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THE JOURNEY OF ELECTION COMMISSION, FROM 1950 TO 2023, WITH SPECIAL REFERENCE TO THE CASE OF TN SHESHAN.
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Authors : RISHAB. D. GOLANI & PUJITA AGARWAL
Registration ID : 106418 Published Paper ID: IJLRA6418 & IJLRA6419
Year : Dec-2023 | Volume : II | Issue : 7
Approved ISSN : 2582-6433 | Country : Delhi, India
Email Id : rishabgolani05@gmail.com & pujita2005@gmail.com
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Article Details
THE JOURNEY
OF ELECTION COMMISSION, FROM 1950 TO 2023, WITH SPECIAL REFERENCE TO THE CASE
OF TN SHESHAN.
AUTHORED BY
- RISHAB. D. GOLANI* & PUJITA
AGARWAL**
ABSTRACT
Elections are the key element in a
democracy as the citizens have the ultimate right to choose their
representative to the government. While drafting the Constitution of India the
makers had a noble idea of having India a “democratic and a republican” nation.
To ensure this idea of democracy in India, the Constitution under Article 324,
Part XV provides for an independent Commission, known as the “Election
Commission” who are entrusted with the duty to conduct and ensure free and fair
elections throughout the nation. Initially this commission was a single member
body and the Constitution provided the scope for a multi-member body. With
India being a varied and diversified nation, with 28 states and 8 union
territories and much smaller divided units within, elections are conducted on a
larger level and this is a mammoth task. The main question which arises is
whether such enormous task, especially in country like India where the
population and literacy is on rise, can be accomplished by a single-member
body? The conflict between the need and the importance of a multi-member
commission over a single member commission and the problems that arose by such
composition were decided in the landmark case of ‘T.N. Seshan Chief Election
Commissioner of India v Union of India.’ This article will try to analysis this
landmark case in the light of legal conceptual understanding as well as the
practical application and nuances of the concept and also recent developments
in this field of constitutional law.
Keywords: Election Commission, Multi-Member
body, Chief Election Commissioner, Democracy, Free and Fair elections.
INTRODUCTION
The Preamble of Indian Constitution
starts with “We, the people of India, having solemnly resolved to constitute
India into sovereign socialist secular democratic republic”.[1] Thus,
the people of India declared India to be a democratic state and democracy as
defined by Abraham Lincoln, is a government “by the people, for the people, to
the people”. Republic- “form of government in which the state is ruled by the
representatives as chosen by the citizens of the country”.
“Free and fair elections” are the cornerstone of democracy and
are essential for ensuring that the will of the people is reflected in the
government. People elect their representatives through elections, the sovereign
power lies in the hands of the people. The government is further answerable to
the people for their actions. These elections are conducted once in every 5
years to elect the representatives at the Lok Sabha (general elections) and the
Legislative Assembly (State Assembly elections). Thus, upholding the ideal of Democratic
Republic as declared by the Preamble.
The implied understanding of having
free and fair elections is that everyone should have equal political rights. So,
having equal rights in terms of standing up to the elections, portraying their
goals and objectives and then leaving it up to the citizens for selection. In
India, we do have a multi-party system in which people have a right to choose their
elected representative out of the members contesting elections. Therefore,
anyone who is qualified as per the Constitution to contest elections should not
be deprived of doing so (giving a chance of choice to people). And for the
people, equal rights here mean given a fair chance to vote and to elect
representative of their choice by whom they wish to be governed. Inequalities
do exist in a society, but this political right shall be given to everyone
despite the inequalities. This brought up the concept of Universal Adult
Franchise- “one person, one vote”, for all the people above 18 years of age,
hence adult.
To understand the democracy of India
better, we can compare it to other countries like China which is a multi-party
socialist state with Communist Party of China as its dominant head and Pakistan
where even after 75 years of Independence, democracy feels a far-fledged idea. In
China, the communist party is the only option that people have and the
so-called choice they give to people in the form of candidates to elect out of is
just for namesake as the whole monopoly is in the hands of the dominant leader
in the end; for example- the current President “Xi Jinping”, currently in his 3rd
term, has been in power since 2013 will hold power atleast till 2028 and maybe
even further. On the other hand, Pakistan who even after so long has failed to
understand the true meaning and essence of democracy. It took them 25 years to
draft a constitution for themselves and government there always being dominated
by the Army. In these 75 years, NO Prime Minister has completed their full
term of 5 years successfully and also out of 75 years, for more than 31 years,
they have been ruled by Army (1958-1971, 1977-1988, 1999-2008). Unlike
Pakistan, India, in its 75 years of Independence has established a democracy,
the Constitution makers of India very initially understood the importance of
this democracy and therefore, our constitution ensures a government elected by
people, conduct of free and fair elections, Universal Adult Franchise and an
Independent body- free from executive pressure with a responsibility for
conduct of elections throughout India in the form of “Election Commission”.
