This is the second segment of a two-part series on the SIR process in Delhi. It records the observations of Voter Adhikar Manch (VAM), a citizens’ collective which has worked closely with people on the ground in the national capital. Read the first part here.§New Delhi: The testimonies from the ground substantiate how arbitrary and unequal the Special Intensive Revision (SIR) of electoral roll process has been for the people in Delhi. Disenfranchisement has characterised the design of this revision process. How exclusion was built inIn the enumeration phase of the SIR exercise, we were able to identify exclusions built into its design at different stages. There are four sections with 11 sub-categories that we largely recognised so far: a) before the beginning of the enumeration phase, b) at the door, c) the design of the application forms, d) wrongful documentation.Before the beginning of the enumeration phase: i) Silent pre-enumeration deletions.At the door: ii) non-receipt or non-distribution of the enumeration form rendering people out of the electoral roll, iii) Booth Level Officers (BLOs) inventing arbitrary eligibility rules, iv) multiple Absent, Shifted, Dead/Deleted or Duplicate and Others (ASDDO) markings without verifiable visits or adequate inquiry that was required by the process.The design of the application forms: v) distressing and unfair to locate details of relatives in the 2002 roll.Wrongful documentations: vi) marital relocation of women, vii) not accommodating those affected by demolitions, displacement and shifting within Delhi, viii) falsely recording temporary absence as permanently shifted, (ix) defective online forms, (x) mismatch in the name on documents making it impossible for voters, who are unable to submit the applications physically, to fill forms online and (xi) rerouting existing electors to fill Form 6. Before the enumeration phase beganWe noticed many silent deletions without notice. We thought of calling these deletions, pre-SIR deletions but realising that there were deliberate and intensified deletions right before the enumeration forms were distributed in Delhi, we realised these deletions were very much a part of the SIR process. In its letter dated September 7, the Chief Electoral Office (CEO) confirmed this mechanism of pre-enumeration deletions itself. Before SIR began in Delhi, BLOs went door to door mapping the 2025 roll against the roll of the last SIR in 2002. The CEO referred to this as a “very crucial pre-revision activity prior to start of SIR,” during which “voters found shifted from their registered address” were reported by BLOs. The letter also states that the list of all deletions, additions and modifications is published on the CEO Delhi website every month, and it is in that record that deletions rise sharply in the months before SIR. Its August 31 press note confirmed that the roll was frozen on June 16 and that the revision began from 1,45,10,299 electors. This meant that everyone removed before June 16 fall outside the roll SIR worked with as a reference, outside the ASDDO list, and outside every figure the commission has published with respect to SIR since. The CEO’s daily bulletin of October 1 records that only 1,68,014 Form 6 applications were received, against 47,56,722 electors excluded from the draft roll, in the entire month (till September 30), which meant barely three in every 100 people struck off. Because of how slow the process was, we wrote in our letter dated September 22 that the figure on September 19 stood at 84,263, around ten days before the earlier last date of submission of Form 6.The figure stood at fewer than two in a 100. Considering this as the pace at which work progresses, how could the CEO ensure as many deletions in the months prior to SIR if it were not intentional?As reported now, 11 lakh names were removed from the electoral rolls between January 2025 and June 2026 with absolute opacity. There is no way for an ordinary citizen to identify when these names were deleted and why. These deletions raise serious concerns immediately as many people found themselves ineligible to even participate in the SIR process. They did not even get a shot at filling enumeration forms and have been forced to register as a new voter. Electors whose names were deleted from the electoral rolls in the pre-enumeration phase have told us that they were never informed about it and claimed that these deletions were unfair and wrong. Section 22 of the Representation of the People Act, 1950 requires a reasonable opportunity to be provided before one’s name and entire electoral history is deleted. Rule 21A of the Registration of Electors Rules, 1960, also specifies notice before deletion.However, in the SIR process many people were kept out of the electoral rolls due to non-receipt of enumeration application form.Arbitrary ineligibility rulesIn Northwest Delhi, a BLO told an elector that linkage to her maternal grandmother will not be accepted since she is not widowed. In many cases, mapping to maternal grandparents was not allowed by the BLO despite the Chief Electoral Office (CEO)’s and Election Commission of India (ECI)’s official directions. In different localities, the BLOs operated according to outdated submission deadlines. In Begumpur, for example, a BLO refused to collect forms after July 30 despite the extended deadline.We recorded multiple