CCG open letter to the Election Commission of India: Urgent need for updated, accurate electoral rolls

2 September 2021


Shri Sushil Chandra

Chief Election Commissioner

Dear Shri Chandra,

Our group of former civil servants is nonpartisan and believes firmly in the Constitution of India. We have had a number of opportunities to interact with your predecessors in the Election Commission of India (ECI) over the past four years on issues relating to the impartiality and integrity of the electoral process, which is the bedrock of our democracy.

As part of our duty as responsible citizens of India, we had constituted the Citizens’ Commission on Elections (CCE), which brought out its reports in two volumes earlier this year (Report of the Citizens’ Commission on Elections – Vol. I and Report of the Citizens’ Commission on Elections – Vol. II). While a number of critical issues pertaining to the conduct of elections have been brought out in these two reports, our present letter focuses on the integrity and accuracy of the electoral rolls, including special care to include vulnerable populations, which alone guarantee the citizen of India her/his precious and basic right to vote. Vol. II of the CCE report highlights the following aspects:

(i) the persistence of the exclusion of vulnerable and disadvantaged groups, such as persons from religious and caste minority communities, women, Dalits, Adivasis (especially Particularly Vulnerable Tribal Groups or PVTGs), trans-people, the urban homeless, persons with disabilities and persons with mental health issues, from the electoral rolls;

(ii) failure of the Electoral Registration Officers (EROs) to ensure the full and verifiable enrolment of persons from all such categories;

(iii) discrepancies in the registration process wherein, even if a person is provided with an EPIC, there is no guarantee that her/his name will figure in the relevant electoral roll;

(iv) problems in voting for categories like circular migrant labour and those whose physical condition (due to age and disability) inhibit their travel to polling stations to vote.

In view of the above infirmities in the electoral registration process, we suggest the following remedial measures for your urgent consideration:


  1. Ensuring registration of all eligible voters

It must be impressed upon EROs that it is their paramount duty to ensure that all eligible voters are included in the electoral rolls. If certain populations are excluded from electoral rolls because of their social and economic disadvantage, this amounts to their disenfranchisement and the denial to them of their most fundamental right in a democracy, namely to cast their vote during general, state, municipal and panchayat elections. Due care should be taken by the EROs to scrupulously attend to claims and objections from citizens for inclusion, deletion and corrections to voter records. While the central and state election staff must do all that it takes to undertake a thorough exercise to include all names, we urge that the electoral registration (ER) machinery in the districts and municipal areas also enlist the active support and cooperation of NGOs and civil society groups who can bring to the notice of the ER machinery the names of those not enrolled. Political parties registered in the respective constituencies could also be requested, indeed encouraged and facilitated, to bring to the notice of the ERO such excluded names, which can then be verified by the ER machinery. It is essential that the ECI appoints senior civil servants from outside the state/UT where such exercise is under way as Special Observers to oversee the electoral registration process to ensure accuracy and objectivity.

In particular, we wish to stress the need for the ECI to make special rules for the urban homeless and put in place special measures for differently abled persons. The normal procedures for registration and verification that apply before a name is included in the electoral lists create virtually unsurpassable barriers for the urban homeless. Typically, homeless women and men have no documents that prove their identity or address. For these groups (members of which have no homes), special rules that permit either self-verification, or verification by any individual whose name exists in the electoral lists, are needed. Since they have no fixed address, we propose that the address of the nearest homeless shelter where they sleep at night, or the address of an NGO that works with homeless populations in the city, should suffice for purposes of the electoral list.

Any information that is publicly required to be made available to people about the election processes etc must be available in accessible formats. Information necessary to enable a person to exercise her franchise in a legal and informed way must be made accessible to all, especially people who communicate differently. There should be detailed awareness drives and some proactive measures (with civil society assistance) to get vulnerable populations, including persons with disabilities, to exercise their right to vote.


