Examine the legal basis and limits of ECI's plenary powers under Art. 324 with reference to roll revision.

Article 324 vests the "superintendence, direction and control" of electoral rolls and elections in the Election Commission of India — a reservoir of plenary power meant to fill statutory gaps, not to displace law. The ongoing Special Intensive Revision (SIR) tests where that reservoir ends.

Legal basis of the power

• Constitutional: Art. 324 gives ECI plenary authority over roll preparation, read with Art. 326 (universal adult suffrage), making roll purity a constitutional duty [1].
• Statutory: SIR rests on Section 21, Representation of the People Act, 1950, read with the Registration of Electors Rules, 1960 — special revision of rolls is an express statutory power, not an invented one [1].
• Judicial: the Supreme Court has held SIR to be within ECI's statutory mandate under the RP Act, 1950 and consonant with Art. 324 [1].
• Functional necessity: Bihar's revision found 1.59% electors deceased, 2.2% permanently shifted and 0.73% enrolled at more than one place out of about 7.89 crore — decay that routine summary revision had missed [3].

Limits on the power

• Subordination to law: plenary power operates only where statute is silent; it cannot override Section 21 or the 1960 Rules [1].
• Due process: no name may be deleted from the draft roll without enquiry, a fair hearing and a speaking order by the ERO [2].
• Procedural fairness in practice: the claims-and-objections window in Bihar ran only 1 August to 1 September 2025, shorter than enumeration — a heavy burden on migrants who must re-prove entitlement [2].
• Institutional limits: ECI's autonomy itself is contested, since the CEC and Other Election Commissioners Act, 2023 replaced the CJI (mandated in Anoop Baranwal, 2023) with a Cabinet Minister, and lets the Selection Committee act despite a vacancy — which PRS warns may undermine ECI's independence [4].

Thus Art. 324 empowers, but does not immunise: ECI's plenary authority is disciplined by statute, judicial review and natural justice. A longer correction window, public searchable disclosure of excluded names, and restoring a non-partisan appointment panel would align roll revision with the constitutional promise of universal franchise, keeping both roll purity and voter trust intact.