State Of Wisconsin
Circuit Court
Fond Du Lac County


Case No. 92 CV 579

Nation of India
City of New Dehli

A. K. Susheela, Ph.D., being first duly sworn on oath, under penalty of perjury, and with personal knowledge of the information contained herein, respectfully states to the Court as follows:

  1. I, Dr. A. K. Susheela, have spent more than 20 years doing scientific research in the field of Fluoride Toxicity and Fluorosis.
  2. I am a full Professor of Anatomy (Histocytochemistry) and Chief of the Fluoride and Fluorosis Research Laboratories, at the All India Institute of Medical Sciences, New Delhi.
  3. I have held Faculty positions at the same Institute since 1969.
  4. I am a Ph.D from India, with Post-doctoral training under LORD WALTON (Neurologist) of U.K. and Dr. Ade Milhorut of the Muscle Institute, New York, USA, (which no longer exists).
  5. I was a Visiting Professor at the Allan Hancock Fn. at the University of Southern California during 1974-76.
  6. I am a Fellow of the Indian Academy of Sciences and the National Academy of Medical Sciences.
  7. I have won the prestigious Ran Baxy Research Foundation Award (Cash Prize) for outstanding research in medical sciences.
  8. I have been involved in teaching medical students of all levels and carrying out research and guiding research in the field of muscle diseases and Fluorosis for more than 20 years.
  9. My field of interest for the last 20 years has been Fluoride and Health Hazards.
  10. Numerous funding organizations have been calling upon me during that time for evaluating projects for funding in the field of Biomedical Research.
  11. I have been a member of several National Committees since early 1970s, where issues related to Fluoride are debated and discussed.
  12. I have convened an International Conference on Fluoride and Fluorosis research in India in 1983. I edited a book on Fluoride Toxicity during 1985.
  13. I have been invited to speak on my experience in the field of Fluoride Research at various scientific meetings held in: (1) Japan; (2) Denmark; (3) Switzerland; (4) Kenya; (5) U.S.A. (several times); and (6) Hungary.
  14. I have guided 6 Ph.D theses in the subject of Fluoride and Health Hazards. A 7th Project is ongoing.
  15. I have more than 80 scientific publications in leading Western and Indian Journals.


