Party : Defendants
Deponent :Rowan Tilly : 1st
Sworn :        March 1999
Exhibit : “RT1”

IN THE HIGH COURT OF JUSTICE	1998-M-NO 1180
QUEENS BENCH DIVISION
BETWEEN
	MONSANTO PLC 	Plaintiff

-and-

(1) ROWAN TILLY
(2) JO HAMILTON
(3) KATHRYN TULIP
(4) MELANIE JARMAN
(5) ZOE ELFORD
(6) ANDREW WOOD
(sued on their own behalf and on behalf of all the other members or
	representatives of "genetiX snowball", an unincorporated association) 	Defendants



AFFIDAVIT OF ROWAN TILLY



I, ROWAN TILLY, of 43 Gardner Street, Brighton, Sussex affirm and say as follows:

1.	I make this affidavit from facts within my own knowledge except where otherwise stated. There 
is now produced and shown to me a paginated exhibit “RT1” containing copy documents to 
which I shall refer.

2.	On 4 July 1998 I entered  a farm at Shirburn, Oxfordshire and uprooted one GM plant.

3.	I have an honours degree in geography and environmental biology from  Oxford 
Brookes University.  I have been a participator in the genetiX snowball campaign since 
its conception.  I currently participate in the genetiX snowball coordinating group.

4.	I was involved in the run-up to genetiX snowball's conception and therefore participated 
actively in the process which shaped the campaign and set the boundaries.   I was a 
participant of an “affinity group” whose purpose was to work together and support each 
other in taking nonviolent direct action in situations where such action would be 
necessary, urgent and likely to receive public support.  I refer to section 5.1 of the 
Handbook, exhibit CLH11 to Catherine Hooper’s second affidavit.

5.	The affinity group came together during a gathering at a workshop about the swords into 
ploughshares tradition, having been inspired by the Seeds of Hope Ploughshares action, 
of which I had been a support participant.   We decided to form an affinity group which 
would explore the potential of using methods used by the ploughshares tradition in an 
environmental context.  

6.	The action taken by the four women of Seeds of Hope Ploughshares caused £1.6 million 
of damage to a warplane which was to be exported to Indonesia.  This was a 
considerable amount of damage to the plane, and risk to the women who took hammers 
to the plane; they were arrested and remanded, but were acquitted because the jury 
recognised that their actions were justified because the plane was likely to have been 
used in genocidal attacks on East Timor.  

7.	Looking at the dangers of GM crops to our environment, to health and to the production 
of food at a global scale it seemed to me that removing GM crops would also be 
legitimate. I refer to the third paragraph onwards of section A 1.2 of the Handbook, 
exhibit CLH11 of Catherine Hooper’s second affidavit.  

8.	We also intended to ourselves take nonviolent action adopting methods arising from our 
discussions.   Our affinity group spent more than a year studying and evaluating these 
ploughshares methods and other methods used in the peace movement.

9.	I had been aware of the dangers of GM crops since 1996.  During affinity group 
meetings we identified genetically manipulated (GM) crops as being a critical issue 
threatening the environment and food production.  Many organisations were already 
campaigning against GM crops but there was no indication that GM crops and food 
would be stopped.  

10.	I wanted to be absolutely sure of the seriousness of the dangers of GM crops before 
planning nonviolent action on this.  At first I consulted at length with Dr. Ricarda 
Steinbrecher, who has had fifteen years of experience working as a genetic scientist, 
working with the University of Liverpool, to find out just how critical this issue was.  
She explained how GM crops could endanger the natural environment, threaten food 
security and human health.  I wanted to get other opinions about the issue so I set about 
attending presentations, consulting with and interviewing other experts on the various 
aspects of GM crops.

11.	As well as attending presentations given by Dr. Steinbrecher, I also attended 
presentations by other scientists in the UK. On 7 June I heard Dr. Michael Antoniou, a 
genetic scientist at Guy's Hospital; Dr. Mae Wan Ho, biologist, reader at the Open 
University and John Durrant, Professor for Public Understanding of Science, University 
of London and Director of the Science Museum. 

12.	On 23 April 1998 at Westminster I also attended presentations or interviewed:
a)	Alan Simpson, MP for Nottingham, about the inadequacies of British regulations to 
safely control GM crops and the likely impact of GM crops on British agriculture 
and economy.

b)	George Monbiot, a journalist and broadcaster, about the way in which GM crops 
confer increasing power to trans-national biotechnology corporations such that they 
are able to control our lives by controlling our food.  

c)	Helena Paul of the Gaia Foundation about the impact of patents on living organisms 
and how the patenting of GM crops confers economic power to a few trans-national 
corporations which will result in further impoverishment and dependency of farmers 
in developing countries, thus undermining food security.   

