Urgent need for new drug discovery regulation in homeopathy – An interview with Dr Rajesh Shah

Manish Bhatia
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Dr Rajesh Shah is interviewed by Dr. Manish Bhatia.

nov-2016-interview-rajesh-shah2Dr Rajesh Shah is a well-known homeopath, researcher and teacher and Director of Life Force Homeopathy in Mumbai, India. He is a pioneer of online practice and has treated patients from 180 countries.  He has developed many new homeopathic medicines, including those from biological sources such as HIV nosode, Hepatitis C nosode, Mycobacterium Tuberculosis nosode, and more. He has also conducted double-blind, placebo controlled Drug Provings, Clinical trials, experiments in animal models, as well as in-vitro studies with many new homeopathic medicines, doing this in collaboration with reputed institutions such as Haffkine Institute, ICT (UDCT), IIT-B, etc. He has introduced a scientific method of development of nosodes. His research papers are published in peer-reviewed, international journals. He has authored several books, including ‘My Experiences with Ferrum Metallicum’. He is one of the founders and Organizing Secretary of the Global Homeopathy Foundation, which conducted the World Homeopathy Summit in India in April 2015. He is on the advisory committees of CCRH under the Ministry of AYUSH, Govt. of India. Dr. Rajesh has initiated a petition to the Minister, AYUSH for setting up a mechanism for new drug discovery in homeopathy. The petition can be signed and supported at

Contact: Dr Rajesh Shah, MD (Hom) ~ Website: ~ Email:

MB: Dr. Shah, welcome to Hpathy! You are the epicenter of the movement to create nov-2016-interview-rajesh-shah6guidelines for introducing new homeopathic remedies in our pharmacopeias and Materia Medica, especially in India. Why and when did you feel the need to raise this issue on a wider scale?

RS: Thank you, Dr Manish for this interaction. I must start by saying that new drug discovery in homeopathy has been a neglected area, not only in India but also across the world. While I started working on developing new drugs in 1998, it was also observed that there were many issues in the making of old drugs as well, which needed to be addressed. If homeopathy has to stand up as a scientific system of medicine, the core sector of drug development would need serious attention.

As a strategic move, my initial focus is on the new drug discovery; eventually, we shall also look into the challenges with the old or existing drugs in the materia medica. If you want to know how my journey of new drug discovery started, I must say that it started with the first nosode of Mycobacterium Tuberculosis (initial version) developed in 1998. To my surprise, the old nosode Tuberculinum was made around 1880, which was found to be ‘not reproducible’! The fact of ‘non-reproducibility’ of our nosodes was intimidating news to me that opened the windows and doors to my future journey in this space.

MB: Interesting. I have never thought of this. What do you mean by non-reproducibility of nosodes and how does it really matter?

RS: Probably, no one ever thought of the risk, threat, and danger hidden with this imperfection, which will never be accepted in any medical science. Old Tuberculinum was prepared by Swan from the ‘infected lung tissue’ of a ‘suspected case of Tuberculosis’. (Reference: Hering Guiding Symptoms) Let’s examine

  1. Infected lung tissue: The infected tissue will obviously have specific organisms (presumably Mycobacterium Tuberculosis), and also other tissues and organisms (co-infections), and a large number of proteins and debris.
  2. Suspected case of Tuberculosis: It was not a confirmed case of tuberculosis, as Robert Koch discovered the organisms two years later in 1882! So, in reality, it is hard to call that nosode ‘Tuberculinum’ as it was much more than the organisms of the disease.

I was stunned at the uncertainty noticed in making of the nosode. I must say that it was an incredible gift by Swan in those years before microbiology emerged as a full-fledged branch. However, we simply carried on with the preparation of Tuberculinum for over 135 years without any review!

It was realized that the Tuberculinum which is available in the market, used by thousands of homeopathsnov-2016-interview-rajesh-shah7 across the world; was probably the same descendent of one made 135 years ago; probably by using the back-potencies, which travelled across oceans, withstanding two world wars…

Most of the pharmacies selling or manufacturing Tuberculinum sourced the back-potencies from ‘other’ pharmacies some years ago. There is no tracking system in place for the source material of such nosodes and other medicines.

MB: So, what is the solution? Can we not make a new Tuberculimum nosode?

RS: Yes, we have to makenew nosodes. In fact, we scientifically developed new Mycobacterium Tuberculosis nosode with many efforts. In that process, I found that there is no well-defined method for making the nosodes, as the nosodes were never re-made but they were always prepared from so called back-potencies. The method shown in the HPI (Pharmacopeia) had many flaws as it was written a few decades ago without any revision.

