Bihar SIR Process ‘Capable of Subverting Electoral Process’, Warn Former Top Civil Servants

New Delhi: Over 90 former top civil servants, members of the Constitutional Conduct group (CCG), have expressed alarm and appealed to the Supreme Court to stop the Bihar SIR (special intensive revision) of the voters’ list by the Election Commission of India (ECI) as it “appears to be an assault on the very foundations of our democracy - the system of universal adult suffrage, i.e the citizen’s right to vote.”

In an open statement, the civil servants, many of whom have been involved in the “conducting and supervising elections, including the preparation of Electoral Rolls, and are familiar with the complexities of doing so in a vast democracy like ours,” said the SIR’s “purported attempt to clean up and sanitise the electoral rolls is likely to end up disenfranchising a very large segment of the voting population, particularly the poor and the marginalised, who possess little or no official documentation as proof of their citizenship.”

The Supreme Court, which is hearing various petitions against the manner in which on SIR is being conducted in Bihar, on July 28 asked the ECI to include Aadhaar and voter identity cards in the revision of electoral rolls. The petitioners have pleaded that about 65 lakh voters have been excluded. The SC told the petitioners on Tuesday that it would hear the pleas on August 12 and 13, related to SIR and assured them that “if there is mass exclusion, we will step in”.

Read the full CCG statement below:

CCG Open Statement on the Special Intensive Revision (SIR) of Electoral Rolls in Bihar

 29 July 2025

We are a group of former civil servants of the All India and Central Services who have worked in the Central and State Governments during our careers. As a group, we have no affiliation with any political party but believe in impartiality, neutrality and commitment to the Constitution of India.

We are writing today to express our alarm at what appears to be an assault on the very foundations of our democracy - the system of universal adult suffrage, i.e the citizen’s right to vote. The assault is an insidious one where the purported attempt to clean up and sanitise the electoral rolls is likely to end up disenfranchising a very large segment of the voting population, particularly the poor and the marginalised, who possess little or no official documentation as proof of their citizenship.

For all the 73 years since the first General Elections were held, the vast majority of the poor in India have held their Right to Vote as their most fundamental stake in Indian democracy. Throughout, the principle followed has been that, unless anyone disputes their status, they are presumed to be citizens and. therefore, attempts should be made to ensure that everyone is included as a voter. In fact, in complete contrast to the manner in which the ‘new’ Election Commission of India (ECI) is functioning, the attempt in the past was to see that no adult Indian was left out of the enfranchisement process and the ECI took it as its solemn responsibility to include people residing in the remotest corners of the country as voters, however marginal their lives might be. The focus was on inclusion and not exclusion on account of alleged ineligibility.

So far, a liberal and flexible approach to documentary corroboration of citizenship was followed in the preparation of electoral rolls knowing full well that most Indians lack adequate documents and certificates to establish their citizenship status. It was also recognised that the poor are especially deprived in their access to official documentation resources and therefore need proactive measures to ensure their inclusion. This process has now been reversed to ensure that those with poor access to documents will be deprived of their rights as voters.

The ECI has exempted electors included in the 2003 electoral roll from furnishing any document under SIR 2025 other than “the relevant extracts of the said part showing their name in the 2003 electoral roll”. ECI’s affidavit states that the children of electors included in the 2003 rolls have also been allowed to use this avenue to prove their eligibility. Such privileging of the inclusions in the 2003 electoral rolls, over and above all electoral rolls published by the ECI in the two subsequent decades, is untenable, unjust and discriminatory.

The SIR is claimed to be an exercise in pursuit of the responsibility entrusted to the ECI under the Constitution, yet what it is effectively doing is to invert precept and practice to:

● pass the burden for proving citizenship to the voter instead of the authorities having to prove why they have excluded someone on the basis of fake citizenship;

● arrogate to itself (the ECI) the authority (instead of the Home Ministry) to effectively confer or take away citizenship rights without any Constitutional mandate to do so;

● introduce the contested idea of the NRC through the backdoor, as it were, in the guise of cleaning up electoral rolls;

● effectively negate and nullify the electoral rolls currently in use (as recently as in the 2024 Lok Sabha Elections) on the pretext that they are likely to be contaminated and, thereby, justify the creation of a completely new set of rolls;

● disenfranchise millions of those who have been registered voters in all elections held since 2003 but may not have documents that they are now required to possess;

● prescribe a list of documents through an arbitrary and whimsical executive fiat making it virtually impossible for most people to obtain them in time;

● use the pretext of cleaning and purifying voter lists to eliminate and delete millions of existing voters who cannot satisfy arbitrary bureaucratic requirements, e.g. married women having to produce birth certificates etc. of their parents;

● give extraordinary discretionary powers to officialdom at various levels to indulge in rent seeking to remove or add voters;

● muddy waters sufficiently to make the entire process mystifying, difficult and opaque.