To ensure free and fair elections,
the Constitution provides for this independent and impartial body that directs,
superintends and controls the election. This Commission is known as the
“Election Commission” as under Article 324 of the Constitution. It’s called the
“Watchdog of free and fair elections”.
Over the years, there has been many
questions regarding Election Commission, its constitutional position and its
components.
NEED FOR A MULTI-MEMBER BODY
The supreme court, in a case where the
constitutional validity of The CEC And Other Election Commissioners (Conditions
of Service) Amendment (then Ordinance) Act, 1993 was challenged,
along with the two appointments made by the central government in furtherance
of this ordinance of the election commissioners.
The first question to be answered by
the hon’ble Supreme court was whether the impugned act was mala-fide in nature.
The then CEC i.e., T.N Seshan challenged the constitutional validity of a
multi-member body and that the power of Ordinance given to President under
Articles 123 and 324(2) was misused to bring an ordinance. The court rejected
this contention of the petitioner saying that there has been a need for
multi-member bodies and the same has also been suggested by various reports of
different Committees.
We think that the court has taken
this matter in a light connotation and did not go deep into it, because the
report that they have referred to i.e., “The Joint Committee of both Houses of
Parliament report, 1972; Tarkunde Committee, 1974; Jaya Prakash Narayan
Committee, 1974” favoured a multi-member Election Commission. Also, the “committee
on electoral reforms appointed by Janata Dal Party, in its 1990 report”,
mentioned the importance of multi-member election commission. But no step was
taken to implement or consider it. These reports existed even during the framing
of the new act in 1991. But suddenly, the importance was recognised in 1993. There
might have been a possibility of existence of mala fide intention of government
which was completely ignored by the Bench. The Bench also ignored the
allegation raised that one of the Election Commissioner appointed was a ‘close
friend of the Prime Minister’. The author through this argument by no means
is against the multi member body as will be analysed in the further part, but
court could have looked deep into the point that if there was any mala-fide in
the appointment of those two persons as EC and also if they were making
the work of the CEC completely unworkable; that would have curbed this argument
without a lacuna.
Now the second and the most important
question before the court was ‘whether election commission should be a multi
member body or not.’ The petitioner, the then CEC i.e., T.N Seshan,
contended that Election Commission should not be a multi member body as it is
against the scheme of article 324 (2). It was challenged that Election
Commission must be a single member body headed by the CEC (CEC). The petitioner
also alleged that multi member body for Election Commission will be unworkable.
This argument of the petitioner was outrightly rejected by the court, and
rightly so, because even a plain reading of “Article 324 (2) of the Constitution
of India” permits the Election Commission to be a multi-member body.
In the case of S.S. Dhanoa v Union of
India[2],
the President first created two posts of Election Commissioner through a
notification, but later abolished it, and when challenged, the court upheld the
abolition. But the
Supreme Court ‘did not oppose a multi-member Commission, by abolishing the
posts of the ECs, but instead intended to ensure the smooth functioning of this
body because of which it decided to abolish their posts. The smooth
functioning here was absent due to the absence of any procedural rules in relation to the
manner of functioning of a multi-member Commission, their appointment was found
to have rendered the functioning of the Commission unworkable[3].’
Before S.S. Dhanoa case there was 61st
constitutional amendment, 1989[4] which
reduced the age of voting from 21 years of age to 18 years, so, the President felt
the need of additional EC’s so as to conduct the elections smoothly as it would
lead to increase in the number of people voting thus increasing the work of
Election Commission. But, as the court in that case rightly observed to curb
the extra work, there was a need of additional number of employees. For
Election Commissioners, as mentioned above, there was a want of procedural
requirements in relation to working of multi-member commission.
While analysing the need of multi-member Election Commission,
the court has taken reference of various committee reports. These are:
·
Tarkunde
Committee Report of 1975[5]- Jayprakash Narayan
appointed this committee on behalf of the Citizens for Democracy. The key
recommendations of the committee:
-
Evaluate and recommend
changes to the voting process in India.
