should be vaccinated against the infections caused by this virus. The age for vaccination should not be fixed at 14. Vaccination should, preferably, be in two doses, as in the rest of the world.
2. Free, Prior and Informed Consent:
In all instances of vaccination, informed consent must be obtained directly from the parents or legal guardians of every minor girl (or boy / child) proposed to be vaccinated, after adequate communication about the vaccine through audio or video. Consent forms must be prepared in multiple languages and in simple, clear language that can be understood by persons with varying levels of literacy. Where parents are non-literate, trained and authorized health workers must explain the process verbally and in full, and an independent witness must attest to the voluntary nature of the consent. Consent by institutional authorities, wardens, or teachers must be explicitly prohibited. Girls who are minors must be given age-appropriate information about the vaccine and its purpose, and their assent must also be recorded, alongside parental consent.
3. Voluntariness and Freedom from Coercion:
Participation in the programme must be entirely voluntary. No child (of any gender) or their family must face any direct or indirect pressure, inducement, or penalty for refusing vaccination. There must be no stigmatization of or discrimination against those who opt out. Instructions to this effect must be issued clearly and unambiguously to all programme personnel, including health workers, school staff, and district officials.
4. Comprehensive Adverse Event Monitoring and Response:
A transparent, well-resourced, and independent system for the surveillance, recording, investigation, and management of Adverse Events Following Immunization (AEFI) must be established and fully operational before the programme commences. The most well AEFI include: Soreness, swelling or redness at the injection site, headache, muscle or joint pain, dizziness, fever, nausea and rarely severe allergic reactions. This system must include:
(i) 24-hour interactive helpline accessible to parents, girls, and health workers;
(ii) rapid response medical teams at the district level;
(iii) mandatory reporting of all adverse events, however minor, to district and State AEFI committees;
(iv) independent causality assessment by qualified medical experts not associated with the vaccine manufacturers or implementing agencies; and
(v) prompt access to free medical care for all girls who experience adverse reactions. All AEFI data must be placed in the public domain on a monthly basis.
5. Independent Ethical Oversight:
The programme must be overseen by an independent Ethics and Oversight Committee that includes medical ethicists, public health experts, representatives of women's and child rights organisations, and community members. This committee must have the authority to pause or halt the programme, if safety concerns arise and must report publicly on a regular basis. A legally binding compensation framework must be established, where manufacturers remain financially liable for vaccine-related harm.
6. Transparency on Funding and Conflicts of Interest:
Full public disclosure must be made of all funding sources for the programme, the roles and financial interests of all implementing agencies and partners, and any arrangements with vaccine manufacturers. Any agency or individual with a financial interest in the outcome of the programme must be excluded from roles in its governance or oversight.
7. Community Awareness and Social Mobilisation:
A sustained community awareness campaign in all languages and formats must precede and accompany the programme, providing evidence-based information about HPV, cervical cancer, the vaccine's benefits and known risks, the consent process, and the AEFI reporting mechanism. This campaign must reach not only parents and girls but also teachers, community leaders, health workers, medical professionals, bureaucrats and local elected representatives.
8. Frontline workers should not be coerced:
HPV vaccination must be de-linked from any disincentives, targets, and coercive performance pressures for all frontline workers like ASHAs, Anganwadi workers, ANMs, teachers, employees etc. Punitive targets and threats of disciplinary action against frontline functionaries must be withdrawn. Involved frontline workers (ASHAs, ANMs, teachers), predominantly, who are predominantly women from rural, marginalized communities, must be provided adequate training for communication and counselling, institutional support, and fair remuneration for their additional work related to this programme.
9. Prepare a comprehensive cervical cancer prevention strategy:
Expand and improve screening services (such as Pap smear, Visual inspection, HPV testing etc.) as well as primary reproductive health care. Vaccination cannot replace the need for cervical cancer screening in India. Screening must be linked to accessible, affordable, and timely treatment pathways for any cases with pre-cancerous lesions or early cancer, to prevent delays between diagnosis and care, which can avoid suffering and deaths. Screening for cancer alone is insufficient without assured treatment access. These measures must be embedded in strategies for expanding women’s health services, and strengthening of public healthcare systems across various states, with adequate and timely budgetary allocations.
10. Gender neutral strategies:
HPV vaccination not only prevents cervical cancer but is also effective in preventing cancer of penile, anal and throat cancers in men. While the current focus on vaccination of girls reflects existing risks of serious disease, long-term strategies should consider gender-neutral vaccination approaches covering girls and boys, while also addressing broader gender norms, ensuring gender equity.
National Alliance of People's Movements (NAPM), All-India Feminist Alliance (ALIFA) and National Health Rights Forum hopes the Government of India and all state governments would consider all these concerns and suggestions in a spirit of constructive engagement and ensure an ethical, gender-neutral and people-centred HPV vaccination policy across India, while working towards a transparent, scientific and comprehensive cervical cancer prevention strategy, re-affirming the principles of free, prior and informed consent and voluntary vaccination.
Jointly issued by: All India Feminist Alliance (ALIFA) and National Health Rights Forum (Rashtriya Swasthya Adhikar Morcha) - pan-Indian initiatives of the National Alliance of People's Movements (NAPM)
Note: We acknowledge the inputs and insights from many feminist and public health activists and researchers and the conversations, sessions over two months and position by the People’s Health Movement, that has guided the framing of this response.