  1. Foolproof mechanism for verification by voter of inclusion of name in relevant part of electoral roll

There have been far too many instances in recent years of voters reaching polling stations on voting day and finding their names missing from the electoral rolls, most often because of deletion/transposition of names without notice to voters. The insistence of the ECI on publishing the electoral rolls as image PDF files online makes prior verification of a voter’s name an arduous task, requiring scrolling through many pages to locate her/his name. There is also evidence to show discrepancies between the NVSP data and the electoral rolls. Unless a simple process for verification of voter names by electoral roll part is developed (as outlined in point no. 5 of this letter), this problem will continue to trouble voters.


  1. Deletion of duplicate names, shifted/dead voters

To check bogus voting, concerted efforts need to be made to systematically weed out names of those voters who have relocated elsewhere or are no more, especially given the migration and mortality trends in the Covid pandemic period. The electoral rolls are also replete with duplicate entries. Assistance should be taken, as mentioned earlier, of civil society groups and political parties to weed out names. With regard to duplicate entries, metaphones and fuzzy-matching approaches can be employed to identify similar voter-name and relative-name sets. Thereafter, photographs of voters within these sets can be compared using image comparison software. There is need to improve the data entry software, with built-in warnings when duplicate entries are being made and verification by the ERO where such warnings are ignored by lower staff.


  1. Using Aadhaar to validate Voter IDs constitutes a gross violation of the citizen’s right to privacy

The Aadhaar ID is meant to be used for specific purposes, such as disbursal of benefits. The EPIC-Voter ID is given to voters by a constitutional authority (the ECI) and forms the basis of the electoral roll, whereas the Aadhaar ID is a government sponsored identity. Linking the Voter ID and the Aadhaar number appears to be clearly unconstitutional, apart from not being provided for in the Aadhaar Act (the 2017 judgment of the Supreme Court in Puttaswamy vs. Union of India is relevant here) or in the Representation of the People Acts, 1950 and 1951. Those whose Aadhaar fails on authentication due to biometric change (as in those of advanced age), technology failure or any other reason are excluded whenever authentication is required. This has been the unfortunate experience of ration card holders in different parts of the country. The Telangana CEO reported in September 2018 that 2.2 million people were excluded from the electoral rolls after Aadhaar based “verification” was carried out in 2015, thus depriving them of the right to vote in the general elections to the Telangana legislative assembly. Enrolment and continuance of names on the electoral rolls is based on the integrity of the electoral database. The risk of the electoral database being compromised will be far higher if it is linked to the Aadhaar database, which is not under the control of the ECI and can be tampered with by an outside body. The Cambridge Analytica episode, highlighted in 2018, brings out the dangers of influencing voters by targeting messages to them based on their psychometric profiles. It is very likely that the linkage of Aadhaar numbers to Voter IDs would allow the targeted manipulation of the beneficiaries of subsidies, benefits and services. We strongly oppose any move to link Aadhaar numbers with Voter IDs.


  1. Ensuring error-free, verifiable electoral rolls

Three aspects must guide the preparation of electoral rolls: (a) processes for inclusion of all voters, irrespective of whether they apply or not; (b) avoiding exclusion through correct processing of all applications for inclusion and ensuring no spurious deletions; (c) ensuring no duplicate/false entries.      These require careful process design at community levels and defining standards of data processing and data organisation that will enable local communities to publicly audit and verify all additions and deletions from electoral rolls.

We recommend maintaining of electoral records on online Public Bulletin Boards, enabling both complete transparency and public verifiability of all decisions regarding enrolments, updations and deletions. Two such public bulletin boards should be maintained by the ECI for each assembly constituency with updation as and when changes occur:

(i) A self-contained bulletin board of the entire electoral roll, which will be the official master electoral roll correct up to the time of the last update. The list of valid voters on any date can be publicly determined from this bulletin board.

(ii) A bulletin board of transaction records, which enables every voter given a receipt for application for enrolment, updation or deletion to search for the application process status on this bulletin board.

