The SIR does not formally compel any elector to furnish a mobile number, an Aadhaar number or a doorstep photograph. The exercise is, however, structured so that declining the digital submission of documents increases the probability of being recorded as unmapped, flagged, noticed or deleted. Where this digitised process cannot match an elector to the unevenly digitised legacy rolls, the elector must answer a notice, produce documents and attend a hearing. Each paper form nonetheless carries an undertaking that the booth level officer (BLO) has verified the elector against the last-SIR rolls, although the linkage was computed centrally. An elector excluded from the draft roll may return only through Form 6 with a declaration that can compel false disclosure. Between 20 November and 8 December 2025, the count of digitised Phase II forms rose from 10 crore to nearly 50 crore, with no published transcription-accuracy standard and in Delhi, 33.13 lakh notices rest on about 14,000 BLOs against a 29 October deadline. According to recent reports by The Reporters Collective and The Hindustan Times, in Delhi, the BLO App now carries a module to mark “VIP” electors, whose notices are reported to be resolved at their doorsteps while other electors have to queue for hearings. No purpose notice, retention schedule or grievance mechanism has been published, and the forgeries in Aland, Karnataka, have shown that the mobile and OTP infrastructure the exercise runs on can be forged at scale.BackgroundEnrolment on the electoral roll is the gateway to the right to vote under Article 326 of the Constitution and the Representation of the People Act, 1950. The proviso to Section 22 of that Act permits deletion of an entry only after the elector has been given a reasonable opportunity of being heard, and Lal Babu Hussein v Electoral Registration Officer (1995) attaches a presumption of validity to persons already on the rolls. The SIR inverts this legal standard as continued enrolment is conditioned on satisfying and matching an voters record against a database, on the database’s own data sources and in its preferred format and accuracy standards, and the consequences of administrative failure are visited on the elector. The pressure travels downward, from ECINET dashboards to district officials, to BLOs, to households. Part 1 described the undisclosed software and the admittedly defective digitisation of the base rolls as a problem of transparency and the structural centralisation through a digital system. Our second post concerns the data that machinery is fed and the persons required to feed it.AnalysisThe contents of the enumeration formOn accessing the ECINET app, each existing elector receives a pre-populated (already filled out) Enumeration Form carrying their name, EPIC number, roll photograph, polling part, address and date of birth, with a QR code whose contents the Commission has not explained. The form collects a current photograph, a mobile number, optional Aadhaar details, the EPIC numbers of family members, and the elector’s or their parents’ entries in the last-SIR rolls, down to district, part and serial number, as Annexure III of the Phase II instructions prescribes. Under the West Bengal CEO’s Press Note No. 28 of 17 November 2025, the booth level officer photographs the elector through the BLO App during the household visit, and the forms, with the documents and signatures they contain, are digitised. Online submission requires EPIC-to-mobile linkage and an OTP-based e-sign. Following the Supreme Court’s order of 8 September 2025, Aadhaar is the twelfth prescribed document, admissible as proof of identity though not of citizenship. Taken together, the exercise assembles a linked family graph of most of the adult population, joined to mobile numbers, current photographs and signatures, with the Commission’s presentation recording that booth level officers may match electors against an All-India database. In 2024, The Wire documented a single broker supplying voter data and booth-management software to more than 4,000 candidates, and IFF wrote to the ECI at that time on the resulting profiling risk. The SIR dataset is materially richer than anything in that ecosystem.The reversal of the burden of proofAt the announcement of Phase II, the Chief Election Commissioner described the design as shifting the burden of proof “from the citizens to the database”. The Phase II instructions direct that no document be collected during enumeration and that the ERO issue notices, after draft publication, to electors who could not be linked with the previous SIR rolls, the accompanying information sheet stating that notices follow where the particulars furnished are unavailable in, or fail to match, that database. The database in question comprised the 2002–05 rolls, digitised in haste, in multiple scripts, without published quality testing and the Commission simultaneously treated an extract of the digitised roll as documentary evidence in itself, announcing on 30 June 2025 that 4.96 crore electors on Bihar’s 2003 roll, about 60% of the electorate, needed no further documents.Where the mapping failed, and it failed at the scale of crores, the burden returned to the elector as a notice, a requirement to produce one of twelve prescribed documents, and a hearing, each paper form meanwhile prints an undertaking, above the booth level officer’s signature, that the details have been verified from the last-SIR rolls, a per-form human certification laid over a centrally computed match. Before the Supreme Court on 22 September 2026, the Commission’s counsel accepted that the twelve documents are not exhaustive and that any convincing material may be placed before the authority. The Phase II order additionally empowered registration officers to open suo motu enquiries wherever doubt arose “due to non-submission of requisite documents or otherwise”. The Commission has conceded, in conduct, the unreliability of the ground truth as set out in Part 1, it suspended hearings for unmapped electors in West Bengal in December 2025, citing the incomplete conversion of the 2002 rolls from PDF into CSV, and withheld auto-generated notices pending re-verification.Form 6, Form 8 and the attached declarationUnder the Registration of Electors Rules, 1960, Form 6 is the application for inclusion of a new elector, and Form 8 the application for correction or transposition on a change of residence. An elector excluded at the draft stage, including one successfully mapped to the legacy rolls, may return only through Form 6, to which a declaration has been attached. This routes electors who have merely shifted residence, for whom Form 8 is prescribed, and electors who never left their addresses, into declarations false on their face. In Parliament, K.C. Venugopal alleged that the declaration question was added to Form 6 without any formal amendment to the Rules. The Commission’s own Phase II Declaration Form, at Annexure IV, expressly provides an option for application through Form 8 on shifting, which sharpens the objection to Delhi’s Form 6 