voters marked ASDD by BLOs without verifiable visits or adequate inquiry that was required by the process.The CEO and ECI had stated that the BLOs should visit each household at least thrice to verify elector details and conduct preliminary inquiry and cross-check details. Most electors found it distressing and unfair to locate details of relatives in the 2002 roll. Beyond inaccessibility, the 2002 benchmark does not carry a defined rationale.Illustration: Pariplab Chakraborty.In multiple documents, it has only been provided that the “last SIR was done more than 21 years ago in 2002-2004” which is why this serves as a linkage roll. Along with that the commission has merely listed that frequent migration resulting in voters getting registered at more than one place, non-removal of dead voters and wrongful inclusion of any foreigners as reasons for SIR to take place. While the commission has stated that 2002 is when the last SIR happened in Delhi, it does not explain the requirement of this year. There has been no official publication clarifying why a 24-year-old roll is a reasonable condition to retain an entry that the commission has already made and how that mandates producing of documents when an elector fails to link to that roll.In Lal Babu Hussein v. Electoral Registration Officer (1995), the Supreme Court upheld that if a person’s name is already present in an immediately preceding roll, it must be presumed that the entire process for inclusion was undergone when the name was entered. The notice must disclose the basis on which doubt is raised about the voter. Everyone on the roll when the SIR began was put there by the commission itself, through an already established process. These entries already carry the presumption that a proper mechanism was carried out for the inclusion of their names when an entry was made. Also read: People’s Tribunal on Delhi SIR: Audit Finds ‘Official Record Doesn’t Correspond with Ground Reality’The logic of such presumption runs on constitutionality, principles of natural justice and due diligence. It is now inverted when electors are required to prove linkage to a roll from 24 years ago. This again embeds exclusion in the design, as the burden of the commission to justify removal is now wrongfully and unjustly shifted onto an elector. The elector is not even given a chance for retention. They are simply forced to register as a new voter altogether for every deletion, justified or not. In our statement, dated September 3, 2026, after CEO, Delhi’s press release following the publication of the draft roll on August 31, we have emphasised that:“As per a press note released by CEO Delhi on 31 January 2025, Delhi had 1,56,14,000 electors before the 2025 assembly election. But as per the press note issued by ECI announcing the third phase of SIR, Delhi had 1,48,23,234 electors on 12 May 2026. And now, CEO Delhi is saying that Delhi had 1,45,10,299 electors at the start of SIR. This means that the Delhi CEO removed 7,90,766 voters between January 2025 and May 2026, and 3,12,935 electors between May 2026 and the start of the SIR. This indicates that even before SIR happened in Delhi, 11,03,701 electors were removed from the voter roll! While some of these deletions may be routine due to migration, deaths etc., but absolute lack of transparency from CEO Delhi explaining these deletions, particularly the overdrive just ahead of SIR in May-June 2026 raises doubts about the veracity of the process.”Around 30% of the pre-enumeration deletions happened in the seven weeks before the official commencement of the SIR process; 11,03,701 voters are outside of every figure that the commission has provided. They are outside the ASDDO list as they disappeared before the roll was frozen on June 16. The presumption that should have protected their entries was extinguished without any notice or intimation. Wrongful documentationMarital relocation of women, not accommodating those affected by demolitions, displacement and shifting within Delhi and falsely recording temporary absence as permanently shifted are other categories of exclusion that took place within the design of the process. In the first segment, I have explained in detail how working class populations, migrant workers and women are excessively prone to being excluded in this process. The case, Lal Babu Hussein v. ERO acknowledges how processes disproportionately affect working-class people who are mostly illiterate or uneducated. Nothing in the Representation of the People Act, 1950 or the Registration of Electors Rules, 1960 makes change of residence a ground for refusing enumeration. Section 22 of Representation of the People Act also provides for transposition; the roll must follow electors who move. Illustration: Pariplab Chakraborty.Instead of transposing them, the process in Delhi removed them and coerced people into registering afresh. The commission ran this on a schedule that it revised three times without proper outreach, where BLO were either unaware or unwilling to take forms from many after extensions of the enumeration deadline. In the machinery, exclusions took place in the form of defective online forms, mismatch in the name on documents making it impossible for those unable to submit physically to fill forms online and rerouting existing electors to fill Form 6. These various mechanisms involving administrative contradictions