SIR Enumeration Form Raises Questions Over Compliance With Voter Roll Rules

The Enumeration Form being used in the ongoing Special Intensive Revision (SIR) of electoral rolls has raised legal questions about whether it complies with the Registration of Electors Rules (RER), 1960. At the centre of the debate is whether the Election Commission of India (ECI) can use a format different from Form-4, which the rules prescribe for collecting voter details during revisions.

Rule 8 of the RER, 1960, says Electoral Registration Officers may, for the purpose of preparing the roll, send letters of request in Form-4 to occupants of dwelling-houses in the constituency or any part of it. Every person receiving such a letter is required to furnish the information sought to the best of their ability. The model Form-4 does not contain pre-printed electoral details or seek information about a voter’s parents or relatives from previous electoral rolls. It has columns for the voter’s name, age, father’s, mother’s or husband’s name, signature and date.

The Enumeration Forms distributed by the ECI, however, came with pre-printed details of electors as per the 2025 electoral rolls. They also include columns seeking voters’ details from the 2002 SIR and, if the voter was a minor at the time, information about their parents or relatives. This format differs from the one prescribed under the RER, 1960, which also lays down procedures for different types of electoral roll revisions.

Rule 25, which deals with revision of rolls, states that where a roll or any part of it is to be revised intensively, it shall be prepared afresh and Rules 4 to 23 shall apply as they do for the first preparation of a roll. Since Rule 8, which prescribes Form-4 for collecting voters’ details based on a household survey, falls within the ambit of those rules, the ECI’s decision to use a different format has raised questions about compliance.

Telangana Chief Electoral Officer C. Sudharsan Reddy described the SIR as a 'de novo' preparation of electoral rolls. Critics argue that the exercise relies on the 2025 electoral rolls, prepared after a Special Summary Revision, rather than starting afresh through a household-based exercise as envisaged under Rule 8.

Activist Lubna Sarwath raised objections to the CEO’s characterisation of the exercise as 'de novo'. She said a de novo process is preparation of a voter roll afresh without reference to any previous roll, whereas the SIR 2026 undertaken in Telangana has references to the 2025 and 2002 electoral rolls. Pre-printed Enumeration Forms and 2002 mapping details, she said, were testimony against the CEO’s statements. Ms Sarwath also said the term 'de novo' had not been stated by the CEO or the ECI in any official documents relating to the SIR 2026. She said the CEO was using the phrase for the first time, even though citizens had been referring to a de novo voter list process and asking for it to be implemented.

Responding to a query, Mr Sudharsan Reddy said Form-4 had not been used for a long time in the preparation of electoral rolls, including during Special Summary Revisions. He said the format used in the SIR was based on the ECI’s decision.

The disagreement turns on whether the SIR is a genuinely fresh preparation of the rolls and whether the Enumeration Form meets the procedural requirements under the RER, 1960. Electoral roll revisions are significant because they determine the inclusion or exclusion of voters from the draft rolls.