routing. The effect is that restoration of an entry deleted without the hearing contemplated by the proviso to Section 22 is conditioned upon executing a declaration prescribed by the deleting authority.The Indian Express has since reported that Election Commissioner Vivek Joshi warned on file in May 2026 that Form 6 could not be changed in this way without the government amending the Rules, and that Election Commissioner Sukhbir Singh Sandhu agreed. The question was added in July regardless, and in August Sandhu recorded that it was “unauthorised and illegal”Timelines, digitisation velocity and administrative pressureDelhi’s house-to-house enumeration ran from 30 June to 17 August 2026, and digitisation rates at the draft stage ranged from 83.43% in Rohini to 52.15% in Tughlakabad and the undigitised proportion of the electorate became, in substance, the excluded proportion. The Pune district administration’s SIR page records ERO directives requiring immediate distribution and collection of forms, mandatory achievement of targets within the stipulated timeline, daily online progress reports, and stating that “no negligence will be tolerated”. In West Bengal, district officials told The Reporters’ Collective that features, protocols and flagged-elector lists reached the BLO App almost daily without standard operating procedures.The velocity of data entry is documented in official bulletins. In Bihar, 1.18 crore forms were collected in a single 24-hour period in July 2025, with 77,895 booth level officers and about four lakh volunteers in the field. In Phase II, only 10 crore forms had been digitised by 20 November 2025, with Uttar Pradesh at 6.1% and Kerala at 3.39%, by 1 December about 40 crore and by 8 December nearly 50 crore had been digitised. Roughly 30 crore forms, each carrying names, dates and legacy-roll particulars, were keyed into the database in the eleven days between 20th November and 1st December, about 2.7 crore a day, with no published transcription accuracy standard or error audit.The notices were similarly issued in haste for instance, on 6 January 2026, the Commission directed the West Bengal CEO that all logical discrepancy notices be downloaded immediately and served within four to five days, with daily constituency-wise counts, for a list then standing at about 95 lakh names. The Supreme Court’s record reflects about 1.25 crore verification notices in West Bengal, and The Reporters’ Collective has alleged that more than 1.5 crore were centrally produced. When the workload overwhelmed the field administration, the Commission issued show-cause notices to its own registration officers for failing to upload about 1.15 lakh electors’ documents, amid reports of unreasoned rejections and system failures.Delhi reproduces the pattern at higher intensity with 33.13 lakh notices on about 14,000 booth level officers and 1,200 registration officers, about 237 notices per officer, against a disposal deadline of 29 October, with the Commission informing the Court it is open to an extension. The Court’s directions of 22 September, permitting responses over WhatsApp or email, and the extension of enumeration deadlines in four States on 15 July after booth level officers reported the schedule could not be met, are the only relief the timeline has received. The legal difficulty emerges that a schedule that makes individualised consideration administratively impossible is inconsistent with the safeguards of notice, hearing and reasoned decision on which the judgment of 27 May 2026 rested the validity of the exercise, and the cost of administrative haste is borne by the elector.A separate queue for ‘VIP’ electorsThe burden is not borne equally. The Reporters’ Collective decompiled the BLO App and found a “Mark VIP” module, added in an update around 30 July 2026 during Delhi’s enumeration. It lets a BLO recommend any elector in the booth for special status with a single click, and the recommendation is reviewed by officials before being uploaded to ERONET. Instructions relayed over WhatsApp from EROs asked BLOs to mark ministers and their families, celebrities, judges, advocates, bureaucrats, media persons and social workers, among others. The Manual on Electoral Rolls has long required certain categories, such as elected representatives, judges and holders of declared offices, to be flagged in the database, and PTI has reported that the Commission’s instructions provide for collecting documents from such electors. But the Representation of the People Act, 1950, creates no class of elector entitled to different treatment, and who is placed on these lists is not disclosed.In practice, the flag changes the procedure. One Assistant ERO told the reporters that when a VIP is flagged he generates no notice and instead sends a BLO to collect the documents, and that he had issued none to the more than 100 such electors in his constituency. Chief Minister Rekha Gupta’s notice was resolved within hours, without a hearing, while hearings at her Shalimar Bagh centre were proceeding booth by booth and had not yet reached hers. In the same constituency, a daily-wage worker flagged as unmapped lost a day’s pay queuing for a hearing on a notice written in English, which he could not read. A classification of electors by prominence, recorded in the software and administered through informal instructions, bears no rational nexus to eligibility and cannot be reconciled with Article 14 or the equal franchise under Article 326.Data protection and securityThe enumeration data is being processed for a new purpose with almost nothing published about the processing. There is no notice to electors of purposes, no retention schedule for photographs, signatures and family linkages, and no grievance mechanism, notwithstanding the notice, purpose limitation and erasure principles in Sections 4, 5 and 8 of the Digital Personal Data Protection Act, 2023. Section 8(3) of that Act obliges a data fiduciary to ensure the completeness, accuracy and consistency of personal data used to make a decision affecting the individual, and Section 8(5) requires reasonable security safeguards. There is no compliance or audit reports for either has been published for the digitised legacy particulars or the keyed form data on which deletions rest, and the West Bengal Chief Minister’s January letter alleged that no acknowledgements were even issued for submitted documents. The only published safeguard is a line in the Bihar CEO’s press notes that documents uploaded to ECINET are accessible to authorised election officials alone. While the DPDPA is not yet in force and hence not binding as law it still requires a duty cast on public authorities in such a large scale data collection authorities to at the very least aim for compliance by May, 2027. Here as to whether the legitimate use and State exemption provisions in Sections 7 and 17 extend to the whole of this processing is a question no authority has been required to answer.This article was first published on Internet Freedom Foundation as part of a series analysing the SIR. Read the original.