and unexplained principles were used by authorities to drive this process that disenfranchised people en masse. With these shocking numbers in the capital – 11,03,701 before the enumeration phase even began in Delhi; 47,56,722 that were marked as ASDD; and now 33,12,000 notices being sent to those on the draft roll. There has been no disclosure by the CEO as to what 11 logical discrepancies are. We figured this out only through a news report published by the Hindu. Throughout the process, the CEO has withheld important information from the public and made the process difficult to navigate. The total scale of disenfranchisement continues to be colossal. We have been repeating that one in three voters in Delhi stand deleted but with another 33,12,000 marked for hearings during the claims and objections phase despite being on the draft roll, more than half of Delhi’s electorate is potentially at risk of being out of the electoral roll at the moment. Replying non-stop, getting it wrong every timeCEO Delhi is on a roll with their quick but shoddy replies to every claim we have made at our press conference, in our public statements and media releases citing our data. These public replies are riddled with errors and contradictions throughout. I will list a few of these to note that there has been no effort by the commission and the CEO to correct errors, instead they have relayed outdated justifications that we have addressed. This in itself is to state the obvious that there has been nothing people-centric about this process. Grievances remain largely unaddressed and ignored while CEO, Delhi grapples to save face with repetitive press statements.The first segment described the contents of our letters dated July 26 and August 18. While our first letter was never responded to, the CEO finally responded to our letter demanding the urgent publication of the ASDDO list and a rollback window for corrections before the publication of the draft roll, on September 2, only after the draft roll was published. Also read: Amid SIR Hearings Across Delhi, Many Voters Say They Were Unaware of NoticesThe CEO replied to us stating that the ASDD list existed at part levels throughout the enumeration phase, it was given to Booth Level Agents (BLAs) and the rollback period that we had demanded existed in some internal capacity.The CEO stated, “Discrepancies pointed out by the BLAs or otherwise came into the notice of BLOs/EROs [Electoral Registration Officers] were rolled back by the EROs itself and corrected accordingly.” This is much more grave than routine bureaucratic ignorance or lack of information, they had a list and a rollback mechanism but it was only meant for party-level agents to see who had been marked in their part and get erroneous deletions reversed while there was still time. An ordinary elector had no access to the list and could not get a wrongful deletion or marking reversed even though it could be done easily. This is deliberate obscurity to keep people out of the process. Karnataka published its ASDDO list on August 4, during enumeration, and three lakh electors were taken off it in six days. That is the point of the ASDDO list. To precede omissions and be reinstated. Similarly, in another response on September 7, the CEO admitted to a pre-revision mapping exercise where BLOs went door to door before the SIR began and mapped 2025 against 2002 to report voters who have shifted. According to the CEO, notices were sent in “each and every case” by speed post. However, none of the electors who had reached out to us had received any such intimation of deletion. The CEO again blatantly lies in its press release dated September 7, where it provides a clarification regarding pre-SIR activities. In this press release, it says that sufficient time was given to every individual marked as shifted to respond to a notice and given time to attend the hearing. This has not been the case.The CEO states that married women can fill Form 8, in case of shifting from their natal residence. Once again, the CEO dodged our concerns and questions to give an entirely redundant solution. Also read: This Delhi Polling Booth Had 729 Voters During 2025 Polls. After Draft SIR List, it Has Only One.Women residing with their natal families and voting for years from the same household have been removed from the electoral roll without any notice. Form 8 can only be a recourse if you are on the roll. The only option left for these women is to register as a fresh voter through Form 6. In its letter of September 7, the CEO states that electors will be given seven days time for submitting their documents and reply to the ERO. However, people are receiving their notices 2-5 days before the hearing date in many localities across Delhi. Despite our emphasis on how such administrative lapses disenfranchise people and create unnecessary panic amongst them, the CEO responds to this concern with a standard reply that does not hold true on ground. The claims and objections phase has been another panic-inducing phase where hearing dates are not showing up online, people don’t know what documents to carry with them to the hearings, notices are received right before the hearings, and people are forced to run around from the hearing venue to fetch extraneous documents that are not listed amongst the “non-exhaustive list” of the commission. While it asserts that