Critically analyse the limits of the Election Commission's plenary powers under Article 324 in light of recent controversies over enrolment procedures.

Article 324 gives the Election Commission of India (ECI) "superintendence, direction and control" over electoral rolls. The Special Intensive Revision (SIR), ordered under Article 324 and Section 21 of the RP Act, 1950 [1], shows how wide this power is. The modified Form 6 row shows where it ends.

Scope of the plenary power

• In 2026 INSC 564 (27 May 2026), the Supreme Court upheld SIR under Article 324 and Section 21(3). Its non-obstante clause lets the ECI order a special revision "at any time", free of the rules for ordinary revision [2].
• Mohinder Singh Gill (1978) held that Article 324 fills areas where no law has been made, so it covers gaps the law leaves open.
• The ECI has run SIR in phases, with door-to-door verification, notice before deletion and two levels of appeal [3].

Limits exposed by recent controversies

• Statutory limit: Article 324 cannot override a law Parliament has made. Enrolment forms are prescribed by the Registration of Electors Rules, 1960. In October 2026 the Supreme Court said no modified Form 6 had been approved by it and sought records on who changed the form [4]. Changing a form through executive orders raises a question of delegated legislation: who has the power to amend it?
• Citizenship limit: The ECI may look into citizenship only to decide inclusion in or exclusion from the roll. Cases of doubt go to the authority under the Citizenship Act, 1955 [2].
• Rights limit: Articles 325–326 guarantee universal adult franchise. In Bihar, about 65 lakh electors were left out of the draft roll because their enumeration forms were not submitted [2]. This puts the burden of proving eligibility on the voter.
• Judicial correction: The Court ordered that Aadhaar be accepted as an extra document in Bihar [5]. This shows that judicial review checks how the ECI uses its discretion.

Assessment

• Strength: Clean rolls protect free and fair polls. The Court found SIR "necessary" for this [2].
• Weakness: Large exclusions and changes to forms without approved rules weaken procedural fairness.
• Balance: The ECI's response is a partial safeguard. Extending claims deadlines in six States/UTs widens the window for correction [6].

Article 324 is therefore a plenary power, but not an unlimited one. Statute, the Constitution's guarantee of franchise and judicial review all bound it. Four steps would keep roll purification and inclusion in balance:

• amend the 1960 Rules formally;
• publish lists of excluded voters booth by booth;
• create a separate re-entry route for existing electors;
• keep the citizenship inquiry within its limits.

This fits the Indrajit Gupta Committee's (1998) call for an ECI that is autonomous but accountable.