The ECI is using Form 6, meant for first-time voters, to reinstate people removed during the SIR. Its changing declarations and demands for past voter or family records have drawn criticism as an ill-conceived burden for eligible voters.
Many families in the J.J. Bela Estate slum cluster, on the banks of the Yamuna in the national capital, have lived here for generations, engaged mainly in growing crops on the floodplains or rearing cattle. However, in the ongoing Special Intensive Revision (SIR) of electoral rolls in Delhi, only a single resident of the area made it to the draft list.
Thirty-eight-year-old Kamal Lal, who was born here and whose fmamily has lived here for several decades, had actively helped residents fill enumeration forms, the prerequisite of the SIR. But Lal and his family members were among those whose names were missing from the draft list published on August 31. The residents of Bela Estate had previously been listed under “Part 33” of the rolls for the Chandni Chowk Assembly constituency. At the start of the SIR, Bela Estate had 729 voters. The single voter who remained on the draft list is now under a renumbered “Part 38”.
Lal said, “I got my voter ID as a resident of Bela Estate in 2009. I have voted in all elections since then, including the Lok Sabha election in 2024 and the Assembly election in Delhi in 2025. More than 500 enumeration forms were filled and submitted by the residents of Bela Estate. However, majority of the voters were marked as either absent or permanently shifted and removed from the list.”
According to a press note issued by the Electoral Registration Officer (ERO) of the Chandni Chowk Assembly constituency on September 18, the voters of Bela Estate were marked absent, shifted, dead, or duplicate (ASDD) as their previous settlement—addresses under which they were enrolled—had been demolished.
The press note said: “The agricultural activities in the said area were discontinued in 2021, and the dwelling units existing in the area were demolished in 2022-23. As per the provisions, the BLO [booth-level officer] marked them as ASDD as they were no longer residing at their address from where they were enrolled, due to demolition. As a result of this, 728 electors were deleted.”
Noting that some had shifted to temporary tarpaulin tents at another location on the floodplains, the ERO said that these people could be enrolled as homeless voters. The poll authority organised a special camp for them on September 18 and 20, and received 496 Form 6 applications.
Lal said, “The demolition of our homes was cited as a reason for not including us in the draft list. However, demolitions have been a part and parcel of our lives, and we have always come back. We never moved away from Bela Estate but only shifted to temporary structures nearby.”
Meanwhile, on September 25, even as they were trying to enlist as voters, the Delhi Development Authority launched another round of demolitions targeting the homes of Bela Estate residents as part of an anti-encroachment drive.
Like the residents of Bela Estate, crores of people have been removed from the voters’ list during the SIR across the country. Many have been wrongly marked ASDD and have had to fill Form 6 for a new voter ID.
Form 6, originally meant for first-time voters, has been repurposed for the SIR to reinstate deleted voters. In this new avatar, it is accompanied by a declaration to be filled by the voter. The format of the declaration itself has changed progressively since the exercise began in Bihar in June 2025 and covered the rest of India in the following months.
This been severely criticised for more than one reason. Questions have been raised about the authority of the Election Commission of India (ECI) to make changes to Form 6; the burden placed on voters, especially first-time voters, to provide information about oneself or one’s parents from the previous SIR; and the fundamental issue of individuals who have previously been voters having to declare that they are applying for inclusion in the electoral rolls for the first time and their names are not in any Assembly or parliamentary constituency lists.
A central issue that Election Commissioners Sukhbir Singh Sandhu and Vivek Joshi reportedly raised in their written objections to the ECI’s decisions on the SIR pertains to changes to Form 6.
According to the investigative report of The Indian Express about the divide within the ECI, on May 16, Joshi recorded his written objection to a proposal for changes to Form 6. He stressed that Form 6 and Form 8 (used to apply for a change of address) are “prescribed statutorily” and “cannot be altered without amendments in the Registration of Electors Rules, 1960”. He suggested that the “best and legally sustainable course of action” would be to send a proposal for changes to the rules to the government.
As per the report, Sandhu had expressed his concurrence with Joshi’s view in writing on May 19. On August 13, Sandhu reportedly wrote to the Deputy Election Commissioner and the Director-in-Charge of IT, copying the Chief Election Commissioner (CEC) Gyanesh Kumar and Joshi, to protest the changes to Form 6 despite the objections raised by him and Joshi.
He reportedly wrote: “In spite of these very clear views expressed by two Election Commissioners, the unauthorised/illegal changes in Form 6 on the portal had not been removed and the original form had not been restored. The changes must be removed immediately so that young and would-be first time voters, who are otherwise eligible, can register themselves as voters as per law, without any harassment.”
According to the ECI’s notification for the Bihar SIR, issued on June 24, 2025, new voters, those shifting from outside the State, and existing voters who could not submit enumeration forms earlier may submit Form 6 applications along with the prescribed declaration form. The declaration required documents certifying the date and place of birth of the applicant if born before July 1, 1987; documents for the applicant and either parent if born between July 1, 1987, and December 2, 2004; and documents for the applicant and both parents if born after December 2, 2004. The applicant had to provide one of the 11 prescribed documents.
