Questions about how the Election Commission of India (ECI) has managed electoral roll revisions, changes to voter registration forms, and the rollout of the Special Intensive Revision (SIR) programme — a process touching close to one billion people on the rolls — have drawn sustained public and institutional attention.

Questions about the Election Commission of India's conduct have accumulated across several fronts — among them, how alleged Model Code of Conduct breaches during the 2019 general election were handled, whether opposition parties received treatment comparable to that extended to others, and what prompted the December 2024 revision of rules around document disclosure.

A directive from the Punjab and Haryana High Court demanding full transparency set these adjustments in motion, while also granting the Election Commission of India authority to keep video recordings from post-hours voting periods out of public view.

Notices went out from the ECI to party organisations over alleged Model Code of Conduct breaches attributed to their prominent campaigners during the 2024 general election, with those same figures later cleared of wrongdoing. Grievances about how the ECI has handled its interactions with civil society groups have been put forward by those organisations.

Complaints about purported irregularities in electoral rolls were lodged by the Lok Sabha's Opposition leader, after which the Election Commission of India directed that official to back the allegations with a sworn affidavit or else offer a public apology. Amendments enacted in December 2023 overhauled how Election Commissioners are chosen, a move that drew objections from those who questioned whether the revised process would allow appointments to be made free from outside influence.

A special revision of electoral rolls got under way through the Election Commission of India that same month in 2025. At the heart of the dispute sits a change made to Form 6 — the document used under the Registration of Electors Rules, 1960, when a person applies to be added to the electoral roll.

Applicants completing Form 6 are required to supply personal particulars — including identity details, date of birth, usual place of residence, citizenship status, and birthplace — with any deliberate misstatement on those fields drawing penalties under Section 31 of the Representation of the People Act, 1950.

Alongside Form 6 or Form 8, a supplementary Declaration Form — designated Annexure D — was made part of the Special Intensive Revision paperwork under the Election Commission of India's 24 June 2025 notification. Applicants were sorted under the declaration according to their dates of birth, with the eligibility conditions drawn from the Citizenship Act's own provisions and the necessary paperwork required to match.

Some fellow Election Commissioners labelled the changes as unlawful and conducted without proper authorisation, while a number of observers put forward the view that the SIR functioned as a backdoor route to establishing a National Register of Citizens. Under the Representation of the People Act, rule-making authority for the Act's own provisions rests exclusively with the central government, as laid out in Section 28.

A press note issued by the ECI on 26 September conveyed that the declaration form attached to Form 6 during the SIR had received backing from the Supreme Court. Responding to a question on the matter, the Chief Justice of India indicated that no revised version of Form 6 had received the court's approval.

A letter the Election Commission of India sent to all Chief Electoral Officers on 1 October 2026 set out that individuals not yet on the electoral roll — or whose names had been removed from it — retained the ability to apply for enrolment at any point. Each polling-station officer received instructions to cross-reference the active voter lists against rolls predating the Summary Intensive Revision, trace any deletions, go door to door to establish whether removed individuals remained eligible, and where eligibility held up, guide those residents through the Form 6 re-registration process.

Where the SIR remains active, Form 6 retains the Declaration as an attached component; once a state's SIR process has concluded, that attachment is dropped from the version in circulation.

Form 7 — the mechanism through which voters may contest or seek the deletion of a name from the electoral roll — has drawn attention in its own right, with the Election Commission of India facing questions from those who contend that the document has been put to improper use across Uttarakhand, Karnataka, and a number of other states. Questions about whether the Election Commission of India has done enough to penalise those who lodged unwarranted Form 7 objections — or to pursue criminal charges where such filings were later deemed fraudulent — have been raised by a number of observers.

No answer has emerged from the Election Commission of India, even after it put out several press statements in response to a news channel's disclosures on 23 September, about the identity of whoever lodged upwards of 1.6 million challenges against voter registrations that had been added through established procedural channels.

Documentation filed by Booth Level Officers and Electoral Registration Officers in West Bengal during the Special Intensive Revision, along with written communications from Electoral Registration Officers in Goa, point to a pattern in which those holding authorised roles found themselves unable to carry out their administrative decisions within the ECINet platform. A collective of eleven presiding officers at West Bengal's Appellate Tribunals reported that the digital infrastructure placed constraints on their day-to-day judicial operations.

The Maharashtra Chief Electoral Officer's assessment pointed to structural shortcomings within the system that left EROs without a viable mechanism for exercising the discretionary powers the legislation had assigned to them.