-
Address issues with the
electoral process
-
Suggest ways to make it more
transparent, fair and efficient.
Some of the important recommendations by them:
-
“Lower the voting age” from
21 to 18 years (which was eventually done in 61st Constitutional
Amendment).
-
Create a “three-
member election commission”
-
ECs be appointed on the
advice of a committee comprising the “Prime Minister, Lok Sabha Opposition
Leader and the Chief Justice.”
-
“Multi-member body with 3
members.”
-
CEC Appointment: Appointed
by the “President in Consultation with the Chief Justice of India and the
Leader of the Opposition” (In case no Leader of the Opposition is available,
consult with the Leader of the largest opposition group in the Lok Sabha.)
-
Appointment of Other Two
Election Commissioners: Consultation with Chief Justice of India, CEC and with
the Leader of the Opposition (In case no Leader of the Opposition is available,
consult with the Leader of the largest opposition group in the Lok Sabha.)
-
The consultation process
should have statutory backing.
-
Regional Commissioners: Not
favoured for appointment. Appointments should be made only as necessary. Should
not be on a permanent footing.
-
Repoll or countermanding
decisions should not solely rely on the returning officer's report. ‘The
Election Commission should have the power to appoint investigating and
prosecuting agencies’ for any wrong they find.
-
Assign the Election
Commission the task of monitoring expenses.
The
court also emphasized on the need of multi-member commission, as the work of
the election commission is tremendous. As mentioned earlier that the 2 election
commissioners appointed in 1989 in the case of S.S Dhanoa was in view of 61st
constitutional amendment as lowering down the age of eligible voting from 21 to
18 would have increased the voting pool. Similarly in 1992-93 with 73rd[7]
and 74th[8]
constitutional amendment the government introduced third tire of government in
Indian federalism and provided a basic framework of decentralization of powers
and authorities to the Municipal bodies at different levels. So 61st, 73rd and
74th amendment read together can be a good example to show how the work of
Election commission has increased over the years and is not same as it was at
the time of framing of our constitution in 1950, and at that point of time
single member body would have suffice the work, but with time, increase in work
demands dilution of powers that can be done by introducing ECs as permanent
members.
Shri
K.M Munshi’s in constitutional assembly remarked: “We cannot have an election
Commission sitting all the time during those five years doing nothing. The CEC
will continue to be a whole- time officer performing the duties of his office
and looking after the work from day to day but when major elections take place
in the country, either Provincial or Central, the Commission must be enlarged
to cope with the work. More members therefore have to be added to the
Commission. They are no doubt to be appointed by the President. Therefore, to
that extent their independence is ensured. So, there is no reason to believe
that these temporary Election Commissioners will not have the necessary measure
of independence."[9]
Over
the years the number of people eligible to vote and turnout in voting has also
increased. “Since 1962 the number of electors has increased 4 times”,
from 21.64 Crores in 1962 to 91.05 Crores in 2019. It is predicted by the
election commission that in general election 2024 eligible voters will be more
than 95 crores and that election commission has set up a target to have at
least 75% of voters turn out in 2024 elections (Chart 1). Also, the number of
people voting in India is largest in the world. “India’s
number of registered voters is almost four times that of the U.S”, the second
country on the list (Chart 2).[10] These
numbers should be sufficient to understand the tremendous and significant task
that is vested in the hands of election commission and that the situation today
cannot be compared with what has been there some decades ago.
The
petitioner i.e., CEC challenged the act of government to bring in the post of
ECs as arbitrary, but it would be wrong to think in that manner. As already
established that the work and the responsibility upon the commission is to
protect the democracy and carrying out such a big task by one member in neither
possible nor desirable. Vesting so much of power in one hand would be giving
unfettered and arbitrary powers to the CEC and can lead to misuse of such
powers, so the act of the government cannot be said to be arbitrary but is to
prevent arbitrary powers.
CHARTS: -
|
“Chart 1-
shows the number of electors and the voter turnout in the past 15 Lok Sabha
elections. From 21.63 crore electors in 1962, the count increased to 91.05
crore in 2019. The total number of voters on January 1 this year was
94,50,25,694 (94.5 crore). The voter turnout has increased significantly in
recent years and crossed the 65% mark in the last two general elections.