complete transparency has been maintained during the SIR process through involvement of BLAs in the process of verifying electors marked as ASDDO, the process on ground is entirely discretionary and opaque. In its press note dated August 31 2026 , the CEO also laid down the process which clarifies the role of volunteers and BLAs in addition to the door to door visits by the BLOs that needed to be carried out thrice. However, this was not uniformly carried out across the national capital.Representational image: A Booth Level Officer (BLO) verifies voters’ names during the Election Commission’s Special Intensive Revision (SIR) of electoral rolls, in Ranchi, Jharkhand, July 19, 2026. Photo: PTI.In Tughlakabad, for example, the BLAs predominantly distributed the enumeration forms while the BLOs were operating from a desk near the Durga temple there. Similarly, BLOs distributed enumeration forms through RWAs in some locations such as Sarita Vihar. In other areas in centralised locations such as local parks where people can collect the forms from them.In Batla house, electorates had reported that they had to go to the election office located in Nai Vasti, around two kilometres away, to collect and submit their forms. In many instances, people have mentioned that they have not seen their BLO or never received a form. Door to door visits did not take place and there was no uniform mechanism in place to ensure that forms were distributed.Despite this, the CEO loudly claims that 100% enumeration forms were distributed. This was repeated without any sufficient explanation in its letter to us on September 7 where we questioned this claim.We have been seeing that through its rebuttals regarding the deletion of 728 out of 729 voters in Part no. 38 of Bela estate or regarding six electors wrongly marked in Mangolpuri, the CEO has not addressed erroneous entries and furnished untrue facts.Even in their responses to claims of specific wrongful instances of deletions, they have outrightly responded with untrue information. For instance, regarding Kamta Prasad from Mangolpuri, the CEO has said that there were two different Kanta Prasads that is being confused by the media, however, Kamta Prasad has said on record that he has tried to get his name corrected to Kamta from Kanta and his EPIC id matches the one provided in the ASDD listing proving that he is the same man wrongfully declared dead. Kamta Prasad is alive, he is on the ASDD list marked as “dead”, and his EPIC and house number match. The CEO’s attempt to prove voters with genuine concerns wrong just sets another precedent of being dishonest. Also read: Delhi SIR: Who Are the 47.56 Lakh People Knocked Out From the Draft Roll?Why is a serving elector who asked only for a spelling correction, marked “dead” and is now being directed to fill Form 6, which requires him to declare that he has never been enrolled, when Form 8 should have been the applicable form and his original entry, EPIC and enrolment date should be restored?The question that still remains unanswered is that despite set precedent and established statutory framework, why does the commission not trust its own administrative processes? The presumption of continuity would mean that any entry to the electoral roll of 2025 would be done with adequate processes in place. Why has the presumption been disrupted to result in more than 11 lakh pre-enumeration deletions from January 2025 to June 2026? The most concerning aspect of the CEO’s replies is that they write on September 7:“It is once again informed that Electoral Roll is being prepared afresh during SIR and accordingly, Draft Roll has been published on the basis of Enumeration Forms received by the BLOs.” The power exercised by the commission and CEO is to revise the existing roll, according to Section 21(3) of Representation of the People Act. How does it make sense to prepare a roll afresh for a functioning electorate of 1.45 crore? The language of preparing a roll afresh can warrant wholesale deletions without accommodating safeguards that legally protect existing entries. This allows for no default retention for anyone. Is this supposed to mean that every entry of this roll that they are preparing is new and the roll itself has no past? Each reply of the CEO results in a subsequent set of more confusing questions that will remain unanswered. An anti-people processThe court upheld the SIR on a proportionality analysis in Association for Democratic Reforms v. Election Commission of India, 2026, asking whether the purpose of the process was legitimate, whether the means were rationally connected, whether they were the least restrictive available processes, and whether the burden was fairly balanced against the aim.The apex court stated that proportionality must be assessed in the manner of implementation and not in the abstract. On applying this principle in the manner of implementation in Delhi, it is not difficult to conclude that the proportionality test for this process will never pass on the ground because its implementation is where it is most unfair, exclusionary, disproportionate and unconstitutional. While the CEO, Delhi claims that these revisions are to benefit people, there barely seems to be any attempt to inform panicked people of these revisions. In fact, these revisions hindered people from submitting forms and marked them as uncollectable. The