Discuss the tension between the purity and the inclusiveness of electoral rolls. How has the judiciary sought to balance the two?

Article 326 gives the vote to every adult citizen. Article 324 makes the Election Commission of India (ECI) responsible for accurate rolls. The Special Intensive Revision (SIR) shows the conflict between a clean roll and a complete one. The judiciary has tried to protect both.

Purity vs Inclusiveness: The Tension

Case for purity

• Integrity: Dead, duplicate and shifted entries make impersonation and double voting possible. The ECI says SIR is a phased exercise with safeguards for eligible voters [1].
• Eligibility checks: Aadhaar proves identity, not citizenship [7]. So the ECI asks for documents.

Case for inclusiveness

• Burden shift: Voters who did not return enumeration forms dropped off the draft roll. To get back on, they must file Form 6 with a declaration [2]. Form 6 is the form for new electors.
• Bypassing existing law: Form 8 already covers a change of residence [3]. ECI norms require a BLO field verification for each shifting deletion [4]. Under SIR, people are deleted first and verified later.
• Unequal cost: Migrants, renters and daily-wage earners are the least able to produce documents in time. Wrongly excluding genuine voters harms the legitimacy of the mandate.

Judicial Balancing

• Due process: In Lal Babu Hussein (1995), the Court held that a person on the earlier roll cannot be removed without notice and a hearing. It also held that earlier inclusion carries probative value [5].
• Upholding the power: In May 2026 the Court upheld SIR under Article 324. It said SIR serves free and fair elections and cannot be used to decide citizenship [6][8].
• Wider documents: The Court ordered that Aadhaar be accepted as the 12th document for identity. The ECI kept the right to verify [7].
• Transparency: The Court directed the ECI to publish about 65 lakh excluded Bihar electors with reasons. The lists went to political parties down to booth level [6].
• Continuing review: The pending Delhi challenge asks whether deleted voters should have to re-enter as "new" electors through Form 6 [2].

The courts have treated purity and inclusiveness as values that work together. They have upheld the ECI's power while insisting on fair procedure. Next phases should build in Form 8 transposition, BLO verification and published deletion lists. Then safeguards would not depend on litigation, and the promise of universal adult franchise would stay intact.