As if it was not enough to commission an SIR which was capable of subverting the electoral process in the garb of reforming it, the breakneck speed with which it has been implemented, the impossible timelines given to the Booth Level Officers, the grossly inadequate infrastructure provided/made available to digitise the data has made a mockery of the very elaborate procedures the ECI has laid down.

In several reports in the print and electronic media, notably the YouTube videos of Ajit Anjum, a reputed journalist, it is abundantly clear that fraud and forgery on a massive scale has occurred. There is video evidence to show that voter forms have been filled up not by the voters but en masse by BLOs sitting in officially provided space, and signatures of thousands of those voters forged in an organised manner. Forms and signatures of family members of several voters (including forms of dead members of their families) have been filled, signed and uploaded on the ECI website without their knowledge and consent. When reports appeared that no one was being given the voter’s copy of the enrolment form nor any acknowledgement receipts provided, pictures were hastily taken to show village women lining up and holding their copy of forms as proof of acknowledgement. When the same women were visited again by the investigating reporter - Ajit Anjum - they confessed that the officials gave them the forms, took the photo of them holding them up, published them and then took back those forms.

In a Jansunwai (public hearing) held in Patna on 21.06.2025 with eminent persons like Wajahat Habibullah (former Chief Information Commissioner of India) and Justice Anjana Prakash (retired judge of the Patna High Court) among others as the Presidees, 25 persons, including several illiterate women, from 14 villages described their experiences of what actually happened during the SIR process, and their detailed testimonies showed the extent of the fraud that is being perpetrated in the name of the SIR. This is a shocking revelation of the way the Election Commission is using its powers, forcing the district machinery to resort to unethical practices in an organised manner in the very first phase of this elaborate charade. The evidence of such fraud in the very first stage of the SIR exercise vitiates the entire SIR process and undermines those very constitutional processes that the ECI claims to be following. It is especially reprehensible that this fraud is being committed under the direct supervision of the ECI, bringing this institution of eminence with a glorious past into grave disrepute. The continuation of this futile exercise and its proposed extension to the rest of the country. especially when all that is required is routine updation of existing data in the regular course of the ECI’s scheduled activities, poses one of the biggest threats Indian democracy has faced, from the very institution that is meant to uphold the system of universal suffrage.

As our various petitions and pleas to the ECI in several matters relating to elections have been ignored and casually dismissed in the past, we are addressing this open letter to ‘We the people’ so that public opinion is mobilised and there is pressure on the ECI to take corrective action. We also hope that the Supreme Court, which is examining the matter, takes heed of the issues raised by us, particularly as most of us, as members of the CCG, have had long experience of conducting and supervising elections, including the preparation of Electoral Rolls, and are familiar with the complexities of doing so in a vast democracy like ours.

SATYAMEVA JAYATE

Yours faithfully Constitutional Conduct Group (93 signatories as indicated below)

1. Anita Agnihotri IAS (Retd.) Former Secretary, Department of Social Justice Empowerment, GoI

2. Anand Arni RAS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI

3. G. Balachandhran IAS (Retd.) Former Additional Chief Secretary, Govt. of West Bengal

4. Vappala Balachandran IPS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI

5. Gopalan Balagopal IAS (Retd.) Former Special Secretary, Govt. of West Bengal

6. Chandrashekar Balakrishnan IAS (Retd.) Former Secretary, Coal, GoI

7. Sushant Baliga Engineering Services (Retd.) Former Additional Director General, Central PWD, GoI

8. Rana Banerji RAS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI  

9. Sharad Behar IAS (Retd.) Former Chief Secretary, Govt. of Madhya Pradesh

10. Aurobindo Behera IAS (Retd.) Former Member, Board of Revenue, Govt. of Odisha

11. Madhu Bhaduri IFS (Retd.) Former Ambassador to Portugal

12. Pradip Bhattacharya IAS (Retd.) Former Additional Chief Secretary, Development & Planning and Administrative Training Institute, Govt. of West Bengal 13. Nutan Guha Biswas IAS (Retd.) Former Member, Police Complaints Authority, Govt. of NCT of Delhi