But 35% still remain absent from the process.”
|
|
“Chart 2- shows
the number of electors registered for the most recent
parliamentary/presidential elections in select countries. Only the top 10
countries are depicted. The ECI has a big task on hand given that India’s
number of registered voters is almost four times that of the U.S., the
second country on the list. India’s voter base exceeds the combined numbers
of the U.S., Indonesia, Brazil, Russia, Pakistan and Japan.”
|
Source- The Hindu[11]
The third, and the final question
that was posed before the court was with respect to the “difference in rank
of the CEC and the Election Commissioners. the petitioner”, the then CEC
i.e., T.N Seshan, contended that the position of the CEC is at a superior
position than that of Election Commissioner for a number of reasons. They are:
-
The
Constitution under ‘Article 324(2) provides CEC as a permanent member’ whereas ‘Election
Commissioners were not regarded as the permanent members.’
-
The
Constitution under Article 324(3) appoints CEC as the Chairman of the Election
Commission in-case any other EC is appointed.
-
The
Constitution under Article 324(5) provides that removal of “CEC shall be
done in the same manner as that of a Supreme Court Judge”, i.e., removal by
bringing in a special resolution in the Parliament, as under Article 124(4) of
the Constitution; but ‘Election Commissioner can be removed by the President
on the advice of the CEC, provided that there are sufficient reasons to do the
same.’
-
According
to sections 3(1) and 3(2) and section 8 of the Act of 1991 (before amendment of
1993), the CEC is entitled to salary and allowances equal to that of a Supreme
Court Judge, and the Election Commissioners are entitled to salary and
allowances equal to that of a High Court Judge, respectively.
-
As
per section 4 of the Act of 1991 (before amendment of 1993), the retirement age
of the CEC would be 65 years of age and the same for the Election Commissioners
would be 62 years of age.
But certain changes were
made by Amending Act of 1993 in the abovementioned service conditions of CECs
and Election Commissioners. They were as follows:
-
The
petitioner contended that the Amendment Act 1994 made Election Commissioners as
permanent members which is against the scheme of Article 324, but this was
rightly rejected by the court as 324 cannot be interpreted in that narrow term,
and Election Commissioners are ought to be permanent members for the reasons
previously discussed.
-
The
Amendment Act of 1994 changed the salary of Election Commissioners from that of
High Court Judges and equated to that of CECs, i.e., salary equal to Supreme
Court Judge.
-
The
Amendment Act of 1994 increased the retirement age of Election Commissioners
equal to that of the CECs, i.e., 65 years of age.
-
The
name of the act was changed from “The Chief Election Commissioner and other
Election Commissioners (Conditions of Service), 1991” to “The
Election Commission (Conditions of Service of Election Commissioners and
Transaction of Business) Act, 1991”.
-
For
decision making process, the decisions as far as possible, must be unanimous
and if there is any conflict of opinions, the majority view will be accepted as
the final decision.
The petitioner challenged the
amendment on the ground that all the abovementioned provisions before the 1994
Act used to give CEC a superior position to that of Election Commissioner, but
the Amendment Act as was brought with a mala-fide intention equated the
position and powers of Election Commissioner with that of CEC. He challenged
the provision equating salaries and allowances of Election Commissioners with
that of Supreme Court Judge, putting CEC and ECs on an equal footing. Also, the
provision providing for majority view in case of conflict of opinions was also
challenged as it lowers down the importance CEC has under Constitution, i.e.,
as that of a Chairman of the Election Commission while it’s a multi-member
body.
All these contentions were rejected
by the hon’ble Supreme Court as it holds no sufficient ground. For the
contention that majority view is to be taken is violative of Article 324, the
court referred to the meaning of the word “Chairman” under various dictionary
meaning and general use of the term and concluded that the work of the Chairman
was to preside over the meeting, ensure correct decisions were taken in a fair
manner, and all those steps are taken which are required for the smooth
functioning of the Commission. Also, the court observed “to project the
individual mightier than the institution would be a grave mistake. Therefore,
even if the Election Commission is a single-member body, the CEC is merely a
functionary of that body; to put it differently, the alter ego of the
Commission and no more. And if it is a multi-member body, CEC is obliged to act
as its chairman.”
This can be better understood by
comparing the situation and powers of CEC with that of Chief Justice of India.