A detailed exposition on these Bulletin Boards may be viewed in Vol. II of the CCE Report (link given in paragraph 2 of this letter).


We reiterate our complete opposition to the linking of Aadhaar numbers and Voter IDs which, in our opinion, constitute a gross violation of the right to privacy of the individual while also allowing executive manipulation of access to beneficiaries to influence election outcomes.


We had earlier sent the ECI copies of both the volumes of our Report for examination and comment but have not heard from you so far. The links to the two volumes are given in the body of this letter. We urge you to respond to our concerns and take remedial actions as suggested in the two volumes. The matter assumes urgency in view of the upcoming general elections to state assemblies in 2022.


Our representatives are available for any discussion with the ECI on the issues involved.




Yours sincerely,


Constitutional Conduct Group


(100 signatories, as below)


1. Anita Agnihotri IAS (Retd.) Former Secretary, Department of Social Justice Empowerment, GoI
2. Salahuddin Ahmad IAS (Retd.) Former Chief Secretary, Govt. of Rajasthan
3. V.S. Ailawadi IAS (Retd.) Former Vice Chairman, Delhi Development Authority
4. S.P. Ambrose IAS (Retd.) Former Additional Secretary, Ministry of Shipping & Transport, GoI
5. Anand Arni RAS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI
6. G. Balachandhran IAS (Retd.) Former Additional Chief Secretary, Govt. of West Bengal
7. Vappala Balachandran IPS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI
8. Gopalan Balagopal IAS (Retd.) Former Special Secretary, Govt. of West Bengal
9. Chandrashekhar Balakrishnan IAS (Retd.) Former Secretary, Coal, GoI
10. Rana Banerji RAS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI
11. Sharad Behar IAS (Retd.) Former Chief Secretary, Govt. of Madhya Pradesh
12. Aurobindo Behera IAS (Retd.) Former Member, Board of Revenue, Govt. of Odisha
13. Madhu Bhaduri IFS (Retd.) Former Ambassador to Portugal
14. K.V. Bhagirath IFS (Retd.) Former Secretary General, Indian Ocean Rim Association, Mauritius
15. Pradip Bhattacharya IAS (Retd.) Former Additional Chief Secretary, Development & Planning and Administrative Training Institute, Govt. of West Bengal
16. Ravi Budhiraja IAS (Retd.) Former Chairman, Jawaharlal Nehru Port Trust, GoI
17. Sundar Burra IAS (Retd.) Former Secretary, Govt. of Maharashtra
18. R. Chandramohan IAS (Retd.) Former Principal Secretary, Transport and Urban Development, Govt. of NCT of Delhi
19. Rachel Chatterjee IAS (Retd.) Former Special Chief Secretary, Agriculture, Govt. of Andhra Pradesh
20. Gurjit Singh Cheema IAS (Retd.) Former Financial Commissioner (Revenue), Govt. of Punjab
21. F.T.R. Colaso IPS (Retd.) Former Director General of Police, Govt. of Karnataka & former Director General of Police, Govt. of Jammu & Kashmir
22. Anna Dani IAS (Retd.) Former Additional Chief Secretary, Govt. of Maharashtra
23. Vibha Puri Das IAS (Retd.) Former Secretary, Ministry of Tribal Affairs, GoI
24. P.R. Dasgupta IAS (Retd.) Former Chairman, Food Corporation of India, GoI
25. Pradeep K. Deb IAS (Retd.) Former Secretary, Deptt. Of Sports, GoI
26. Nitin Desai   Former Chief Economic Adviser, Ministry of Finance, GoI
