How far does judicial review act as a check on the Election Commission's plenary powers under Article 324? Illustrate with recent judgments.

Article 324 gives the Election Commission of India (ECI) "superintendence, direction and control" of elections. The Supreme Court has called this power a reservoir to be used where the law is silent. It has also held that the ECI is not a law unto itself [1]. Judicial review is therefore a strong check on legality, fairness and independence. It is a light check on the ECI's administrative and technical choices.

Where judicial review checks the ECI firmly

• Must obey the law: Mohinder Singh Gill (1978) held that the ECI must act in line with laws made by Parliament. Article 324 fills gaps in the law. It cannot override a statute [1].
• Independence of the ECI: In Anoop Baranwal (2023), a Constitution Bench ruled that a committee of the PM, the Leader of the Opposition and the CJI should advise on appointing Election Commissioners until Parliament made a law [2].
• Protection of voters' rights: In the SIR judgment (2026 INSC 564), the Court allowed the ECI only a limited enquiry into citizenship for the electoral roll. The ECI cannot declare anyone a non-citizen. Doubtful cases must go to the authority under the Citizenship Act. The whole exercise "remains amenable to judicial review" [3].
• Correcting the process: The Court ordered that Aadhaar be accepted as a document. It also allowed Bihar voters who were wrongly deleted to seek judicial review [3].

Where the check is limited

• Deference on administrative choices: The same SIR verdict upheld the exercise as traceable to Section 21(3), RP Act 1950 read with Article 324. It found the exercise proportionate and the document list a "considered exercise of administrative discretion" [3].
• Technical matters: ADR v. ECI (2024) refused 100% VVPAT counting and a return to paper ballots. It added only small safeguards: Symbol Loading Units sealed for 45 days, and a burnt-memory check of 5% of EVMs if the second- or third-placed candidate asks for it [4].
• Parliament can override: The CEC and ECs Act, 2023 replaced the CJI on the selection panel with a Union Cabinet Minister nominated by the PM [5].
• Constitutional bar: Article 329(b) says an election can be challenged only through an election petition. This keeps courts from stepping in while an election is under way.

Judicial review mainly controls how the ECI uses its power, not what it decides. Review would mean more if the ECI gave reasoned orders, published deletion data, and if SIR safeguards were written into law. That would protect Article 324's purpose of free and fair elections, the foundation of universal adult franchise under Article 326.