The People’s Union for Civil Liberties (PUCL) has called for the immediate initiation of removal proceedings against Chief Election Commissioner Gyanesh Kumar and the restoration of all names deleted from electoral rolls during the Election Commission of India’s (ECI) Special Intensive Revision (SIR), following an investigation published by The Indian Express on September 23, 2026.
In a statement, PUCL has said the investigation confirmed concerns that opposition parties and civil society groups had raised regarding the conduct and consequences of the SIR. The organisation characterised the revision as a political exercise rather than a routine administrative exercise to update electoral rolls, and alleged that it had resulted in the disenfranchisement of millions of voters.
Central to PUCL’s concerns are disclosures that Election Commissioners Sukhbir Singh Sandhu and Vivek Joshi had formally objected on at least 14 occasions over a 10-month period to decisions and orders concerning the SIR that they said had been issued without their knowledge. According to PUCL, the matters in question included new voter registration, deletion and restoration of names, procedures for appeals and control of the electoral database.
PUCL said these disclosures raise questions about the functioning and institutional integrity of the three-member Election Commission. It alleged that the Commission effectively operated according to decisions taken by CEC Gyanesh Kumar and argued that this was inconsistent with the statutory framework governing decision-making within the Commission. The organisation therefore called for removal proceedings against Kumar and for the SIR to be suspended.
One of the specific issues cited by PUCL concerns Form 6, the statutory form used by citizens to register as new voters. According to the organisation, Election Commissioner Vivek Joshi had objected to changes to the form on the grounds that the SIR had been authorised as a “one time measure and exception” under Section 21(3) of the Representation of the People Act and that prescribed forms could not be altered without formally amending the Registration of Electors Rules, 1960. PUCL said Joshi had recommended that the proposed change instead be routed through the Union government, but that the Commission proceeded with it.
PUCL also cited concerns raised by Joshi about what it described as the “gradual centralisation” of the electoral-roll database. It said Joshi sought an audit of officials authorised to alter voter records and that both dissenting Commissioners had raised concerns about control of the Commission’s information-technology infrastructure directly with the Cabinet Secretary. PUCL said these concerns were not addressed.
The organisation invoked Section 18 of the Chief Election Commissioner and Other Election Commissioners Act, 2023, which provides for decisions of the Commission to be taken unanimously as far as possible and, where unanimity is not possible, by majority. PUCL argued that the provision is intended to establish collective decision-making within the Commission and prevent unilateral action by any one Commissioner.
The ECI has rejected allegations that the SIR decisions were taken without the participation or agreement of the other Commissioners and has maintained that its decisions were unanimous. PUCL disputes that position, arguing that the objections attributed to Sandhu and Joshi require the Commission to publicly account for how those objections were handled. At the same time, PUCL questioned why the two Commissioners did not make their concerns public earlier, given that their objections were recorded over a period of approximately 10 months.
PUCL said the SIR has been implemented in three phases: initially in Bihar in 2025, followed by nine states and three Union Territories, and subsequently in a third phase covering 16 states and three Union Territories. According to the organisation, the exercise has so far affected almost every part of India except Himachal Pradesh, Jammu and Kashmir, and Ladakh, with more than 13 crore names allegedly deleted from electoral rolls across the three phases.
The organisation highlighted several state-level figures to illustrate the scale of the deletions. It said the draft electoral rolls in Bihar excluded more than 65 lakh people, while the second phase in West Bengal resulted in the deletion of 58.2 lakh names and separately identified more than 1.2 crore voters as having “logical discrepancies”. PUCL noted that the ECI had reportedly told an RTI applicant that it could not define the latter category. It further alleged that different criteria for identifying such discrepancies were subsequently being applied in different states without a publicly available standard operating procedure. In Delhi, PUCL said, nearly 48 lakh voters had been removed, representing 32.78 per cent of the electorate.
PUCL said the impact of the deletions has been particularly significant for migrant workers, women whose names or addresses may change following marriage, transgender people whose official documents may not correspond with electoral records, and Dalit and Adivasi households that may have difficulty producing documents sought during the revision. It also referred to reports from West Bengal alleging that deletion from electoral rolls had been linked to the deactivation of ration cards for people categorised as dead or having shifted residence. PUCL said such developments could affect access to welfare entitlements.
The organisation also raised questions about elections that have already taken place using rolls produced through the SIR process. It pointed to Bihar, West Bengal, Tamil Nadu and Kerala, as well as the Union Territory of Puducherry, and said that challenges to electoral-roll deletions had raised questions about the integrity of elections conducted on those rolls. PUCL cited claims made by petitioners that in at least 31 West Bengal constituencies the number of disputed deletions exceeded the eventual margin of victory. It gave as an example a constituency in which the losing candidate was defeated by 862 votes while 5,550 appeals by deleted voters remained pending.
PUCL also criticised the Supreme Court’s handling of challenges to the SIR, particularly its decision in Association for Democratic Reforms v. Election Commission of India concerning the Bihar exercise. The organisation argued that the Court’s approach failed to adequately protect the constitutional principle of political equality and the right to vote. PUCL contrasted the decision with the Supreme Court’s 1976 judgment in ADM Jabalpur v. Shivkant Shukla, while acknowledging that the two cases arose in very different circumstances.
The organisation further connected its concerns about the SIR to the process for appointing Election Commissioners. It referred to the Supreme Court’s 2023 judgment in Anoop Baranwal v. Union of India, in which the Court had prescribed a selection committee comprising the Prime Minister, the Leader of the Opposition in the Lok Sabha and the Chief Justice of India. PUCL said Parliament subsequently enacted legislation replacing the Chief Justice with a Union Cabinet minister on the selection committee and argued that the change reduced the independence of the appointment process. It described Gyanesh Kumar as a beneficiary of the revised system and alleged that the subsequent functioning of the ECI demonstrated the consequences of that arrangement.
PUCL also referred to a split Supreme Court judgment delivered on September 23, 2026, concerning the appointment process for Election Commissioners. It highlighted an observation by Justice Bagchi that the inclusion of a Cabinet minister did not provide the same independent counterweight as a neutral selector. PUCL expressed the hope that this view would prevail if the matter is considered by a larger Bench.
The organisation called for Parliament to demand a full and transparent accounting of decisions that the two Election Commissioners say were taken without their consent, including through a Joint Parliamentary Committee with the power to summon records. It also urged the Supreme Court to take suo motu cognisance of the Indian Express investigation and reconsider the validity of the SIR in light of the newly reported material.
PUCL further called for the suspension of all remaining phases of the SIR and restoration of the pre-SIR electoral rolls as the operative rolls wherever the revision has already been conducted. It demanded the restoration of all names deleted during the exercise and said that any future deletion should comply with Section 21A of the Registration of Electors Rules, with the burden of proof placed on the relevant authority. It also called for the restoration of Form 6 and withdrawal of procedural changes that, in its view, were introduced without the required amendment to the Registration of Electors Rules, 1960.
Among its other demands, PUCL called for publication of every objection recorded by Election Commissioners Sandhu and Joshi, together with all SIR-related orders, decisions and minutes identifying participants in each decision. It sought an independent audit of every alteration made to the electoral database during the revision, including identification of the officials who authorised and executed each change.
PUCL additionally called for an end to what it described as the intimidation and harassment of people accused of being non-citizens on the basis of SIR-related deletions, citing developments in West Bengal. It asked the Supreme Court to examine the effect of the SIR on recent state elections and called for those elections to be declared void.
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