The People's Union for Civil Liberties (PUCL) has written a detailed representation to the Chief Election Commissioner and the two other Election Commissioners of India, strongly objecting to the ongoing Special Intensive Revision (SIR) of the electoral rolls in Bihar. The human rights body has warned that the hurried and legally ambiguous process threatens to disenfranchise millions of voters, particularly among the most marginalized communities, and thereby undermines the constitutional principle of universal adult franchise.
QIn a letter addressed to Chief Election Commissioner Shri Gyanesh Kumar and Election Commissioners Dr. Sukhbir Singh Sandhu and Dr. Vivek Joshi, PUCL General Secretary Dr. V. Suresh and President Kavita Srivastava have urged the Election Commission of India (ECI) to immediately halt the SIR and instead initiate a consultative process with civil society, political parties, and other stakeholders before proceeding.1
PUCL’s representation questions the legality, transparency, and feasibility of the SIR being conducted under significant time constraints, and points out major procedural deviations from established rules under the Registration of Electors Rules, 1960. The letter notes that the current process appears to bypass statutory forms and verification procedures, shifting the burden of proof onto voters rather than Election Commission officials.
Legal and Procedural Concerns Raised
PUCL points to inconsistencies between the ECI’s press note of June 26, 2025, and the operational letter issued to Bihar’s Chief Electoral Officer on the same day. While the former envisages a house-to-house verification by Booth Level Officers (BLOs) as per Rule 8 and Form 4 of the 1960 Rules, the latter deviates significantly—requiring voters themselves to fill and submit “Enumeration Forms” that are not legally prescribed, either by hand or online, often accompanied by documents many rural and illiterate voters may not possess.
The PUCL warns that this document-centric, voter-driven verification process is legally questionable and procedurally burdensome. "If the ECI is itself having to curtail prescribed procedures to battle against time," the letter states, "it does raise fears that the primary responsibility under Article 326 to include all adult voters… would be compromised."
The ECI's target is to process over 7.9 crore electors in Bihar—4.96 crore existing and 2.94 crore new voters—within just 90 days, with only 35 days allocated for distribution, collection, and verification of forms before the publication of draft rolls. Citing large-scale vacancies and rushed appointments of BLOs with minimal training, PUCL says the process lacks clarity and risks widespread exclusion.
Exclusion of Vulnerable Groups
PUCL’s concerns are particularly acute for marginalized communities, including illiterate citizens, daily wage workers, migrants, and those living in document-deficient rural areas. According to PUCL, many voters do not understand the forms or have the documents demanded by BLOs, leading to chaos and confusion.
Media reports cited in the letter reinforce the concern. The Hindu (July 2, 2025) and The Indian Express (July 1, 2025) have reported widespread confusion on the ground, with BLOs unable to answer basic queries and voters unable to meet unclear documentation requirements.
Moreover, PUCL notes that the ECI's own 2023 Electoral Roll Manual allows for inclusion through basic, accessible processes and does not require the additional documentary burden currently being imposed. Requiring proof of parentage or other documents not mentioned in the official amended forms is “de hors the rules,” PUCL asserts.
Constitutional and Policy Violations
The PUCL contends that the current exercise violates Articles 14, 324, and 326 of the Constitution. Instead of facilitating inclusion, it creates high entry barriers for precisely those the electoral process should empower. “The burden of inclusion is being shifted onto the marginalized voter and also made document-centered,” the letter says, reversing decades of policy focused on proactive inclusion.
Furthermore, the organization points out that the need for such an expansive SIR is itself questionable, given that electoral rolls are now digitized and continuously updated through summary revisions. The Representation of the People Act, 1950 already provides legal mechanisms to disqualify ineligible voters under due process.
PUCL also highlights past contributions to electoral reform through legal intervention—including its role in the Supreme Court's recognition of the "None of the Above" (NOTA) voting option, and the right of voters to know the criminal antecedents and financial assets of candidates.
Call for Immediate Action
PUCL has urged the Election Commission to suspend the current SIR process in Bihar and instead engage with civil society and legal experts to design a voter verification process that is lawful, inclusive, and democratic. “By going in for an ill-advised, hasty SIR which can only serve to exclude those without requisite documentation,” the letter warns, “the ECI is betraying its constitutional mandate of equal access to the right to vote.”p
PUCL's appeal underscores that India’s democratic credentials depend on ensuring that every eligible citizen—not just the documented or privileged—has the opportunity to vote.
“The exercise of universal adult franchise is what marks out India as a unique experiment in the history of global democracy,” the letter concludes. “This should not be undermined by arbitrary, exclusionary, and legally infirm procedures.”
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