"The power of the Election Commission under Article 324 is plenary but not unbounded." Discuss with reference to the Special Intensive Revision of electoral rolls.

Article 324 gives the Election Commission of India (ECI) "superintendence, direction and control" over electoral rolls and elections. The Supreme Court's 2026 ruling on the Special Intensive Revision (SIR) shows that this power is wide but must stay within statute, proportionality and judicial review [1].

Plenary: what SIR shows the ECI can do

• Constitutional and statutory base: The Court held SIR is "traceable to Section 21(3), RP Act, 1950 read with Article 324" [1]. Bihar's SIR was ordered in June 2025, the first intensive revision since 2003 [2].
• Legitimate aim: It responds to urbanisation, migration, unreported deaths and ineligible entries [2].
• Administrative discretion: The ECI can design its own documentation regime. Excluding the EPIC (voter ID card) is based on "intelligible criteria" [1].
• Citizenship check: Section 16 bars non-citizens from the roll, so the ECI can make a limited enquiry into citizenship [1].

Not unbounded: limits drawn by law and the Court

• Statute: SIR must not conflict with the RP Act and the 1960 Rules. Deletions must keep Rule 21A notice and hearing [1].
• Proportionality: Measures need a rational nexus with the objective, must not be manifestly excessive and must carry safeguards against arbitrary exclusion [1].
• No ruling on citizenship: Deletion "does not amount to a declaration" of non-citizenship. Doubtful cases must be referred within 4 weeks to the Citizenship Act authority, and the name restored if citizenship is confirmed [1].
• Presumption: Being on the roll creates a rebuttable presumption of validity [1].
• Remedies: People wrongly deleted as dead, shifted or duplicate can seek judicial review [1]. Statutory appeals under Section 24 lie to the District Magistrate, then the CEO [2].

Remaining concerns

• The burden of proof falls on poor, migrant and women voters with few documents. Aadhaar was added only by court order [1].
• Trust deficit: The ECI now runs SIR in phases, with Booth Level Agents, Special Roll Observers and care for vulnerable voters [3]. Whether this works must be verified.
• Any change to enrolment conditions, such as Form 6 declarations, should come through amendments to the Registration of Electors Rules, 1960, not through Article 324 alone.

Article 324 lets the ECI clean the rolls, but statute and fair procedure set the limits. Going forward, the ECI should publish booth-wise deletion reasons, report on referrals and run enrolment drives for migrants. This would make the Article 326 promise of universal adult franchise real, so that no eligible voter is left behind.