India has been consistently objecting to the methodology adopted by WHO to project excess mortality estimates based on mathematical models. Despite India’s objection to the process, methodology and outcome of this modelling exercise, WHO has released the excess mortality estimates without adequately addressing India’s concerns. India had also informed WHO that in view of the availability of authentic data published through Civil Registration System (CRS) by Registrar General of India (RGI), mathematical models should not be used for projecting excess mortality numbers for India. Registration of births and deaths in India is extremely robust and is governed by decades old statutory legal framework i.e. “Births & Deaths Registration Act, 1969”. The Civil Registration data as well as Sample Registration data released annually by RGI has been used by a large number of researchers, policy makers and scientists both domestically & globally.

RGI is over a Century old statutory organization and is assisted by Chief Registrars of states/UTs and about 3 lakhs Registrars/Sub-Registrars across the country. Based on reports submitted by states/UTs, National reports - Vital Statistics of India based on Civil Registration System (CRS) are published annually by RGI. The last such National Report for the year 2019 was published in June 2021 and for the year 2020 has been published on 03^rd May 2022. These reports are in public domain. India firmly believes that such robust and accurate data generated through Legal Framework of a Member State must be respected, accepted and used by WHO rather than relying on less than accurate mathematical projection based on non-official sources of data.

India had pointed out the inconsistencies in the criteria and assumption used by WHO to classify Countries into Tier I and II as well as questioned the very basis for placing India into Tier II countries (for which a mathematical modelling estimate is used). India had also underlined the fact that given the accuracy of the Mortality Data collected through an effective and robust statutory system, India doesn’t deserve to be placed in Tier II countries. WHO till date has not responded to India’s contention.

India has consistently questioned WHO’s own admission that data in respect of seventeen Indian states was obtained from some websites and media reports and was used in their mathematical model. This reflects a statistically unsound and scientifically questionable methodology of data collection for making excess mortality projections in case of India.

Throughout the process of dialogue, engagement and communication with WHO, WHO has projected different excess mortality figures for India citing multiple models, which itself raises questions on the validity and robustness of the models used.

India objected to the use of Global Health Estimates (GHE) 2019 in one of the models used by WHO for calculating excess mortality estimates for India. GHE itself is an estimate. Therefore, a modeling approach which provides mortality estimates on the basis of another estimate, while totally disregarding the actual data available within the Country exhibits lack of academic rigour.

The test positivity rate (another key variable used by WHO) for Covid-19 in India was never uniform throughout the country at any point of time. Such a modeling approach fails to take into account the variability in COVID positivity rate both in terms of space and time within the country. The model also fails to take into account the rate of testing and impact of different diagnostic methods (RAT/RT-PCR) used in different geographies.

Owing to its large area, diversity and a population of 1.3 billion which witnessed variable severity of the pandemic both across space and time, India consistently objected to the use of “one size fits all”, approach and model, which may be applicable to smaller countries but cannot be applicable to India. In one of the models, India's age-sex distribution was extrapolated based on the age-sex distribution of excess deaths reported by other countries incomparable in terms of demography and size with India and India’s request to use the available data from authentic Indian source was not considered.  

The model assumed an inverse relationship between temperature and mortality, which was never substantiated by WHO despite India’s repeated requests.

In spite of these differences, India continued to collaborate and coordinate with WHO on this exercise and multiple formal communications (10 times from November 2021 to May 2022) as well as numerous virtual interactions were held with WHO.

The CRS data of 2020 published by RGI on 3^rd May 2022 clearly reveals that the narrative sought to be created based on various modelling estimates of India’s Covid-19 deaths being many times the reported figure is totally removed from reality.  We now have actual figures of deaths (i.e. all cause mortality) for 2020. The historical figures of all cause mortality for the years 2018 and 2019 are also available in public domain. Since RGI figures capture “all cause mortality” for a particular year, mortality figures of COVID 19 could at best be considered a sub-set of the “all cause mortality” in that year.  Therefore, reliable figures released by the Statutory Authority captured through a rigorous process across the country are presently available for analysis and support in policy planning. It is a known fact that modelling, more often than not, can lead to over-estimation and on few occasions, these estimates may stretch to the limits of absurdity.

The data released by the Civil Registration System (CRS) report-2020 under the aegis of the office of Registrar General of India (RGI) was shared with WHO for preparation of excess mortality report. Despite communicating this data to WHO for supporting their publication, WHO for reasons best known to them conveniently chose to ignore the available data submitted by India and published the excess mortality estimates for which the methodology, source of data, and the outcomes has been consistently questioned by India.

 

Year	Estimated Deaths	Registered Deaths	Level of Death Registration	Increase in Number of Deaths registered over previous years
2018	82,12,576	69,50,607	84.6 %	4,86,828
2019	83,01,769	76,41,076	92 %	6,90,469
2020	81,20,268	81,15,882	99.9 %	4,74,806

 

Ref.: Vital Statistics of India based on the CRS 2020, office of RGI.

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HFW/Rebuttal on excess mortality estimates by WHO/5 May 2022/4

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