The Special Intensive Revision (SIR), the Election Commission of India's (ECI) mechanism for verifying electoral rolls, is meant to strip out the names of the dead, the relocated and the duplicated, correct errors, and leave only genuine electors on the voter list. Unlike the routine revisions that precede elections, Section 21(3) lets the ECI order a special revision at any time, provided it records its reasons in writing.

A cluster of provisions in the Representation of the People Act (RPA), 1950, is meant to give that exercise teeth. Section 17 bars a person from being registered in more than one constituency. Section 22 lets an Electoral Registration Officer (ERO) correct, amend or delete an entry, giving the person an opportunity to be heard.

Section 31 of the RPA makes false declarations during the preparation or revision of electoral rolls a criminal offence, punishable with imprisonment of up to one year, a fine or both. Actor Prakash Raj is currently facing trial in a case related to allegations of making a false declaration in connection with electoral roll details. Section 32 penalises election officials who, without reasonable cause, fail to carry out their duties in preparing or revising the rolls.

To find out how often these provisions are actually enforced, this author filed a series of RTI applications with the ECI, Chief Electoral Officers (CEOs) in several states and District Election Officers (DEOs) and EROs at the constituency level. What came back was not a record of enforcement: It was a record of an enforcement system that, by its own officials’ admission, does not know what it has enforced.

Unconsolidated data, inconsistent answers

None of the authorities approached – the ECI, any of the CEOs, any DEO or ERO – maintained consolidated data on violations of Sections 18, 22, 31 or 32. Where information was provided at all, it frequently contradicted what a neighbouring office or a superior authority had said about the very same provision.

Section 22 notices don't exist, even where allegations run into the lakhs

Section 22 is the most consequential of these provisions in day-to-day terms – it is the mechanism by which a name is actually corrected, shifted or struck off the rolls. The CEOs of Gujarat and Maharashtra confirmed in their RTI replies that the responsibility for issuing Section 22 notices rests with the ERO of each constituency.

Gujarat alone has 182 EROs – one per assembly seat.

In August 2025, Gujarat Congress president Amit Chavda alleged that his party had identified around 30,000 bogus voters in the Choriyasi assembly constituency, within the Navsari Lok Sabha constituency held by Union minister and state Bharatiya Janata Party (BJP) chief C.R. Patil.

On this basis, Chavda claimed that a statewide check could turn up as many as 62 lakh fake entries.

To examine what action, if any, the election machinery had taken, I filed an RTI with the ERO, Navsari, seeking the number and copies of notices issued under Section 22 between January 1, 2018 and September 7, 2025. The response stated that not a single Section 22 notice had been issued during this period. The response to a similar RTI filed with the ERO of Choriyasi also revealed that no Section 22 notices had been issued.

Delhi: Seven offices, seven different responses

The absence of a uniform system was the most evident in Delhi, where another RTI application seeking information on notices issued under Section 22 of the RPA elicited seven different responses from seven EROs and Assistant EROs.

• Dwarka (Assembly Constituency 33): Reported that 29,508 notices had been issued under Section 22(c), while no notices were issued under Sections 22(a) and 22(b).
• Badarpur (AC 53): Refused to disclose the information, citing the privacy exemption under Section 8(1)(j) of the RTI Act.
• Shalimar Bagh (AC 14): Stated that the requested information was not part of the office's records.
• Mustafabad (AC 69): Said the information could be provided only in respect of a specific, named case.
• Babarpur (AC 67): Said the records existed but asked the applicant to deposit Rs 25,000 towards the cost of retrieving them.
• Patparganj (AC 57): Confirmed that it held the relevant records and stated that no such notices had been issued.
• Rohini (AC 13): Replied that notices had been issued as per ECI guidelines, without disclosing the number of notices.

The contrasting responses to the same RTI applications highlight the absence of a consistent approach to record-keeping and disclosure across election offices in the national capital.

This inconsistency stands out against one case that did surface publicly: the District Election Office, New Delhi, posted a notice on X regarding Congress leader Pawan Khera, alleging that he had registered in more than one constituency's electoral roll.

To find out whether comparable notices had been issued and publicised elsewhere, I filed RTIs with the DEOs of Navsari, Surat, Kabirdham, Dwarka and Panchkula, and with the CEOs of Gujarat, Maharashtra, Chhattisgarh and Karnataka, asking for details of notices issued under Sections 18 and 22 and whether any had been posted on X. None of these authorities provided any information for either question.