For phase two of the SIR, notified on October 27, 2025, which covered nine States and three Union Territories, the declaration to go with Form 6 was revised, requiring applicants to provide either the details of their inclusion in the previous SIR or the mapping details of their parents from the earlier revision.
The online Form 6 application was altered in July 2026. There was anecdotal evidence about applicants being unable to submit applications without details of the inclusion of their parents or grandparents in the previous SIR. A declaration inserted between Sections J and K on the form required mapping details of parents or grandparents. This was seen as a big impediment for young and first-time voters who were unable to provide these details.
Changes outside the ECI’s purview
Experts have said that the ECI is not legally empowered to make changes to Form 6. They emphasised that in view of the statutory arrangement for registration of voters, any amendment to the form can only be made by the government with the approval of Parliament.
Former Chief Election Commissioner S.Y. Quraishi said, “Form 6 flows from The Registration of Electors Rules, 1960, which were made under Section 28 of The Representation of the People Act, 1950. The rules can be made and amended only by the Union Ministry of Law and Justice.”
“If the CEC were not so arrogant as to ignore or bypass this route, and if he had listened to the questions raised by the Election Commissioners, the ECI could have approached the government seeking amendment to the rules. But he did not bother, and the result is utter chaos. The changes in Form 6 are illegal or extra-legal,” he said.
The last time Form 6 was changed was in August 2022 to include Aadhaar details of voters in keeping with the amendments made by Parliament to The Representation of the People Act in December 2021.
After a meeting of the full ECI on September 26, 2026, the ECI issued a press note stating that the declaration attached to Form 6 for SIR has been upheld by the Supreme Court, and for the non-SIR period, the forms applicable as per the 1960 Rules will be used. However, on October 5, hearing a batch of petitions seeking suspension of Chief Election Commissioner Gyanesh Kumar, among other things, the Supreme Court said the modified Form 6 was not approved by it.
In a fact-check the ECI issued on October 5 after it was accused of making false claims about Form 6, it said that the June 24, 2025, order for Bihar SIR which included the declaration to go with Form 6 had the unanimous approval of the ECI and was upheld by the Supreme Court in its May 27, 2026, judgment.
However, experts countered this clarification by pointing to the revised declaration issued for the second phase of the SIR in October 2025. The revised declaration sought details of previous SIRs for the self, parents, or grandparents, while changes were also made to Form 6 online in July 2026. Experts said these changes were not brought before the court.
According to experts, the Supreme Court judgment in May said that the ECI retained a degree of residual authority to formulate an appropriate documentation framework suited to the needs of the SIR, but this authority was not unbounded.
The judgment said, “In devising such a framework, the Commission must remain cognisant of the existing statutory scheme, and any departure therefrom must be informed by a rational nexus to the object sought to be achieved.”
Sagrika Rajora, lawyer-activist and co-founder of Voter Adhikar Manch, said, “The changes to Form 6 do not clear the proportionality test for Article 14. They are unconstitutional and arbitrary. The ECI cannot prove the necessity for making the process so much more difficult for the people. The Supreme Court very clearly said the ECI’s authority with regard to the documentation is not unbounded and it has to adhere to the existing legal framework.”
After its meeting on September 26, the ECI announced that the original Form 6, devoid of the declaration, would be reinstated in the States where the revision process is not on. Subsequently, on September 29, in the States where the SIR is not currently underway, the declaration was removed.
Major General Anil Verma (Retd), head of the Association for Democratic Reforms, said, “The ECI is drawing a distinction between Form 6 for the States where the SIR is underway and the States where it is currently not on. So we have two different versions of Form 6, one for SIR, and another for non-SIR states. How can you have two different versions of Form 6 for the same operation?”
Special campaign
Meanwhile, amidst the furore over the SIR having removed at least 13 crore voters from the rolls, the ECI, on October 1, wrote to the Chief Electoral Officers of all the States and Union Territories where the SIR is complete or underway to carry out a special campaign to include eligible voters whose names were removed by asking them to submit Form 6 applications. BLOs would now have to compare the current electoral rolls with the pre-SIR list to identify voters whose names had been dropped during the exercise. Eligible voters would have to be included in the list within a month.
However, experts say that asking deleted voters to submit Form 6 applications amounts to forcing them to make a false declaration which is a punishable offence. Form 6, meant for new voters, asks for a declaration that the person is applying for inclusion in the rolls for the first time and their name does not exist in any Assembly or parliamentary constituency lists.
Quraishi said, “Form 6 is meant only for new voters. By making deleted voters fill up Form 6, the ECI is forcing them to commit an illegality. Making a false declaration is a criminal offence which carries a punishment of up to one year in prison. The ECI is playing with the law of the land. It is abetting a crime.”
Activists working on the field in Delhi have also expressed doubts about how far the ECI’s special campaign would help because those left out, especially from marginalised and underprivileged sections, would encounter the same roadblocks of documentation and mapping with the previous SIR which they did during the enumeration phase.
Chidambaram, a social worker associated with the NGO Basti Suraksha Manch, said, “There is a lot of anxiety and confusion amongst the residents of slum localities in Delhi, which have a large migrant population. Many of them could not fill up the enumeration form properly because they did not have mapping details either for self or their parents. They have to provide these details in Delhi.”