statistics. The burden to clarify such data rests solely on the ECI, as a constitutional authority, without waiting for procedural triggers. 6. Demand In light of the above, you are hereby called upon to: Immediately issue a point-by-point public clarification on the alleged discrepancies. Publish the complete raw data relating to voter turnout, votes polled, and final results in a machine-readable format for independent verification. Facilitate an independent technical audit of the electronic and manual voting records by a panel comprising retired judges, data scientists, and civil society representatives. 7. Consequences of Non-Compliance Please take notice that if you fail to issue the above clarifications within 7 days of receipt of this representation, appropriate proceedings shall be initiated before the Hon’ble Supreme Court of India under Article 32, seeking judicial directions to ensure electoral transparency, together with any other remedies available in law, including under the Right to Information Act, 2005. Issued in the interest of safeguarding the sanctity of the electoral process, the basic structure of the Constitution, and the public’s faith in the world’s largest democracy. Date: 8 / 8/ 2025 Place: chennai Name: __Adv CA venkatasivakumar By patriotic citizens Dr Sirish kumar Adv venkatasivakumar CA Dinesh Dwivedi Prafull Upadhyay CA Ravikumar Dr Giridharan CA Logunathan CA Allamma Prabhu Viswanathan

[08/08, 18:09] Venkatasivakumar Mhc Adv: —
LEGAL NOTICE / REPRESENTATION
(Under Article 324 of the Constitution of India read with Principles of Transparency under the Right to Information Act, 2005)

To
The Chief Election Commissioner
Election Commission of India
Nirvachan Sadan, New Delhi – 110001

Subject: Demand for Immediate Clarification on Discrepancies in ECI’s Published Electoral Data and Allegations of Vote Manipulation

Sir,

1. Background
It has come to public notice, through the statement of Shri Rahul Gandhi, Member of Parliament, that certain serious discrepancies exist in the electoral data published by the Election Commission of India itself. The said statement is based entirely on figures and statistics uploaded by the ECI, which prima facie suggest possible irregularities favouring a particular political party.

2. Constitutional Position
Under Article 324 of the Constitution of India, the ECI is vested with the superintendence, direction, and control of elections to Parliament and State Legislatures. The Supreme Court in Mohinder Singh Gill v. CEC (1978) 1 SCC 405 has categorically held that this power carries with it the duty to act fairly, transparently, and in a manner that maintains public confidence in the electoral process.

3. Institutional Accountability
The Indira Nehru Gandhi v. Raj Narain (1975 Supp SCC 1) judgment recognises free and fair elections as part of the basic structure of the Constitution. When allegations are raised based on the Commission’s own published data, it is the ECI — and not the citizen — that bears the primary responsibility to clarify, correct, or justify such data in the public domain.

4. Public Right to Information
The Supreme Court in State of UP v. Raj Narain (AIR 1975 SC 865) held that citizens have the fundamental right to know the workings of public institutions, especially in matters affecting governance and representation. Likewise, Subramanian Swamy v. ECI (2013) 10 SCC 500 emphasised that even the possibility of manipulation demands proactive corrective measures.

5. Current Concern
Instead of issuing a data-backed clarification to address these allegations, the ECI has reportedly asked Shri Rahul Gandhi to submit a complaint in the form of an affidavit. This response is legally unsustainable because:

The allegations are not based on private or unverifiable claims, but on ECI’s own published statistics.

The burden to clarify such data rests solely on the ECI, as a constitutional authority, without waiting for procedural triggers.

6. Demand
In light of the above, you are hereby called upon to:

Immediately issue a point-by-point public clarification on the alleged discrepancies.

Publish the complete raw data relating to voter turnout, votes polled, and final results in a machine-readable format for independent verification.

Facilitate an independent technical audit of the electronic and manual voting records by a panel comprising retired judges, data scientists, and civil society representatives.

7. Consequences of Non-Compliance
Please take notice that if you fail to issue the above clarifications within 7 days of receipt of this representation, appropriate proceedings shall be initiated before the Hon’ble Supreme Court of India under Article 32, seeking judicial directions to ensure electoral transparency, together with any other remedies available in law, including under the Right to Information Act, 2005.

Issued in the interest of safeguarding the sanctity of the electoral process, the basic structure of the Constitution, and the public’s faith in the world’s largest democracy.

Date: 8 / 8/ 2025
Place: chennai

Name: __Adv CA venkatasivakumar

By patriotic citizens

Dr Sirish kumar
Adv venkatasivakumar
CA Dinesh Dwivedi
Prafull Upadhyay
CA Ravikumar
Dr Giridharan
CA Logunathan
CA Allamma Prabhu
Viswanathan
[09/08, 07:53] Sekarreporter: 👍