Under Section 21 of the RPA, the revision of electoral rolls is a statutory process conducted before every General Election to the Lok Sabha or a state legislative assembly, as well as before by-elections to fill casual vacancies in constituencies.

However, RTI applications seeking details for the seven years  from January 1, 2018 to September 7, 2025 did not yield any specific information on the notices issued related to the electoral roll revisions.

Section 31: an offence without an enforcer

Section 31 criminalises knowingly making a false declaration anywhere in the process of preparing, revising, correcting or amending an electoral roll. Unlike Section 22, the law does not explicitly say who is responsible for initiating action under this provision.

Asked to identify the competent authority, the ECI as well as the CEO of Maharashtra said the responsibility lies with the ERO.

However, the DEO of Kabirdham in Chhattisgarh said the information sought was a matter for the ECI – directly contradicting the position taken by the ECI itself.

Apart from these contradictions, more than 30 RTI replies from Electoral Registration Officers (EROs) were examined to check whether any cases had been registered or complaints filed under Section 31 of the RPA. The responses either stated that such information was not available or no reply was received.

None of the RTI replies provided details of any recorded case or complaint under Section 31 of the Act.

Section 32: Who acts against election officials?

Section 32 of the RPA penalises an ERO, Assistant ERO or other election official for neglecting their official duties connected to the electoral roll. The punishment prescribed is three months to two years of imprisonment, plus a fine. The law specifies that a court can only take cognisance of such an offence on a complaint filed by, or with the authorisation of, the ECI or the state CEO.

Despite this, when asked for information on cases filed under Section 32, the Chief Public Information Officer (CPIO) for the ECI, Pawan Diwan, responded that the matter pertained to the ERO. I filed an appeal challenging this response. The First Appellate Authority of the ECI upheld the original reply given by the CPIO.

However, in response to an RTI, the CEO, Gujarat, stated that it had designated 34 DEOs to initiate action under Section 32 of the RPA. But an RTI response from the DEO, Navsari, stated that the information sought pertained to the CEO, Gujarat and the ECI, adding yet another contradiction to the responses received from election authorities.

The RTI responses contradict which authority is responsible for initiating action under Section 32. While the ECI stated that the matter falls within the jurisdiction of the ERO, the CEO Gujarat indicated that designated DEOs are responsible for such action.

What is more, the DEO Navsari redirected the query back to the CEO and the ECI. The differing responses from the ECI, CEO and DEO suggest lack of clarity and inconsistency regarding the implementation and record-keeping of proceedings under Section 32 of the RPA.

SIR phase II: decision taken in a single day, no meeting records disclosed

An RTI application was filed with the ECI seeking copies of the file notings related to the decision to undertake the second phase of the SIR, along with the minutes of all meetings held on the matter.

The CPIO did not provide a response within the statutory time limit. In the first appeal, the CPIO attributed the delay to workload constraints. The RTI application, filed on November 29, 2025, was finally responded to on March 19, 2026 – more than three months after the prescribed period.

The information provided by the ECI consisted of only two pages of file notings. These records indicate that the proposal was initiated by an Under Secretary on October 27, 2025 and was approved by all concerned officials, including the CEO, on the same day.

However, the ECI did not provide any minutes of meetings, despite the specific request in the RTI application. No explanation was offered regarding whether such meetings were held or whether any records were maintained.

The SIR Phase II exercise became a matter of national significance, triggering litigation in multiple courts, placing millions of citizens under scrutiny and generating widespread public debate. Yet, the records disclosed through the RTI raise questions about the extent of internal deliberation and documentation behind a decision with such far-reaching consequences.

Records missing, questions remain unanswered

The SIR is among the largest electoral roll verification exercises undertaken anywhere and affects millions of voters. However, this investigation suggests that election offices often do not maintain comprehensive or consistent records related to the legal provisions governing electoral rolls.

The findings raise questions about transparency and how the routine enforcement of these provisions is being done across the country. They raise an important question: if electoral rolls were updated consistently through regular statutory processes, would a large-scale exercise such as the SIR have been necessary?

Suchak Patel is an independent writer.

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