13.	In April 1998 I attended a conference on GM crops in Budapest where I heard 
presentations and conducted camcorder interviews with representatives of non-
governmental organisations from Ukraine, Poland, Hungary, Croatia, Lithuania.  They 
reported that Eastern Europe was becoming a dumping ground for unwanted and 
dangerous GM crops which were rejected by Western Europe; they feared that GM crop 
producers would take advantage of weaker regulations or enforcement in Eastern 
Europe. Also in Budapeste I consulted and interviewed Robert Vint, Coordinator of the 
Religious Environment Education Project, who spoke about GM crops in relation to 
ethics, morality and the principle religions.  He explained how his discussions with 
religious leaders had shown that their knowledge and understanding of this issue was, so 
far, extremely limited, such that none of them had been able to work out a position on 
the issue.

14.	In May 1998, as a representative for The Women's Environmental Network, I attended 
the United Nations Convention on Biological Diversity in Slovakia and interviewed on a 
camcorder a number of experts who were able to speak and answer my questions on the 
various related aspects of GM food and crops, these were: 
a)	Dr. Vandana Shiva, Director of the Research Foundation for Science, Technology 
and Ecology, Delhi, India, who spoke about the dangers of GM crops and their threat 
to biodiversity, farmers and food security in India; 
b)	Christine von Weizsacker, a biologist with four years of active involvement in  the 
United Nations Convention on Biological Diversity and the Biosafety Protocol, who 
spoke about the failure of international conventions to control or safely regulate GM 
crops; 
c)	Patrick Mulvany, Food Security Policy Adviser of Intermediate Technology 
Development Group, UK, who spoke about the impact of GM crops on agriculture in 
Britain and developing countries, the way that this impedes sustainable and secure 
agriculture and the threat to biodiversity; 
d)	Hope Shand, Rural Advancement Foundation International in USA, spoke about the 
adverse effect of the so-called “terminator” gene on biodiversity and food security; 
e)	Dr. Tewolde Berhan Gebre Egziabher, Director of the Institute of Sustainable 
Development, Ethiopia; spokesperson for the United Nations Africa Group on 
Biosafety, the United Nations Convention on Biological Diversity and the Food and 
Agriculture Organisation; Manager of the Environmental Protection Agency of 
Ethiopia; who spoke about the impact of GM crops on Africa and explained why 
such crops would be inappropriate for farming in African nations such as Ethiopia.  

15.	These interviews were significant in forming my view that the nonviolent action I took 
at Model Farm was necessary and urgent.

16.	I also read widely from many articles and briefings written by scientists and 
campaigners.  

17.	In all my aforementioned research and consultations I could find no arguments to 
convince me that GM crops were either necessary,  safe nor an effective way to produce 
crops.  On the contrary I was firmly convinced that these GM crops were not wanted by 
the British public, or people in Eastern Europe, that they would not improve crop 
production, that they were a threat to biodiversity, public health and food security in the 
UK, throughout Eastern Europe, Africa, India and probably elsewhere in the world and 
finally that the dangerous effects of their release would be irreversible.  

18.	In these circumstances I felt that nonviolent direct action would be a legitimate action to 
take against GM crops. I knew from my own experience of being part of Seeds of Hope 
Ploughshares, that nonviolent direct action could be extremely effective and although 
clearly involving some risk, it is not necessarily illegal. 

19.	Since genetic engineering of plants was still in its infancy, both in terms of its scientific 
development and in commercial production,  most of the experts I had consulted held 
the view that it would be possible to stop GM crops before it has too much hold over 
agriculture and the economy.  However, once GM crops become widely accepted and 
established it will be too late for two main reasons: too late in a political sense in that it 
would be hard to reverse a decision with so much economic muscle; too late in the 
scientific sense in that once plants which have been genetically engineered have been 
released into the environment, it is impossible to recall them.  These arguments made 
absolute sense to me and instilled in me a sense of absolute urgency to try to stop GM 
crops before they could be accepted and established.  

20.	I am aware of how long it takes to effect even the smallest change to the status quo 
through my contact with many campaigners on this issue and other environmental 
issues, and through my own experience of having previously worked as a campaigner 
for three years at Women’s Environmental Network.  Using traditional campaigning 
methods which ask or put pressure on those in power - either government or 
corporations - to make appropriate changes are very slow.  On the other hand, economic 
forces operate very rapidly and put enormous pressure on governments to follow suit.  It 
was very clear to me that we do not have that much time if we are to stop GM crops; this 
was, and continues to be, a very clear case for urgent and drastic action of the kind that 
would literally remove the problem.

21.	Nonviolent direct action does not depend on asking those in power to act on behalf of 
ordinary people; by taking nonviolent direct action we would be going directly to the 
source of the problem and ourselves doing what we believe urgently needs to be done - 
safely removing the hazardous GM plants.  My involvement in ploughshares has led me 
to reflect carefully on whether the public would agree that such action would be 
reasonable given the extremity of the circumstances.  As part of the group I took part in 
research and discussions reflecting on this question: whether the public were giving their 
informed consent to GM crops.  

