Bihar Electoral Roll Revision Begins as EC Launches NRC-Like Voter Verification Drive

Bihar Electoral Roll Revision Begins as EC Launches NRC-Like Voter Verification Drive

The current term of the Bihar state assembly ends on November 22, 2025. Elections, therefore, have to be held before that date.

Section 21(3) of the Representation of the People Act, 1950, authorises the Election Commission of India (ECI), to ‘direct a special revision of the electoral roll for any constituency or part of a constituency in such manner as it may think fit’ … ‘at any time, for reasons to be recorded’.

This is further reinforced by Rule 25 of the Registration of Electors Rules, 1960, which says, ‘The roll for every constituency shall be revised under sub-section (2) of section 21 either intensively or summarily or partly intensively and partly summarily, as the Election Commission may direct.’

On June 24, 2025, ECI

1. issued a four-page press note announcing that it will ‘begin Special Intensive Revision of Electoral Rolls in Bihar’, and 

2. wrote a 19-page letter to the Chief Electoral Officer (CEO) of Bihar with the subject – ‘Special Intensive Revision w.r.t. 01.07.2025 as the qualifying date’ – consisting of a three-page letter with four annexures:

1. a three-page ‘ORDER’ titled ‘Special Intensive Revision of Electoral Rolls’,
2. a nine-page ‘Detailed Guidelines For Special Intensive Revision’, 
3. a two-page ‘Enumeration Form’ including a ‘Declaration’ format, and
4. a two-page ‘Declaration Form’ including an ‘Indicative (not exhaustive) list of documents to be submitted in support of the declaration (separate self attested documents to be submitted for Self, Father and Mother, if mentioned above, except where extract of the Electoral Roll of Bihar with qualifying date 01.01.2003 is used, which will be considered as a sufficient document in itself)’.

Paragraph 7 of the letter to the CEO of Bihar states that ‘SIR (Special Intensive Revision) [is] to be undertaken strictly within the timeline as per the following schedule.’ 

The schedule shows that the process was to begin on June 25, 2025. Note that the letter itself is dated June 24, 2025. This is what will need to happen:

• ERO (electoral registration officers) to print pre-filled Enumeration Forms (in duplicate) for all existing electors and give it to the respective BLOs (booth-level officers)’, 
• then, training to be given to BLOs, 
• then, distribution of enumeration forms by going from house to house, 
• subsequently, the collection of the filled/corrected forms, again by going from house to house, 
• the checking and verification of Enumeration Forms by superior officials, 
• the rationalisation/re-arrangement of polling stations and finalisation of proposed restructuring of section/part boundaries, location of polling stations and obtaining approval of list of polling stations,
• the publication of draft electoral roll on August 01, 2025,
• followed by a period for filing claims and objections, and 
• final publication of the electoral roll on September 30, 2025.

Need and timing for the ‘Special Intensive Revision’

The press note says:

“Various reasons such as rapid urbanization, frequent migration, young citizens becoming eligible to vote, non-reporting of deaths and inclusion of the names of foreign illegal immigrants have necessitated the conduct of an intensive revision so as to ensure integrity and preparation of error-free electoral rolls.”

Paragraph 4 of the order of June 24, 2025 says:

“Whereas, in line with this objective, the Commission has previously exercised its powers under enabling statutes in the years such as 1952-56, 1957, 1961, 1965, 1966, 1983-84, 1987-89, 1992, 1993, 1995, 2002, 2003 and 2004 to undertake Intensive Revision of electoral rolls for all or some parts of the country for afresh preparation of electoral rolls through enumeration. The last intensive revision in Bihar, was conducted by the Commission in the year 2003 with reference to 01.01.2003 as the qualifying date.”

This raises an issue.

Have ‘rapid urbanization, frequent migration, young citizens becoming eligible to vote, non-reporting of deaths and inclusion of the names of foreign illegal immigrants’ intensified in the last few years or have they been on-going phenomena?

Following this, it is surprising that while from 1952 to 2004, such revisions seem to have been done much more frequently, the ECI has not felt the need for doing so for the last 21 years!

The current ECI might say that they are not responsible for what happened between 2004 and now but that may not be an adequate explanation because the ECI is an institution which is expected to function continuously irrespective of the individuals who come and go. There has to be some institutional memory and 21 years is not an insignificant period of time by any standard.

