Former Union minister RK Singh has launched a sharp attack on Chief Election Commissioner Gyanesh Kumar over the Election Commission’s Special Intensive Revision (SIR) of electoral rolls, alleging multiple violations of electoral law and questioning the authority behind several decisions taken during the exercise.

In a strongly worded letter, Singh, a former BJP minister and retired IAS officer, alleged that the Election Commission had acted contrary to the provisions of the Representation of the People Act, 1950, while revising.

He questioned whether the decision to undertake an intensive revision across the country was taken by the full Commission or by Kumar alone.

Singh specifically invoked Section 21 of the Representation of the People Act, arguing that special revision of electoral rolls can be undertaken only in special circumstances and that the reasons must be recorded.

He alleged that applying such a revision across the entire country was therefore unlawful.

The former minister also raised questions over the use of revised electoral rolls while appeals against deletions were pending. According to his letter, the electoral roll in force when the revision was notified should continue to operate until the revision, including appeals against inclusion or deletion, was completed.

Singh alleged that despite pending appeals, a new roll containing deletions was used during elections. He described this as a violation of the law.

‘Who authorised it?’ Singh questions deletions, Form 6 changes

A significant portion of Singh’s letter focuses on the removal of voter names and the role of Electoral Registration Officers.

Citing Section 22 of the Representation of the People Act, Singh argued that an Electoral Registration Officer, rather than the Election Commission or another authority, has the statutory power to remove a voter’s name, subject to specified grounds, an enquiry and an opportunity for the affected person to be heard.

He alleged that voters whose names had been included in electoral rolls after 2003 were removed without individual enquiry or adequate notice.

Those affected, he claimed, were subsequently required to apply afresh through Form 6 and provide evidence of their eligibility.

Singh also cited the Supreme Court’s 1995 judgment in Lal Babu Hussain and Others v. Electoral Registration Officer and Others, arguing that the burden of producing material to challenge an enrolled voter should lie with the authority or objector, rather than the voter.

The former minister then turned to the changes made to Form 6, alleging that an additional appendix was introduced asking applicants to provide the serial number of their parents in the 2003 electoral roll.

Singh questioned who authorised the addition and alleged that it was introduced despite opposition from two Election Commissioners.

He argued that the requirement could particularly affect young first-time voters who may have difficulty accessing electoral rolls dating back more than two decades.

The letter also raises questions over bulk objections filed through Form 7.

Singh asks who filed the objections, how they were accepted and how they were acted upon when, according to his allegation, the individuals who signed them did not appear.

West Bengal features prominently in his claims. Singh alleges that 16 lakh voters who had been found valid by Electoral Registration Officers were not included in the electoral roll because appeals were filed against their inclusion.

He questions the grounds for those appeals and asks who authorised them.

Another issue flagged by Singh is the use of what he describes as 'logical discrepancy' to exclude voters.

He argues that differences in recorded ages between parents and children can occur because poorer citizens may not possess birth certificates or accurate records of their dates of birth.

Singh alleges that such voters were excluded without adequate enquiry.

He further argues that migrant workers and economically disadvantaged citizens could be disproportionately affected because returning to their home constituencies to complete documentation could mean losing wages.

The former minister claims that around 13 crore names have been deleted through SIR so far and argues that the scale of the deletions could have an impact on elections.

He contrasts the figure with the 2024 Lok Sabha election margin between the NDA and INDIA blocs at the national level.

Singh also questions the centralisation of electoral-roll amendments, alleging that statutory officials were prevented from exercising their powers while the revision process was effectively centralised.

The letter escalates its criticism by asking whether the alleged actions were undertaken by Kumar independently or whether he was acting on instructions from 'his bosses'.

Singh says a proposed impeachment of the CEC would be ineffective because the Opposition lacks the numbers required for such a move.

Instead, he calls for criminal cases against those responsible for what he describes as illegal actions.

He also calls for Opposition parties to unite over the issue and proposes changes to the process for appointing Election Commissioners.

Singh further argues that elections should be conducted through ballot papers rather than EVMs.

The letter concludes with an appeal to mobilise public opinion around the electoral-roll revision, with Singh warning that the issue concerns the functioning of Indian democracy.

Singh signed the letter as 'RK Singh, IAS Retd., Ex Union Home Secretary'.

The allegations contained in the letter represent Singh’s position and have not, in themselves, established that the Election Commission or Gyanesh Kumar committed the alleged violations.