22.	The findings of other campaigns, such as Greenpeace, and my own experiences of 
distributing information leaflets outside supermarkets, which opened up discussions 
with customers, led me to believe that most people did not even know of the existence 
of GM crops or food let alone understand the implications of them.  This raised a further 
question in my mind: why were GM crops and food were being released without the 
public’s knowledge let alone their understanding of the enormous implications.  At this 
time a MORI poll was published which found that 77% of people wanted GM foods to 
be banned.  In either case, the UK government is clearly acting undemocratically 
without the informed consent of the public.

23.	The best democratic response to this situation would be to put a moratorium in place 
which would allow time both for the risks to be evaluated by independent scientists and 
to allow for informed public participation in deciding whether GM crops should be 
released.  As part of the group we consulted with experts, such as Dr. Steinbrecher, 
about how long such a moratorium should be to ensure that both these things could 
happen; the unanimous response was five years.  In accordance with nonviolent 
principles I believed that calling for a limited moratorium would also allow for the 
possibility that we might be wrong so that, should this be the case, progress in this field 
would not be excessively limited.

24.	By taking non-violent direct action to remove the GM crops we would be attempting to 
literally put in place a five year moratorium in order that the democratic process of 
assessing whether GM crops should be accepted could take place.  Such a process 
should have already taken place before the GM crops were in our midst and spreading 
genetic pollution.  I therefore believed that in these circumstances and with these 
intentions our non-violent action would be reasonable and democratic.

25.	I also believed that such action could be very effective in stopping the continued release 
of GM crops into the environment before the biotechnology corporations had too much 
of a hold over agriculture and our economy.  Furthermore, I believed that if we could 
gain a moratorium on GM crops in Britain, we may be able to influence the rest of 
Europe, which in turn could have global influence.  Finally, and most importantly, by 
raising the issue in the public eye, our action would make ordinary people aware of the 
dangers of GM crops and that it is possible - and a responsibility - for them to help to 
remove the GM crops.

26.	After discussing various ways of removing the crops, we decided on an action that 
would combine the methods of ploughshares with a campaign from the 1980s called 
Snowball, which called on people to cut the fences at nuclear weapons bases in Britain.  
I refer to the first two paragraphs of section A 1.2 of the Handbook, exhibit CLH11 of 
Catherine Hooper’s second affidavit.   We wanted to invite people to join in with our 
campaign; we felt it would make our action more democratic if many people pulled up a 
few plants each, rather than a small group of people pulling up lots of plants.  This 
formed the basis of the genetiX snowball campaign.  

27.	Some members of our affinity group, including myself, formed a new group (which I 
will refer to as "the coordinating group") to steer and coordinate the campaign .  The 
original group continued and launched the genetiX snowball campaign with the first 
non-violent action.  Both groups operate by consensus and each person takes a 
leadership role at various times according to their strengths, skills, energy levels and so 
on.  

28.	I wanted to draw very clear boundaries around the campaign: what we wanted to 
achieve, how we intended to do this, making sure that our means and ends were 
consistent.  The coordinating group laid the framework for these boundaries down in the 
form of a pledge which I edited from the contributions of others in the group; this was 
completed before we took our first non-violent action at Model Farm.  

29.	At page 1 of RT1 a true copy of The Pledge which I signed on the day of the action.  
The coordinating group decided to provide a full explanation of the campaign in the 
form of a handbook which would serve as a manual and reference guide to anyone who 
wanted to join.  A handbook would also ensure that the campaign, and ourselves, as 
organisers of the campaign, would be accessible, thus making it possible and easy for 
other people to join in.  I took on the task of editing the handbook and writing several 
sections; this was already in a draft form before we took our action at Model farm.

30.	The first three sections of the handbook sets out our motives, aims and objectives, the 
ground rules of safety, non-violence, openness and a willingness to accept the 
consequences of actions.  

31.	Section 3.2.2 of the handbook, (exhibit CLH11), demonstrates that the campaign asks 
for "anyone and everyone to be respected" and has no intention of causing harm to the 
companies or any individuals who are part of the companies: "Keep in mind that the 
aims of the campaign are to halt the bad practices of the companies; not to target the 
companies themselves or to see them as enemies."  

32.	Comments in paragraphs 8-14 of Catherine Hooper’s second affidavit suggest that our 
actions were aimed at Monsanto and harming Monsanto. This is not true. Our actions 
were aimed at GM crops and GM crops alone.

