New Delhi: The Forum for Electoral Integrity (FEI), a civil society coalition formed in 2010 and headed by former IAS officer M.G. Devasahayam, on Thursday (July 23) wrote to National Human Rights Commission (NHRC) chairperson Justice V. Ramasubramanian demanding a formal inquiry into what they describe as a large-scale, discriminatory disenfranchisement of citizens arising from the Special Intensive Revision (SIR) of electoral rolls.The representation draws heavily on a joint communication sent to the Union government on May 1 by three United Nations Special Rapporteurs – Nicolas Levrat, Irene Khan and Nazila Ghanea – highlighting minority issues, the promotion and protection of freedom of opinion and expression and the freedom of religion or belief pertaining to the SIR process.What are the demands?FEI’s eight-point appeal to the NHRC demands the formal registration of the representation as a complaint under Section 12(a)(i), 12(a)(ii), 12(b) read with 12(d) of the Protection of Human Rights Act (PHRA), 1993. The mentioned provisions empower the commission to inquire into rights violations, intervene in court proceedings and review constitutional safeguards.They also pointedly note that the commission has not exercised its Section 12 powers even though concerns surrounding the contentious revision have been regularly documented since the pilot exercise in Bihar in 2025. “It is concerning that despite these violations having been extensively documented since the Bihar pilot mid-2025, this Commission did not use its powers under Section 12 of the PHRA to intervene in the matter,” FEI said.The letter further asks the commission to exercise its powers under Section 13, which gives it the authority to summon witnesses, demand documents and receive affidavits during inquires, to call for detailed reports from the Election Commission of India, the Union home ministry and the state election mechanism in Bihar and West Bengal.It calls for the disclosure of the exact number of names deleted from the electoral rolls, state and constituency-wise data, further broken down as per religion, caste and gender along with the associated reasons for deletion and the number of objections filed and their outcomes.FEI’s third request concerns the immediate constitution of an open, online public hearing and the summoning of petitioners to place their allegations on record transparently. They specifically state that this should happen before any notice is issued to the ECI, so that the commission has the benefit of hearing FEI’s presentations first.“Immediately constitute and conduct an open, online public hearing into the matter by summoning the petitioners, so that the allegations herein may be examined transparently and on record – even before issuance of notice to the Election Commission of India so that this Hon’ble Full Commission may have the benefit of hearing our presentations prior to issuing of such notice,” the representation said.Only after that, should the commission call for the responsible ECI officials and concerned ministries to respond to the allegations directly, they said.The representation also raises due-process concerns over an undisclosed AI-driven system reportedly used by the ECI to flag “irregularities” in voter data, without any clarity on methodology, error rates or safeguards against biases. They argue that these issues are heightened by the finality of the consequence, which is the loss of the right to vote.The representation’s fifth demand seeks that any extension or replication of SIR to other parts of the country be held in abeyance under the inquiry is completed, with adequate time, transparent procedures and effective remedies instituted for any claims-and-objections process that is already underway.Furthermore, FEI has asked the commission to suggest accountability measures against functionaries whose public statements are found to be have been discriminatory or to have incited hostility against a religious or linguistic minority. While flagging the nature of official rhetoric around the contentious exercise, they explicitly mention the Union home minister’s description of the exercise utilising a “Detect, Delete and Deport” formula and hateful language about “purifying” the rolls of “infiltrators” promote communal prejudice.Also read: Ways to Make Voters Disappear: SIR Deletions and ‘Consensus’ PoliticsThe letter also urges the commission to “pass such other and further orders/recommendations as this Hon’ble Commission may deem fit and proper in the interest of justice.”Lastly, the representation, citing observations made by the UN Office of the High Commissioner for Human Rights, ask NHRC to give them an opportunity to present their legal position in light of international human rights law through an online hearing.The numbers behind the appealMentioning West Bengal in particular, the UN special rapporteurs had flagged the SIR process as a matter of “particular concern,” specifying potential violations of the International Covenant on Civil and Political Rights (ICCPR) and the International Convention on the Elimination of All Forms of Racial Discrimination.The rapporteurs had also noted that the exercise’s disproportionate effect was felt by one religious community, risking an “official endorsement of discriminatory attitudes.” They cautioned that public rhetoric surrounding the exercise could “amount to incitement to discrimination within the meaning of article 20(2) of ICCPR.”In Bihar, Muslim voters, who constitute nearly 17% of the state’s population, are said to have accounted for close to a third of the 4.7 million names removed from the rolls. Of the 6.5 million voters excluded from the draft poll published on August 1, 2025, only 60,010 had managed to file appeals by August 20, FEI pointed out.An independent analysis by The Wire, cited in the letter, found that women made up nearly 60% of those excluded despite comprising 47.8% of the electorate. This share crossed 60% in 43 of Bihar’s 243 constituencies.The second phase, extended to nine states, Chhattisgarh, Goa, Gujarat, Kerala, Madhya Pradesh, Rajasthan, Tamil Nadu, Uttar Pradesh and West Bengal, and three union territories, Andaman and Nicobar, Lakshadweep and Puducherry, reportedly saw around 52 million names deleted overall, 9 million of them from West Bengal. In the state, Muslim voters are said to have comprised 34% of the deletions against a 27% population share, with one constituency where 95% of the deletions were Muslim people against a 25% share in the electorate.Also read: Bengal Police’s Arrest of a Prominent Anti-SIR Protester Is ‘Meant to Send a Message,’ Say Fellow ActivistsThe representation mentions the alleged misuse of form seven, an electoral provision ordinarily meant for individual voters to object to another elector’s inclusion, for “organised, large-scale campaigns targeting Muslim residents.”They cite various instances of violations, including the filing of more than 15,000 form seven applications by just 269 individuals in Gujarat’s Somnath constituency, over 11,000 forms in Madhya Pradesh’s Indore linked to Bharatiya Janata Party-affiliated (BJP-affiliated) sources and 544 pre-printed forms attacking Muslim residents of a single village in Uttar Pradesh traced to a single applicant.During the Special Revision exercise in Assam, the chief minister reportedly directed party workers to file similar applications, later confirming that complaints from party members had led to names being struck off. Of 1.29 million form seven applications filed, 1.06 million were said to have been accepted.On Supreme Court rulingsImportantly, the letter notes the Supreme Court’s refusal to stay the SIR process in an order dated April 6, 2026. Ten days later, the apex court, invoking Article 142, permitted West Bengal voters removed from the rolls to contest the decisions before April 21 and April 27, ahead of the state assembly elections scheduled on April 23 and April 29. It adds that individualised review of approximately 3.4 million appeals in such a compressed timeframe is structurally impossible.The representation is signed by Devasahayam along with former Rajya Sabha MP Jawhar Sircar, Supreme Court advocate Mehmood Pracha, software specialist Madhav Deshpande, Right to Information (RTI) specialist Venkatesh Nayak, Delhi University professor Sant Prakash and social activist Tara Rao.