Like CJI is known as the “master of the roster”, he decides the bench for a
case, he overlooks the working of the court, he overlooks the legislative
functions of the court (for administrative purposes) etc. but while decision
making inside the court, he does not have any special powers, decision of a
case if not unanimous is taken by the majority view and even if the CJI is in descending
opinion it does not make any difference to the final outcome of the judgement.
For example, in the recent case of Janhit Abhiyan vs UOI[12]
where the 103rd Constitutional Amendment[13]
was challenged the then CJI J. UU Lalit gave descending opinion but majority
view (3:2) upheld the constitutional validity of the amendment and the decision
was taken accordingly.
To ensure the independence of the
Election Commissioner and to keep it free from external pressure which would
have compromised the decision making of the CEC, Constitution under Art 324
provides “Chief Election Commissioner shall not be removed from his office
except in like manner and on the like grounds as a Judge of the Supreme Court
and the conditions of service of the Chief Election Commissioner shall not be
varied to his disadvantage after his appointment.” But for the removal of
Election Commissioner, if appointed, it provides that he/she can be removed by
the President on the recommendation of CEC. The petitioner challenged that in
the present case that the alterations made to the conditions of service of EC
is violative of this differentiation created and this process of removal in
itself shows the intent of the constitutional makers to keep EC as a temporary
member of the commission and that at the peril of CEC. This contention was also
rejected by the court and the court explained that EC is a very important and
crucial member of the commission and rightly so for the various reasons
abovementioned. Court also explained that just because ECs can be removed from
the office on the recommendation of the CEC, that does not mean CEC can misuse
this power vested in his/her hand. It should be used wisely and the
recommendation made must be intelligible, reasonable and must provide adequate
reasons for removal. The court held, “of course, the recommendation for removal
must be based on intelligible, and cogent considerations which
would have relation to efficient functioning of the Election Commission. That
is so because this privilege has been conferred on the CEC to ensure that the
ECs as well as the RCs are not at the mercy of political or executive bosses
of the day.”
CONCLUSION
There is no doubt that democracy is
an essential feature and ideal of the Constitution of India and free and fair
elections are a pathway to achieve the same. When the representatives that are
elected by the people are held accountable for their actions, the real purpose
of this democratic system reflects, highlighting the importance of it. In such
a diverse country like India and with such a high number of and diverse
population conducting elections is indeed a mammoth task and it was duly
understood by the constitution makers and thus an independent and self-reliant
constitutional body was constituted under the constitution i.e., The Election
Commission of India.
The legislators in 1993 made a change
in the structure of Election Commission by adding new limbs for its better and
effective working, i.e., the post of Election Commissioner and making it a multi-member
body. This was done by considering increasing task of Election Commission with
increasing population and awareness amongst people. Various committees over the
years have recommended this electoral reform which was recognised by the
Parliament.
The importance of having Election
Commissioners as an aid to the CEC as was recognised by the judges in this case,
was indeed a good step and it can be felt even today, as the number of electors
has only been increasing and with every new general election, numbers make new
records.
Even after this case, there has been
various other electoral reforms suggested by various committees to ensure
accountability and effective working of Election Commission. In 1999 and 2015,
170th Law Commission Report and 255th Law Commission
Report, respectively, suggested that there must be a body comprising of Chief Justice of India and
the Leader of the Opposition for recommending the names of CEC and ECs
to President for appointments; to ensure the independence of Election
Commission as now the appointment is made by the President on the advice of
Council of Ministers. This year, in case of Anoop Baranwal v Union of India[14], held
that till the time Parliament comes up with a law on this point, i.e.,
Independent Committee for appointment of CEC and ECs, the recommendations will
be made by a committee comprising of Chief Justice of India, Prime Minister and
Leader of Opposition. In case there is no Leader of Opposition, consult with the
Leader of the largest opposition group in the Lok Sabha. In furtherance of this
decision, Parliament has brought The Chief Election Commissioner and Other
Election Commissioners (Appointment, Conditions of Service and Term of Office)
Bill, 2023, that will be placed before the Parliament in the special session
starting from 18th September 2023. The Bill seeks to amend The Election Commission (Conditions Of
Service Of Election Commissioners And Transaction Of
Business) Act, 1991 and form a “selection committee” comprising
of “the Prime Minister as Chairperson, (ii) the Leader of the Opposition in Lok
Sabha as member, and (iii) a Union Cabinet Minister nominated by the Prime
Minister as member. If the Leader of
Opposition in Lok Sabha has not been recognised, the leader of the single
largest opposition party in Lok Sabha will assume the role.”; and
this committee will be working on the advice of a “search committee” which
‘will prepare a panel of five persons for the consideration of the Selection
Committee. The Search Committee will be
headed by the Cabinet Secretary. It will
have two other members, not below the rank of Secretary to the central
government, having knowledge and experience in matters related to
elections. The Selection Committee may
also consider candidates who have not been included in the panel prepared by
the Search Committee.’