Feasibility of the time frame

The time frame for the entire exercise as summarised at above appears to be extremely ambitious.

Not to overstress the supreme optimism in the expectation that EROs will start printing pre-filled enumeration forms for all existing electors and giving them to the respective BLOs on June 25, 2025 after receiving the instructions by email or WhatsApp on June 24, 2025, but expecting two rounds of house-to-house survey after having been trained (assuming training materials are ready), preparation of draft electoral rolls, rationalisation or re-arrangement of polling stations and finalisation of proposed restructuring of section or part boundaries, location of polling stations, dealing with objections or claims after providing sufficient time for their filing, to be completed in just three months, seems a really tall order.

Perhaps the ECI can take some advice from the Registrar General and Census Commissioner of India.

A related issue is the starting time. Conducting an intensive revision is clearly a very useful activity. Could it not have been started a few months earlier?

ECI states in the press note, reassuringly, that it ‘shall be seeking active involvement of all political parties in the process.’

It adds, ‘It may be underscored that both, the electors and the political parties, are the most important stakeholders in any electoral process and it is only with their full participation that an exercise of such magnitude can be conducted smoothly and successfully.’

Might it not have been useful and was it not possible to include ‘the most important stakeholders in any electoral process’ in the planning process for ‘an exercise of such magnitude’?

Legal and procedural issues

Voters registered in Bihar after January 1, 2003

Paragraph 11 of the Order of June 24, 2025 reads as follows:

‘Since the last intensive revision in Bihar was undertaken in 2003, the EROs shall treat the electoral roll of 2003 with qualifying date of 01.01.2003 as probative evidence of eligibility, including presumption of citizenship unless they receive any other input otherwise.’ 

It is followed by paragraph 12 which reads:

‘Any person whose name is not recorded in the 2003 Electoral Roll shall for the purpose of registration in the electoral roll is required to submit from amongst a wide range of eligible government documents as prescribed for establishing their eligibility to be an elector.’

Read together, and in simple English (devoid of legalese), these mean that all those registered as voters after January 1, 2023, are not registered voters and, to add insult to injury, not presumed to be citizens of India.

This may sound like an exaggeration but it follows directly from what Paragraph 11 says:

‘…the EROs shall treat the electoral roll of 2003 with qualifying date of 01.01.2003 as probative evidence of eligibility, including presumption of citizenship…’

This is reinforced by Paragraph 12 which says that such persons (those not enrolled as voters on January 1, 2003) will be ‘required to submit from amongst a wide range of eligible government documents as prescribed for establishing their eligibility to be an elector.’

The ‘wide range of eligible government documents’ given in the ‘indicative (not exhaustive) list of documents to be submitted in support of the declaration’ are very similar to documents required to be produced to establish one’s citizenship.

Here the ECI is on firm ground because Article 326 of the Constitution of India states that ‘every person who is a citizen of India…shall be entitled to be registered as a voter at any such election’.

However, three issues still remain. 

One, if these persons who were not registered as voters on January 1, 2003 but were registered later, are not to be considered registered voters now, what happens to the votes they cast in all the intervening elections from January 2003 till now?

Are all those votes and the election results based on those votes, invalid? How do we deal with this?

Two, again, if these persons who were not registered as voters on January 1, 2003 but were registered later, are not to be considered registered voters now, does this not mean that for all practical purposes their names have been deleted from the electoral roll? This creates a problem.

Rule 21A of the Registration of Electors Rules, 1960 is titled ‘Deletion of name’ and provides a process for deletion of names registered in the electoral roll. This process, inter alia, requires that ‘before taking any action under this rule in respect of any person…the registration officer shall make every endeavour to give him a reasonable opportunity to show cause why the action proposed should not be taken in relation to him’.

This means that all those persons who were not registered as voters on January 1, 2003 but were registered later, have now been deprived of their legal right for this ‘reasonable opportunity’. If any of these deprived persons decides to go to court for this violation, the courts will have to decide this issue.