27. Keshav Desiraju IAS (Retd.) Former Health Secretary, GoI
28. M.G. Devasahayam IAS (Retd.) Former Secretary, Govt. of Haryana
29. Sushil Dubey IFS (Retd.) Former Ambassador to Sweden
30. A.S. Dulat IPS (Retd.) Former OSD on Kashmir, Prime Minister’s Office, GoI
31. K.P. Fabian IFS (Retd.) Former Ambassador to Italy
32. Arif Ghauri IRS (Retd.) Former Governance Adviser, DFID, Govt. of the United Kingdom (on deputation)
33. Gourisankar Ghosh IAS (Retd.) Former Mission Director, National Drinking Water Mission, GoI
34. Suresh K. Goel IFS (Retd.) Former Director General, Indian Council of Cultural Relations, GoI
35. H.S. Gujral IFoS (Retd.) Former Principal Chief Conservator of Forests, Govt. of Punjab
36. Meena Gupta IAS (Retd.) Former Secretary, Ministry of Environment & Forests, GoI
37. Ravi Vira Gupta IAS (Retd.) Former Deputy Governor, Reserve Bank of India
38. Wajahat Habibullah IAS (Retd.) Former Secretary, GoI and former Chief Information Commissioner
39. Deepa Hari IRS (Resigned)  
40. Siraj Hussain IAS (Retd.) Former Secretary, Department of Agriculture, GoI
41. Kamal Jaswal IAS (Retd.) Former Secretary, Department of Information Technology, GoI
42. Najeeb Jung IAS (Retd.) Former Lieutenant Governor, Delhi
43. Brijesh Kumar IAS (Retd.) Former Secretary, Department of Information Technology, GoI
44. Sudhir Kumar IAS (Retd.) Former Member, Central Administrative Tribunal
45. Harsh Mander IAS (Retd.) Govt. of Madhya Pradesh
46. Amitabh Mathur IPS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI
47. Lalit Mathur IAS (Retd.) Former Director General, National Institute of Rural Development, GoI
48. Aditi Mehta IAS (Retd.) Former Additional Chief Secretary, Govt. of Rajasthan
49. Sonalini Mirchandani IFS (Resigned) GoI
50. Satya Narayan Mohanty IAS (Retd.) Former Secretary General, National Human Rights Commission
51. Deb Mukharji IFS (Retd.) Former High Commissioner to Bangladesh and former Ambassador to Nepal
52. Shiv Shankar Mukherjee IFS (Retd.) Former High Commissioner to the United Kingdom
53. Gautam Mukhopadhaya IFS (Retd.) Former Ambassador to Myanmar
54. Sobha Nambisan IAS (Retd.) Former Principal Secretary (Planning), Govt. of Karnataka
55. Surendra Nath IAS (Retd.) Former Member, Finance Commission, Govt. of Madhya Pradesh
56. P.A. Nazareth IFS (Retd.) Former Ambassador to Egypt and Mexico
57. P. Joy Oommen IAS (Retd.) Former Chief Secretary, Govt. of Chhattisgarh
58. Amitabha Pande IAS (Retd.) Former Secretary, Inter-State Council, GoI
59. Maxwell Pereira IPS (Retd.) Former Joint Commissioner of Police, Delhi
60. Alok Perti IAS (Retd.) Former Secretary, Ministry of Coal, GoI
61. G.K. Pillai IAS (Retd.) Former Home Secretary, GoI
62. Rajesh Prasad IFS (Retd.) Former Ambassador to the Netherlands
63. Sharda Prasad IAS (Retd.) Former Director General (Employment and Training), Ministry of Labour and Employment, GoI
64. R.M. Premkumar IAS (Retd.) Former Chief Secretary, Govt. of Maharashtra
65. Rajdeep Puri IRS (Resigned) Former Joint Commissioner of Income Tax, GoI
66. T.R. Raghunandan IAS (Retd.) Former Joint Secretary, Ministry of Panchayati Raj, GoI
67. N.K. Raghupathy IAS (Retd.) Former Chairman, Staff Selection Commission, GoI
68. V.P. Raja IAS (Retd.) Former Chairman, Maharashtra Electricity Regulatory Commission
