"Universal adult franchise is meaningful only if electoral rolls are inclusive." Discuss this in light of the Supreme Court's May 2026 verdict on the Special Intensive Revision of electoral rolls.

Article 326 gives the vote to every citizen aged 18 or above. In practice, that right exists only through the electoral roll. Section 21(3), RP Act, 1950 lets the ECI order a special revision for recorded reasons [2]. On May 27, 2026, the Supreme Court upheld Bihar's Special Intensive Revision (SIR) on this basis [1]. The verdict shows that a roll must be accurate and also inclusive.

Why the Roll Decides the Franchise

• Gatekeeper: a citizen whose name is missing cannot vote. The Court called the roll "the legal record of that political community" [1].
• Integrity: dead and shifted entries dilute honest votes. Bihar's enumeration phase reported over 20 lakh deceased and over 30 lakh permanently shifted electors [3].

How the Verdict Protects Inclusion

• Limited enquiry: the ECI may examine citizenship only to decide roll eligibility. This is not a citizenship determination "in the strict sense", and its consequences are electoral alone [1].
• Referral, not finality: doubtful cases go to the competent authority under the Citizenship Act, 1955. Those deleted as non-citizens must be referred within four weeks, with decisions preferably before the next election [1].
• Due process: notice and hearing under Rule 21A were held "preserved in substance". Aadhaar was added to the documents, and wrongly deleted voters may seek judicial review [1].

Concerns for Inclusion

• Weaker presumption: the Court held that a name on the roll carries only a rebuttable presumption of validity [1]. It confined Lal Babu Hussein (1995), which had stressed natural justice before deletion [2], to adjudicatory proceedings [1]. Settled voters may thus have to re-prove eligibility.
• Migrants at risk: the "shifted" label rests on house visits. It can catch seasonal migrants who are still citizens [3].
• Costly remedy: judicial review is hard for the poor to access, and deleted voters may miss elections in the meantime.

The verdict balances roll purity with real safeguards, but inclusion depends on how those safeguards are applied. The ECI should write notice, hearing and reasoned orders into the Registration of Electors Rules. It should also publish deletions with reasons, re-verify migrants before marking them "shifted", and finish citizenship referrals before polls. This is the "care, fairness" the Court itself urged [1], and it would keep Article 326's promise of universal adult franchise real.