safeguard of the proportionality test cannot be used because the elector cannot even locate their exclusion. In many cases, they are not even aware of their exclusion. There was no timely publication of the ASDDO list, no reason codes, no notice; basically, no due process whatsoever. As mentioned above, people had not a clue that their names were struck off the roll. They were not served a notice nor were they informed of any hearing as the CEO claims. Balancing this process has also entirely failed because the burden is distributed by class and gender. Married women, split between households and still not counted. Working-class and migrant populations, especially those residing in slums and unauthorised clusters, are disenfranchised through the process. Homeless populations are not identified according to the ECI’s manual and regulations. The BLOs have not mapped homeless and displaced individuals to street lights, electricity poles and other sedentary markers that would serve as their residence. Instead, those who had their houses demolished by the state were informed by election officials that their names were deleted because they resided on unauthorised land. Not only is this process not uniform across different states, it is not uniform within different constituencies of the same state. BLOs have applied different rules in different areas and people have accessed the process in starkly diverse ways across Delhi. Such large discretionary powers given to an overworked and biased non-employee of the commission is also highly problematic. The SIR requires extensive specialised training and an adequate number of people to carry out these processes with multiple checks. Who is the ECI and CEO, Delhi answerable to?There are many cases where disgruntled electors have come to us panicking about their status or witnessing their names struck off from the voter’s list right in front of them. While many people did not see their enumeration form at all, we also came across a case where an elector received two enumeration forms in two different locations.Based on all these issues, we demanded the publication of part-wise ASDDO lists in Delhi along with a correction window during the claims and objections period. Now during the claims and objections phase, we are demanding that they publish the list of people who will receive notices based on anomalies or because they are considered unmapped. This list also exists with the CEO, yet they have still not published it. While the same has been published in Karnataka. Even as notices are being given out to people, the commission is forcing them to operate in a frenzy with no instructions as to how to navigate a very obsolete and opaque process that even the Supreme Court has unreasonably deemed necessary.People are receiving notices in English despite The Delhi Official Language Act, 2000 specifying Hindi in Devanagari script as the official first language used for government and administrative work in NCT Delhi and Punjabi in Gurmukhi script and Urdu in Persian script as the second official languages. This process has been a frustrating amalgamation of infrastructural lethargy, ignorance and outright violent exclusions. There is no way people can verify any detail about the process carried out. The entire process is carried out without any honest communication.Chief Election Commissioner Gyanesh Kumar. Photo: PTI.There have been no proper instructions from the ECI or the CEO and no indication of appropriate training for BLOs carrying out this process. People are both confused about how serious this process is and what implications it might have. Some are even taking the process casually because they were simply given a form on a random day while they rushed to work.Some people think this is just another “sarkari (bureaucratic)” routine, while others fear that this might result in them being deported, facing demolitions, their children being thrown out of school or having no access to an already clogged public distribution system (PDS). Other than that, this has been recognised as a means to simply secure the voter rights of those who will elect the ruling party. As many critics of the SIR have pointed out, the politics of SIR seems to be the politics of exclusion. It has rightly been called another National Register of Citizens (NRC). As we worked with different communities struggling with graded vulnerabilities, it became even clearer that SIR has been a process of mass disenfranchisement. It is by design, not only functioning through exclusionary methods, but in its implementation shutting out people who are then left to worry about how deletion from the rolls will affect their loans, rations, voting rights and other markers of citizenship.Our most pertinent concern from this process is: Who is the CEO and ECI answerable and accountable to? This has been answered before, but we keep asking this question.Sagrika Rajora is a lawyer, researcher, and trade union activist organising predominantly with women workers and others marginalised by caste, religion, and migration. They work with Migrant Solidarity Network on intersecting issues of migrants in Delhi. Their work lies at the intersection of urbanisation, labour rights, and human rights, rooted in ongoing working-class organising and struggles.For our full coverage on the SIR and the issues it has brought to citizens, click here.