4 min readNov 12, 2026 05:53 PM IST First published on: Nov 12, 2026 at 05:53 PM ISTOn October 31, Hyderabad police reportedly rescued 43 women from an alleged egg-donation trafficking network. The women were recruited from various states and were promised Rs 20,000-30,000 for each donation cycle. According to the police, the accused were linked to 23 IVF centres in the city. The police also seized Humog HP 150 IU, a prescription drug used for ovarian stimulation, along with two other drugs.This is not an isolated incident. In 2022, a 16-year-old girl in Erode, Tamil Nadu, alleged that her family had forced her, over four years, to sell her eggs to hospitals in Tamil Nadu and other states. In 2023, four people were arrested in Varanasi for taking a 17-year-old to an IVF centre after tampering with her Aadhaar card and presenting her as a married woman. These cases reveal troubling commonalities: The involvement of brokers, the targeting of economically vulnerable women, the use of falsified documents, and fertility facilities that apparently overlook the circumstances in which women are recruited.AdvertisementOn paper, India protects egg donors well. Under Section 27 of the Assisted Reproductive Technology (Regulation) Act, 2021, only registered ART banks can screen donors and provide them to clinics. Clinics must source gametes only from those registered ART banks (Section 21(b)). A woman may donate only once in her life, only between the ages of 23 and 35, and no more than seven eggs may be retrieved from her.The law also shuts out middlemen. Section 33 bars medical practitioners from using intermediaries to find donors. A first offence draws a fine of Rs 5-10 lakh, while a repeat offence draws three to eight years in prison and a fine of Rs 10-20 lakh. The law, therefore, does not permit brokers to procure women for egg donation.Nevertheless, brokers continue to recruit women across state lines for egg donation. One possible reason is the gap between the demand for donor eggs and the limited pool of women legally eligible to donate. Also, the number of registered facilities and the estimated number actually operating vary considerably. As of October 31, the National ART and Surrogacy Registry listed 4,726 registered clinics and 940 banks. This is far below the academic estimate of around 40,000 clinics.How well is the law enforced? The government’s own records offer little information. The Department of Health Research’s 2025-26 annual report records the number of forms downloaded from the National Registry portal and the permissions granted, including no-objection certificates.AdvertisementAlso Read | Why must the dinosaur always be the bad guy?But its chapter on assisted reproduction is silent on inspections, violations, or prosecutions.Enforcement appears only in the description of the functions of the Appropriate Authority. Even the system for collecting donor information from clinics and banks has so far only been piloted.That gap matters. ART banks must keep donor records and update the National Registry. A functioning Registry should show whether a woman has donated before and stop repeat retrievals, the very safeguard that failed in Erode. Yet, little is known publicly about whether the Registry works, how often it is updated, or whether donor details are verified before each procedure.you may likeAccountability also rests with the Boards. Since courts can take cognisance of offences under the Act only on complaints by the National or State Boards or their authorised officers (Section 35), enforcement rests largely with these bodies. Rule 5 of the ART Rules, 2022, requires these Boards to submit annual reports to the government, yet the DHR report includes nothing from the National Board. The Union Health Ministry should publish these reports, and states should disclose details of inspections, suspensions, complaints and violations.The women recruited through brokers should be treated as witnesses, not accused. They must receive independent medical care, including monitoring for complications arising from hormone injections, as well as the 12-month health insurance coverage that Section 22(1)(b) of the Act requires.The Hyderabad, Varanasi, and Erode cases came to light through police raids or individual complaints, not routine regulatory inspections. Unless regulators check donor registers and hold clinics accountable, police operations will end with only a few agents in custody, while the institutions facilitating the trade continue to operate.The writer is a public health researcher working on gender justice, reproductive health, ARTs and surrogacy