In this journey, the nosodes as well as the method for preparing the nosodes, were developed. The article on Mycobacterium Tuberculosis nosode was published in the journal ‘Homeopathy’. ( A full method of developing any new nosode was developed and published in IJRH. (

MB: That is indeed a pioneering work, as you not only found the problem but also the solution, Dr Shah. In that case, you have already travelled some good distance. What is the problem now?

RS: It has taken me over twenty years to travel thus far. The travel time would have been much shorter if the mechanism for new drug discovery was defined in the law. My dream is to have a proper mechanism for new drug discovery in place so that more researchers could introduce new homeopathic drugs and more research could take place; which, in turn, could help the science of homeopathy grow to the next level.

MB: What do you mean by ‘mechanism’ for new drug discovery’?

RS: In conventional medicine (allopathy), there are clear guidelines by DCGI (Drug Controller General of India) and FDA for new drug discovery. Such guidelines are missing in homeopathy. What I mean by a mechanism is the exact roadmap and steps required for making new drug discovery and bringing it to either pharmacopeia and/or making ready for manufacturing, with technical and legal approvals.  Since there are no major instances of new drug discovery except some by CCRH, such a mechanism does not seem to be in place. Also, for new drugs in the Nosode (biological source) category, there is absolutely no clarity about the guidelines.

MB: Did you write to the concerned authorities for the required guidelines for new drugs?

RS: Yes, there is a documented story! Over the years I wrote to FDA (Mumbai) for guidelines for new drug discovery. FDA asked me to write to HPL (Homeopathy Pharmacopeia Laboratory, Ministry of AYUSH) for the same. On writing to HPL, after a few months, I received a reply asking me to write to CCRH. I did it. CCRH wrote to me asking me to write to the Ministry of AYUSH. I wrote to AYUSH, and they asked me to write to DCGI. I wrote to DCGI… The whole process took over two years! And you know what, DCGI wrote to me saying they were unable to help; and I must write to FDA. Back to square one!  Now, since we have new government, I am hopeful of an answer and guidelines from the Ministry.

MB:  So what is the difference between ‘Proving’ a new remedy and ‘mechanism for new drug discovery’?

RS: The homeopaths often believed that ‘proving’ is enough for any new drug discovery. Actually, the steps to new drug discovery should be as follows

  1. Identification of a new drug substance
  2. Rationale of use
  3. Standardization of source material for future use
  4. Potentization criteria
  5. Safety check
  6. Drug proving (Homeopathic Pathogenetic Trial)
  7. Evaluation in Animal models
  8. Evaluation in in-vitro models
  9. Efficacy evaluation:
    1. Clinical trial
    2. Clinical evaluation in practice

All the steps may not be required for every new drug discovery.

MB: So, for some of the new drugs, especially the nosodes, that you have introduced, did you undergo some of the above studies?

RS: Mostly, yes. For example, the HIV nosode and Hepatitis C nosode underwent all of the above studies except the animal study. Capsaicin underwent all of the above including animal study. So, the steps would depend on the nature of the source material and other factors.

MB: This is interesting. Do you agree that the most important part of the mechanism is the drug proving?

RS: Well, after conducting several double blind, placebo controlled provings; I would say that drug-proving may not be always required. Did you know that about 30% of the medicines in Boericke’s materia medica are not well proven, and many are not proven at all? There are other ways of identifying the therapeutic indications.

MB: I understand that there are no government guidelines in India yet to add new remedies to our Pharmacopeia and Materia Medica. But are there any laws or guidelines that prevent us from using the newly proved remedies? I know so many homeopaths who order the newer remedies from International pharmacies like Helios and Remedia.

About the author

Manish Bhatia

Manish Bhatia

- CEO, Hpathy Medical Pvt. Ltd.
- Homeopathy physician.
- Lecturer of Organon & Homeopathic Philosophy.
- Founder Director of
- Editor, Homeopathy 4 Everyone
- Member, Advisory Board, Homeopathic Links
- Member, Center for Advanced Studies in Homeopathy
- Co-author - Homeopathy and Mental Health Care: Integrative Practice, Principles and Research
- Author - Lectures on Organon of Medicine vol 1 & 2
- For consultation, seminars or clinical training, write to

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  • “Tuberculinum was prepared by Swan from the ‘infected lung tissue’ of a ‘suspected case of Tuberculosis’.”
    The term *suspected* did attract my attention many years ago and I wondered on the same lines. But then the practitioners continue to prescribe them based on the MM and also basis their own experience (which doesn’t get documented).
    I also often think about the source of the remedy, especially plants. Say a plant that is grown in the foothills of Himalayas, or in a black soil or a red soil is likely to show variation in proving symptoms or is it that the central theme or the genius of the remedy outplays the peripheral differentiation.

  • DEAR DR,