33.	I produce at page 12 of RT1 a true copy of an article I wrote which was published in 
Peace News, issue no. 2431, dated November 98 which reports "....neither do we want to 
demonise the companies involved with GE (genetic engineering).  Seeing the companies 
as The Enemy only underlines their power and feeds the myth that the enemy is 
something entirely external and separate from ourselves.  It also suggests that companies 
such as Monsanto, Novartis, Zeneca - all transnational giants - can be easily identified 
and pinned down.  Corporate networks are extremely complex and opaque so that 
tracking their accountability is extremely difficult.  We aim to expose and challenge the 
bad practices of the companies but we will also need to reach the real people with 
beating hearts, as opposed to faceless corporations, who are implicated either actively or 
passively by allowing it to happen."  

34.   I refer to the second paragraph of section 5.7.1.1 of the handbook.  The site at the 
garden centre, owned by AgrEvo, was intended to be the location of the first genetiX 
snowball action.  We rejected this site because it was in such close proximity to the home of 
the elderly owners;  an action here would have felt too intrusive on their lives.  If these had 
been the circumstances at Model Farm I would have rejected the Monsanto site for the same 
reason.  One of our group had identified Monsanto's test site at Model Farm to be well away 
from the farmer's home and had also met with the farmer, finding him to be unperturbed by 
the unannounced visit and questions about GM crops.  

35.	We recognise that we may be causing damage to the companies' GM plants, but this is 
unavoidable and necessary in the circumstances.  I do not believe that Monsanto is 
inherently a bad company.  I consider it possible for them to employ their expertise and 
substantial resources in ecologically sustainable organic agriculture or production of 
beneficial chemicals which minimise impact on ecology.  It is also possible for them to 
change the structure of the company and its methods; for example: to scale down their  
influence to one bio-geographical region, to be open and accountable, to encourage self-
determination of farmers and to have no part in the patenting of life.

36.	The statement I made (which appears in section A 4.1.2 of the handbook) explains my 
motives, the non-violent action I intended to carry out and the reasons for it.  At the time 
of our action a signed and dated copy of the statement was handed to the farmer, the 
company and I gave one to the policeman who arrested me.  I did carry out the action as 
intended but also helped the others to put their plants in bags and seal them up. Section 
4.2 of the handbook gives a true account of the action.  I refer to exhibit RT2 which is 
the small garden fork I used to dig up one GM plant and on which I inscribed "Bless our 
food.  Bless this land".

37.	Since the action at Model Farm I have taken part in three out of the four genetiX 
snowball actions which have taken place.  I have continued to work as part of the 
coordinating group; giving talks about genetiX snowball, inviting people to form local 
genetiX snowball groups and organise nonviolent actions.  I continued to work on 
producing the Handbook which was published in September 1998 in time for 
distribution at the training for the fourth genetiX snowball action known as "genetiX 
harvest".  It was publicly launched in December 1998.  I am a participant of two local 
genetiX snowball groups and will be offering support to any new genetiX snowball 
groups that form in the south east region.  

38.	The quote in paragraph 9 of Catherine Hooper’s second affidavit - “get all the plants out 
of the ground” - is taken out of context from a paragraph which looks at the possible 
ways in which gXs could be effective. Section 2.2 of the handbook calls for "the 
removal by government agencies, farmers or the biotechnology companies of all GM 
plants already existing."  I would prefer that the GM plants be removed by the 
aforementioned agents, whom our society holds to be responsible for safe production of 
resources.  If and when those held responsible fail us, other people need to take up the 
responsibility as their civil duty.  

39.	The passage 5.7.2 outlines what is possible and emphasises the importance of bringing 
the issue into the public domain because “it is here, not in the field, that the action can 
realise its potential power”.  This is in recognition that pulling up all plants, especially if 
this is done by only a handful of people, will not, of itself, solve the problem unless 
there is a corresponding change from those in power, either government or corporation.  
There is a limit of 100 plants for each person - the only way to remove all GM plants as 
part of the genetiX snowball campaign is by involving a large number of people.  
Greater participation indicates public recognition of the importance of this issue,  the 
need for a moratorium and the removal of all existing GM plants.  I chose to pull up one 
plant, symbolic of the first snowball action because I believed that this would be 
sufficient to bring the issue into the public domaine.  It is my intention to continue to 
remove GM plants or products according to the number of snowball actions which have 
taken place, thus corresponding with growing participation of new people in the actions.

40.	Paragraph 10 of Catherine Hooper’s affidavit states that “the whole point of the exercise 
was to strike at Monsanto GM crops as appears from paragraph 4.2 of the Handbook and 
video film…”. Section 4.2 of the Handbook gives a true account of the number of GM 
plants the defendants chose and intended to pull up but does not clearly report on how 
many plants were actually removed.  Those who wanted to pull up a smaller number of 
plants, managed to achieve their aims, whereas those who intended to pull a larger 
number, were not able to pull up all that they wanted.  I intended to pull up only one 
GM plant and I did pull up no more and no less than one GM plant.

Sworn this	day of March}
1999 at	}
	}
	}

before me			


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