14. Meeran C Borwankar IPS (Retd.) Former DGP, Bureau of Police Research and Development, GoI

15. Ravi Budhiraja IAS (Retd.) Former Chairman, Jawaharlal Nehru Port Trust, GoI

16. Maneshwar Singh Chahal IAS (Retd.) Former Principal Secretary, Home, Govt. of Punjab

17. R. Chandramohan IAS (Retd.) Former Principal Secretary, Transport and Urban Development, Govt. of NCT of Delhi

18. Ranjan Chatterjee IAS (Retd.) Former Chief Secretary, Govt. of Meghalaya & former Expert Member, National Green Tribunal

19. Kalyani Chaudhuri IAS (Retd.) Former Additional Chief Secretary, Govt. of West Bengal

20. Purnima Chauhan IAS (Retd.) Former Secretary, Administrative Reforms, Youth Services & Sports and Fisheries, Govt. of Himachal Pradesh

21. Gurjit Singh Cheema IAS (Retd.) Former Financial Commissioner (Revenue), Govt. of Punjab

22. F.T.R. Colaso IPS (Retd.) Former Director General of Police, Govt. of Karnataka & former Director General of Police, Govt. of Jammu & Kashmir

23. Anna Dani IAS (Retd.) Former Additional Chief Secretary, Govt. of Maharashtra

24. Vibha Puri Das IAS (Retd.) Former Secretary, Ministry of Tribal Affairs, GoI

25. P.R. Dasgupta IAS (Retd.) Former Chairman, Food Corporation of India, GoI

26. Pradeep K. Deb IAS (Retd.) Former Secretary, Deptt. Of Sports, GoI

27. Nitin Desai Former Chief Economic Adviser, Ministry of Finance, GoI

28. M.G. Devasahayam IAS (Retd.) Former Secretary, Govt. of Haryana

29. Kiran Dhingra IAS (Retd.) Former Secretary, Ministry of Textiles, GoI

30. Sushil Dubey IFS (Retd.) Former Ambassador to Sweden

31. A.S. Dulat IPS (Retd.) Former OSD on Kashmir, Prime Minister’s Office, GoI

32. K.P. Fabian IFS (Retd.) Former Ambassador to Italy 33. Prabhu Ghate IAS (Retd.) Former Addl. Director General, Department of Tourism, GoI

34. Suresh K. Goel IFS (Retd.) Former Director General, Indian Council of Cultural Relations, GoI

35. S.K. Guha IAS (Retd.) Former Joint Secretary, Department of Women & Child Development, GoI

36. H.S. Gujral IFoS (Retd.) Former Principal Chief Conservator of Forests, Govt. of Punjab

37. Meena Gupta IAS (Retd.) Former Secretary, Ministry of Environment & Forests, GoI

38. Sajjad Hassan IAS (Retd.) Former Secretary, Govt. of Manipur

39. Rasheda Hussain IRS (Retd.) Former Director General, National Academy of Customs, Excise & Narcotics

40. Kamal Jaswal IAS (Retd.) Former Secretary, Department of Information Technology, GoI

41. Najeeb Jung IAS (Retd.) Former Lieutenant Governor, Delhi

42. Sanjay Kaul IAS (Retd.) Former Principal Secretary, Govt. of Karnataka

43. Gita Kripalani IRS (Retd.) Former Member, Settlement Commission, GoI

44. Ish Kumar IPS (Retd.) Former DGP (Vigilance & Enforcement), Govt. of Telangana and former Special Rapporteur, National Human Rights Commission

45. Subodh Lal IPoS (Resigned) Former Deputy Director General, Ministry of Communications, GoI

46. Sandip Madan IAS (Resigned) Former Secretary, Himachal Pradesh Public Service Commission

47. P.M.S. Malik IFS (Retd.) Former Ambassador to Myanmar & Special Secretary, MEA, GoI

48. Harsh Mander IAS (Retd.) Govt. of Madhya Pradesh 49. Amitabh Mathur IPS (Retd.) Former Special Secretary, Cabinet Secretariat, GoI