This Bill has raised many eyebrows for
the point that it equates the salaries and allowances of CEC and ECs to that of
a Cabinet Secretary. It is a major concern that Parliament is trying to degrade
the rank of CEC and ECs from that of Supreme Court Judge to Cabinet Secretary.
The opinion and reason behind it will get more clearer once the Bill will be
taken up by Parliament, and that through the discussions that will take place
there. The court in the present case has stated that equating salaries and
allowances of CEC with that of Supreme Court Judge does not give him powers
similar to that of a SC Judge and it must be confined only for the matters
stated in the law i.e., salaries, allowances etc. And, as of 2023, the salary
of a SC Judge is same as that of Cabinet Secretary (i.e., 2,50,000/- per month)
but there are certain differences in allowances. So, will it be such a big
issue? Time has a better answer.
Politics and elections have never
ceased to amaze and take turning points- many more is yet to come. With general
elections for India scheduled in 2024, election commission has a tedious task
ahead as the number of voters are on a rise and also with the talks of
implementation of “One Nation- One Election” around the corner the role of
election commission becomes crucial and that the importance of multi-member
body for its free functioning.
In the end, above all this game of
power and politics we all shall remember what hon’ble ex- Prime Minister Atal
Bihari Vajpayee has very rightly said “Governments will come and go, parties
will be formed and will deteriorate, but this country should remain.”[15]
[1] Constitution of India, 1950.
[2] S.S. Dhanoa v Union of India,
[1991], Supreme Court of India, 1991 AIR 1745, 1991 SCR (3) 159.
[3] Mr. Ashwini Chawla, A Critical Study of the Position of
the CEC in the Light of Cases Such as SS Dhanoa V. Union Of India and TN Seshan
V. Union Of India, Sept 6, 2004, A
Critical Study of the Position of the CEC in the Light of Cases Such as SS
Dhanoa V. Union Of India and TN Seshan V. Union Of India (manupatra.com) accessed 1st November 2023.
[4] The Constitution (Sixty-First
Amendment) Act, 1989.
[5] Report of the Committee on
Electoral Reforms (Tarkunde Committee), Citizens for Democracy, (1975)
[6] Ministry of Law and Justice, Committee
on Electoral Reforms, Report of the Committee on Electoral Reforms, May 1990.
[7] The Constitution (Seventy-Third
Amendment) Act, 1992.
[8] The Constitution (Seventy- Fourth
Amendment) Act, 1992.
[9] Constitutional Assembly Debates
Vol. VIII (1949).
[10]The
Hindu, DATA-30 crore missing voters in India: Mostly
young, urban or migrants, February 11, 2023, https://www.thehindu.com/data/data-30-crore-missing-voters-in-india-mostly-young-urban-or-migrants/article66485421.ece, accessed 31st October 2023.
[11] DATA-30 crore missing voters in India: Mostly young, urban or migrants, February 11, 2023, https://www.thehindu.com/data/data-30-crore-missing-voters-in-india-mostly-young-urban-or-migrants/article66485421.ece, accessed 31st October 2023.
[12] Janhit Abhiyan v Union of India, [2022],
Supreme Court of India, (2023) 5 SCC 1; 2022 SCC Online SC 1540, (India).
[13] The Constitution (One Hundred and
Third Amendment) Act, 2019.
[14] Anoop Baranwal v Union of India, [2023],
Supreme Court of India, (2023) 6 SCC 161, (India).
[15] Prime Minister Atal Bihari
Vajpayee: Motion of Confidence 28th May 1996, Parliament of India,
Digital Library, https://eparlib.nic.in/handle/123456789/809245?view_type=browse,
accessed 1st November 2023.
Article Information
THE JOURNEY OF ELECTION COMMISSION, FROM 1950 TO 2023, WITH SPECIAL REFERENCE TO THE CASE OF TN SHESHAN.
Authors: RISHAB. D. GOLANI, PUJITA AGARWAL
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/12/07
- Issue 7
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