The third issue pertains to what amounts to a change in the procedure for registration of voters. The current procedure, before June 24, 2025, required a person wishing to be registered as a voter, to fill Form 6, given in the Registration of Electors Rules, 1960, and the person is required to give the following declaration:

‘DECLARATION – I hereby declare that to the best of knowledge and belief – 

1. I am a citizen of India and place of my birth is Village/Town ____ District ____ State ____
2. I am ordinarily resident at the address given at (h) above since ____ (date, month, year).
3. I have not applied for the inclusion of my name in the electoral roll for any other constituency. 
4. *My name has not already been included in the electoral roll for this or any other assembly/ parliamentary constituency

OR

*My name may have been included in the electoral roll for ____ Constituency in ____ State in which I was ordinarily resident earlier at the address mentioned below and if so, I request that the same may be deleted from that electoral roll.

* strike off the option not appropriate’

Form 6 does not require any information regarding the parents of the applicant.

Now, there is an ‘indicative’ (not exhaustive) list of documents to be submitted in support of the declaration with separate self-attested documents to be submitted for self, father and mother.

This is a major departure from the practice that has existed for many years and there is no specific explanation provided for this major change.

Practical issues

The first major practical issue is that of timing and feasibility primarily arising from the conditions in rural Bihar such as literacy, computer literacy, availability or lack of power, and the elephant-in-the-room in Bihar – migration.

As of now, all the forms seem to be in English. Even assuming that they will be translated into Hindi and possibly other local languages, literacy remains a challenge.

‘Key highlights’ attached to the press note say the following:

• ‘EROs to print pre-filled Enumeration Form (EF) for all existing electors as on the date of the order and give it to BLOs.
• ‘BLOs to distribute EFs to all existing electors through House-to-House visit
• ‘EF will be available on the ECI website/ECINET which can be downloaded by an elector whose name is in the electoral roll as on the date of the order’.

While it is very nice for the EF to be available on the ECI website/ECINET but the question arises as to how many electors in rural Bihar will be computer-literate enough to download the EF, or will have the equipment to do so, or will have adequate supply of electricity to do so

Then there is the issue of migration. The propensity of people from Bihar to migrate to other states in search of livelihood is widely known. Imagine the plight of migrants who are earning a living working outside the state, often under difficult conditions. They will not be found ‘at home’ when the BLO goes to their ‘house’ in the village to give and then to collect the EF. Will they be in a position to ‘download’ the EF while working at a construction site in Mumbai? 

How many such and other unfortunate electors will be disenfranchised because of these impractical provisions is anyone’s guess.

Transparency

The fourth paragraph of the press note has a very curious and interesting provision. It says the following:

‘Now, to ensure complete transparency, it would be necessary that the documents on the basis of which such satisfaction of ERO is arrived at, are also uploaded in ECINET as the current level of technology enables so. However, these documents shall be accessible to authorized election officials only keeping in view the privacy issues.’

This is truly delectable.

While the documents will be uploaded in ECINET ‘to ensure complete transparency’, ‘(h)owever, these documents shall be accessible to authorized election officials only…’

How transparent can one get!

Another view

In a June 25, 2025 editorial, a national daily has said:

‘So, birth certificates for those born after 2004, who also need to furnish parents’ documents, as proof of citizenship will throw up a gazillion issues. Already, there are fears that the ‘illegal immigrant’ electoral plank, in a state where EBCs include Muslim groups, will rear its head – as it did in pre-poll Jharkhand.’

It goes on to add, ‘Vagaries of monsoon are certainly not the time for poor Bihar voters to be scurrying around to prove, via documents, their eligibility as a voter.’

Thus, the proposed Special Intensive Revision  of electoral rolls for Bihar, as envisaged by the ECI in the documents available in the public domain so far, appears to be impractical given the schedule the ECI has itself laid down.

The revision might result in the disenfranchisement of a substantial number of electors of Bihar.

The procedure specified for the revision circumvents and violates existing legal provisions that the ECI has been following for a long time. This has the potential to create legal complications.

Last word

The list (indicative not exhaustive) of documents required to be produced, including some for the applicant’s parents reminds one of the slogan ‘kagaz nahin dikhayenge (we won’t show our papers)‘ used during the protests against the Citizenship Amendment Act and the National Register of Citizens.

And this leads to the next logical question. Is this electoral roll revision or is this the NRC?

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