69. C. Babu Rajeev IAS (Retd.) Former Secretary, GoI
70. K. Sujatha Rao IAS (Retd.) Former Health Secretary, GoI
71. M.Y. Rao IAS (Retd.)  
72. Satwant Reddy IAS (Retd.) Former Secretary, Chemicals and Petrochemicals, GoI
73. Vijaya Latha Reddy IFS (Retd.) Former Deputy National Security Adviser, GoI
74. Julio Ribeiro IPS (Retd.) Former Adviser to Governor of Punjab & former Ambassador to Romania
75. Aruna Roy IAS (Resigned)  
76. Manabendra N. Roy IAS (Retd.) Former Additional Chief Secretary, Govt. of West Bengal
77. A.K. Samanta IPS (Retd.) Former Director General of Police (Intelligence), Govt. of West Bengal
78. Deepak Sanan IAS (Retd.) Former Principal Adviser (AR) to Chief Minister, Govt. of Himachal Pradesh
79. G. Sankaran IC&CES (Retd.) Former President, Customs, Excise and Gold (Control) Appellate Tribunal
80. N.C. Saxena IAS (Retd.) Former Secretary, Planning Commission, GoI
81. A. Selvaraj IRS (Retd.) Former Chief Commissioner, Income Tax, Chennai, GoI
82. Ardhendu Sen IAS (Retd.) Former Chief Secretary, Govt. of West Bengal
83. Abhijit Sengupta IAS (Retd.) Former Secretary, Ministry of Culture, GoI
84. Aftab Seth IFS (Retd.) Former Ambassador to Japan
85. Ashok Kumar Sharma IFoS (Retd.) Former MD, State Forest Development Corporation, Govt. of Gujarat
86. Ashok Kumar Sharma IFS (Retd.) Former Ambassador to Finland and Estonia
87. Navrekha Sharma IFS (Retd.) Former Ambassador to Indonesia
88. Pravesh Sharma IAS (Retd.) Former Additional Chief Secretary, Govt. of Madhya Pradesh
89. Raju Sharma IAS (Retd.) Former Member, Board of Revenue, Govt. of Uttar Pradesh
90. Rashmi Shukla Sharma IAS (Retd.) Former Additional Chief Secretary, Govt. of Madhya Pradesh
91. Satyavir Singh IRS (Retd.) Former Chief Commissioner of Income Tax, GoI
92. Sujatha Singh IFS (Retd.) Former Foreign Secretary, GoI
93. Tara Ajai Singh IAS (Retd.) Former Additional Chief Secretary, Govt. of Karnataka
94. Tirlochan Singh IAS (Retd.) Former Secretary, National Commission for Minorities, GoI
95. Narendra Sisodia IAS (Retd.) Former Secretary, Ministry of Finance, GoI
96. Parveen Talha IRS (Retd.) Former Member, Union Public Service Commission
97. Thanksy Thekkekera IAS (Retd.) Former Additional Chief Secretary, Minorities Development, Govt. of Maharashtra
98. P.S.S. Thomas IAS (Retd.) Former Secretary General, National Human Rights Commission
99. Hindal Tyabji IAS (Retd.) Former Chief Secretary rank, Govt. of Jammu & Kashmir
100. Ramani Venkatesan IAS (Retd.) Former Director General, YASHADA, Govt. of Maharashtra




One thought on “CCG open letter to the Election Commission of India: Urgent need for updated, accurate electoral rolls

  1. Mahabir Singh Yadav

    I want to draw the kind attention of the CCG,towards the deterioration of RPA Act,by vested interests of political parties. There is no true representation of people in the Parliament, State assembly etc.As the elected representatives are elected by the nearly 25 % of the registered voters.When the elected candidate is not the choice of 75% of the registered voters, than how can he be the representative of the majority of the people? This negates the essence of democracy. There is urgent need to address this loop hole in our democratic process. Thanks.


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