50. Aditi Mehta IAS (Retd.) Former Additional Chief Secretary, Govt. of Rajasthan

51. Avinash Mohananey IPS (Retd.) Former Director General of Police, Govt. of Sikkim

52. Satya Narayan Mohanty IAS (Retd.) Former Secretary General, National Human Rights Commission 53. Sudhansu Mohanty IDAS (Retd.) Former Financial Adviser (Defence Services), Ministry of Defence, GoI 54. Jugal Mohapatra IAS (Retd.) Former Secretary, Department of Rural Development, GoI

55. Ruchira Mukerjee IP&TAFS (Retd.) Former Advisor (Finance), Telecom Commission, GoI

56. Anup Mukerji IAS (Retd.) Former Chief Secretary, Govt. of Bihar

57. Deb Mukharji IFS (Retd.) Former High Commissioner to Bangladesh and former Ambassador to Nepal

58. Shiv Shankar Mukherjee IFS (Retd.) Former High Commissioner to the United Kingdom

59. Gautam Mukhopadhaya IFS (Retd.) Former Ambassador to Myanmar

60. T.K.A. Nair IAS (Retd.) Former Adviser to Prime Minister of India

61. Ramesh Narayanaswami IAS (Retd.) Former Chief Secretary, Govt. of NCT of Delhi

62. P. Joy Oommen IAS (Retd.) Former Chief Secretary, Govt. of Chhattisgarh

63. Amitabha Pande IAS (Retd.) Former Secretary, Inter-State Council, GoI

64. Maxwell Pereira IPS (Retd.) Former Joint Commissioner of Police, Delhi

65. R. Poornalingam IAS (Retd.) Former Secretary, Ministry of Textiles, GoI

66. N.K. Raghupathy IAS (Retd.) Former Chairman, Staff Selection Commission, GoI

67. V. Ramani IAS (Retd.) Former Director General, YASHADA, Govt. of Maharashtra

68. M. Rameshkumar IAS (Retd.) Former Member, Maharashtra Administrative Tribunal

69. K. Sujatha Rao IAS (Retd.) Former Health Secretary, GoI

70. Satwant Reddy IAS (Retd.) Former Secretary, Chemicals and Petrochemicals, GoI

71. Vijaya Latha Reddy IFS (Retd.) Former Deputy National Security Adviser, GoI

72. Julio Ribeiro IPS (Retd.) Former Director General of Police, Govt. of Punjab

73. Aruna Roy IAS (Resigned)

74. Deepak Sanan IAS (Retd.) Former Principal Adviser (AR) to Chief Minister, Govt. of Himachal Pradesh

75. G.V. Venugopala Sarma IAS (Retd.) Former Member, Board of Revenue, Govt. of Odisha

76. N.C. Saxena IAS (Retd.) Former Secretary, Planning Commission, GoI

77. Abhijit Sengupta IAS (Retd.) Former Secretary, Ministry of Culture, GoI

78. Aftab Seth IFS (Retd.) Former Ambassador to Japan 79. Ashok Kumar Sharma IFoS (Retd.) Former MD, State Forest Development Corporation, Govt. of Gujarat

80. Ashok Kumar Sharma IFS (Retd.) Former Ambassador to Finland and Estonia

81. Aruna Sharma IAS (Retd.) Former Secretary, Steel, GoI

82. Navrekha Sharma IFS (Retd.) Former Ambassador to Indonesia

83. Raju Sharma IAS (Retd.) Former Member, Board of Revenue, Govt. of Uttar Pradesh

84. K.S. Sidhu IAS (Retd.) Former Principal Secretary, Govt. of Maharashtra

85. Mukteshwar Singh IAS (Retd.) Former Member, Madhya Pradesh Public Service Commission

86. Padamvir Singh IAS (Retd.) Former Director, LBSNAA, Mussoorie, GoI

87. Tara Ajai Singh IAS (Retd.) Former Additional Chief Secretary, Govt. of Karnataka

88. Tirlochan Singh IAS (Retd.) Former Secretary, National Commission for Minorities, GoI

89. Prakriti Srivastava IFoS (Retd.) Former Principal Chief Conservator of Forests & Special Officer, Rebuild Kerala Development Programme, Govt. of Kerala

90. Anup Thakur IAS (Retd.) Former Member, National Consumer Disputes Redressal Commission

91. P.S.S. Thomas IAS (Retd.) Former Secretary General, National Human Rights Commission

92. Geetha Thoopal IRAS (Retd.) Former General Manager, Metro Railway, Kolkata

93. Ashok Vajpeyi IAS (Retd.) Former Chairman, Lalit Kala Akademi.