  1. From my extensive experience, I state without hesitation and with a high degree of scientific certainty, the following evaluation of fluoridation.
  2. Fluoride destroys muscle structure, muscle function and depletes muscle energy.
  3. Fluoride destroys the bone.
  4. Fluoride destroys the teeth.
  5. Fluoride destroys the RBCs.
  6. Fluoride destroys the Blood Vessels.
  7. Fluoride destroys the lining of the stomach and intestine causing GI problems.
  8. Evidence that is forthcoming also strongly suggests that in some individuals it causes infertility (not in all, depending on their hormonal status).
  9. Substantial scientific evidences has emerged in recent years from studies conducted on Human Subjects and Hospital patients & those residing in areas/ regions/villages where fluoride content ranges in drinking water from 0.5 p.m to 38.5 ppm.
  10. Twenty years of follow-up studies have now been concluded and the important findings include the following.
  11. Gastro-intestinal complaints are the earliest manifestations of Fluoride toxicity and Fluorosis. The most common complaints include (1) Headache; (2) Nausea (Loss of appetite); (3) Pain in the stomach; (4) Gas formation in the stomach (bloated feeling); (5)Constipation; (6)Intermittent fermentation diarrhea.
  12. As a result of the above, GI complaints in endemic areas are considered as early warning signs of the fluoride toxicity and are used as a diagnostic parameter under field based conditions. See Fluoride Ingestion and its Correlation with Gastrointestinal Discomfort. (Exhibit____).
  13. Studies on human teeth have shown that fluoride alters a chemical substance in the matrix of the tooth. The mineralization process is abnormal, leading to changes in mineral content, and cavities or pitting are known to occur.
  14. In other words, Fluoride induces cavity formation, as well as discoloration of teeth. It is also evident that use of fluoride can lead to loss of teeth at an early age and one becomes edentulous. See The Status of Sulphated Isomers of Glycosaminoglycans in Fluorosed Human Teeth. (Exhibit____).
  15. Fluoride in circulation has an affinity to get deposited in tissues rich in calcium although some amount is excreted. In children, the fluoride ingested has adverse effects on kidney function. See Fluoride: Too Much Can Cripple You. (Exhibit____).
  16. During the last 20 years, six Doctorate Degrees which were carried out under my supervision and guidance have been conferred on theses on Fluoride Toxicity & Fluorosis.
  17. Thesis No.1 (Ph.D): "Muscular and Neural manifestations in Fluoride Toxicity in Rabbit and Man". Submitted to All India Institute of Medical Sciences, New Delhi and conferred the Ph.D. degree to RAJ D. KAUL in 1976.
  18. Significant Findings emerged from studies on human patients of skeletal fluorosis. Degenerative changes were well defined at the ultrastructural level in the fluoresced muscle obtained from patients of Skeletal Fluorosis.
  19. Thesis No.2 (Ph.D): "Certain structural and functional aspects of bone with reference to Fluoride Poisoning". Submitted to the All India Institute of Medical Sciences, New Delhi and conferred the degree of Doctor of Philosophy to MR. MOHAN JHA during the year 1983.
  20. Significant findings emerged from the thesis and have added a new dimension to our understanding of fluoride poisoning and fluorosis. The thesis has reported a sensitive blood based test which has been developed based on the chemical defects occurring in the tissues as a result of fluoride poisoning.
  21. Thesis No.3 "Erythrocyte membrane abnormalities during Fluoride Toxicity and Fluorosis". Submitted to the All India Institute of Medical Sciences and conferred the Doctorate degree to MR. SURESH K. JAIN in 1987.
  22. Significant findings emerged from the thesis, showing that fluoride inhibits the activity of enzymes of Glucose-6-Po dehydrogenase and pyruvate kinase in erythrocytes leading to impairment of carbohydrate metabolism.
  23. Fluoride adversely affects membrane bound enzyme (ATP - ase) and affects the transfer of calcium and magnesium ions in erythrocytes.
  24. Fluoride inhibits antibody formation in rabbits and may occur in human subjects as well.
  25. Fluoride inhibits protein and DNA synthesis in cultured lymphocytes.
  26. Fluoride reduces the number of lymprocytes in circulation by inhibiting their proliferation.
  27. Thesis No. 4 (Ph.D): "Fluoride Toxicity Studies on Glycosaminoglycans and its Sulphated Isomers in the Calcified Tissues" Submitted to the All India Institute of Medical Sciences and conferred the degree of Ph.D. to MR. KAMAL SHARMA in the year 1988.
  28. The findings emerging from the studies on both tooth & bone have made significant contributions to negate the belief that fluoride is good for teeth.
  29. Instead, Fluoride does more damage to teeth than any good. Prolonged use of fluoride leads to a decrease in the organic matrix of rabbit tooth but Dermatan Sulphate content is increased.
  30. High Dermatan Sulphate content appears to be the detrimental factor in causing dental fluorosis.
  31. Thesis No. 5 (Ph.D): "Effects of excess fluoride ingestion on calcification of bone with reference to Glucocorticoids". Submitted to the All India Institute of Medical Sciences, New Delhi and conferred the degree of Ph.D to MR. TAPOSH K. DAS during 1991.
  32. The above treatise has contributed significant, novel information in the understanding of the pathogenesis of skeletal abnormalities occurring in chronic fluoride toxicity and fluorosis.
  33. Reduced plasma cortisol levels in patients afflicted with fluorosis is reported for the first time. Fluoride treated animals also produced less cortisol and revealed adrenocortical hypofunction.
  34. The study also revealed for the first time, pituitary gland hypofunction which is possibly the reason for adrenal insufficiency in the production of steroid hormone.
  35. Fluoride toxicity was shown to impair cortisol production, thereby altering the bone matrix constitution both organic and inorganic, leading to defective and abnormal mineralization process.
  36. Thesis No. 6 (Ph.D): "Effect of fluoride on soft tissues - Structural and Biochemical studies". Submitted to the All India Institute of Medical Sciences, New Delhi and conferred the degree of Ph.D to MRS. POONAM KHARB during 1991.
  37. This thesis focuses on the biochemical mechanism of ectopic or soft tissue calcification.
  38. Although the treatise was completely devoted to animal studies, it offers the message to both the developing and developed world, particularly in the prevention of cardiac problems. Aortic calcification, which is very frequently occurring, perhaps is a result of excess ingestion of fluoride through food, water, drugs, cosmetics like tooth paste/mouth rinses and fluoridated water.
  39. The disappearance of Dermatan Sulphate from soft tissue (which normally has high concentration of Dermatan Sulphate) is the beginning of nucleation for calcification of the soft tissue. This process is activated by fluoride.
  40. The impact of the above contributions in the Indian National scene has been significant.
  41. India launched a Technology Mission on "Safe Drinking Water" in 1986 (now re-designated after the late Prime Minister Sh. Rajiv Gandhi, as Rajiv Gandhi National Drinking Water Mission) in which every drinking water source in the rural sector is checked for water quality, specially for Fluoride.
  42. People are keen to defluoridate the water due to gastrointestinal problems and are adopting indigenous technology for obtaining potable (defluoridated) water.
  43. Results include reduced abortions (as Fluoride is known to induce calcification of blood vessels of the fetus).
  44. Reduced still births (as Fluoride is known to induce calcification of blood vessels of the fetus).
  45. I am absolutely certain that large numbers of persons all around the world are suffering from Fluoride Toxicity, to one degree or other.
  46. The various and frequent health complaints, caused by fluoride ingestion, are often (or invariably) over-looked due to unawareness at all levels, which include the health professionals or, perhaps, due to the prevailing ill conceived, unscientific notion that "fluoride is good for teeth."
  47. Fluoride is potentially a dangerous chemical and a poisonous substance, which does no good to the human body.
  48. With a high degree of scientific accuracy and certainty, I conclude that artificial fluoridation of drinking water is an ineffective means of improving dental health, and is in fact quite dangerous to those forced to consume it.
  49. I make this Affidavit in support of the Plaintiff's Motion for Summary Judgment.