An independent institute of public policy research · Lucknow, India

The Research Library · Justice and Legal Studies · Commentary

Archipelago and Subcontinent: Two Democracies, One Voter-List Problem

Indonesia builds its voter list on a civil registry and a lawful fallback; India, for now, relies on intensive revision, and the registry is the lesson to carry across.

Archipelago and Subcontinent: Two Democracies, One Voter-List Problem

Two of the world’s largest democracies ask their citizens to line up on a single day and choose a government, and both must first answer a prior question: who, exactly, is entitled to stand in the line? Indonesia, an archipelago of thousands of islands, and India, a subcontinent of 28 States, have reached different answers. Comparing the voter lists of India and Indonesia is useful because it separates two things that are often confused: the size of the electorate and the quality of the state machinery that registers it.

India and Indonesia: two voter lists, two scales

India’s Election Commission put the number of registered electors at over 96.88 crore in February 2024, on rolls with a qualifying date of 1 January 2024. That year’s summary revision added over 2.63 crore new electors and removed 1,65,76,654 names of persons who had died, permanently shifted or were duplicated.

Indonesia’s General Elections Commission (KPU) fixed the permanent voter list (Daftar Pemilih Tetap, DPT) for the 2024 elections at 204,807,222 voters at a plenary meeting on 2 July 2023. Of these, 203,056,748 were domestic voters and 1,750,474 were overseas. The list was recapitulated province by province for all 38 provinces, with West Java the largest at 35,714,901.

India’s electorate is therefore nearly five times the size of Indonesia’s. Yet the contrast that matters is not the headcount. It is the architecture.

How Indonesia builds its list

Indonesia’s list starts from the civil registry. In March 2023, when the KPU launched the voter data update for 2024, it worked from a synchronisation of the potential voter population data (DP4) with the existing DPT, a base of 204,559,713 voters. Field officers, the pantarlih, then used that synchronised data as their working tool to match and check entries on the ground, a process called coklit (pencocokan dan penelitian). The list is thus a continuous product of two things: a population database kept by the state, and a physical check at the doorstep.

Indonesia also builds a safety valve for the citizen who is missed. Article 348(8) of the Election Law, Law No. 7 of 2017, allows a holder of the electronic ID card (KTP-el) who is on neither the DPT nor the supplementary list to vote using that card. The Constitutional Court, in decision no. 20/PUU-XVII/2019, read this more broadly to cover the certificate issued by civil registry offices to show that a person’s KTP-el recording is done. A voter who moves must register on the supplementary list (DPTb) under Article 210(1) at least 30 days before polling, and the Court permitted later registration, up to seven days before polling, for illness, natural disaster, detention or official duty. The Court’s reasoning was that voting rights cannot be set aside by technical matters alone.

How India builds its list

India’s roll is a statutory document maintained by Electoral Registration Officers under the Representation of the People Act, 1950, and the Registration of Electors Rules, 1960. It is updated by revisions: annual summary revisions, and, where the Commission judges it necessary under section 21(3), a special revision that can be intensive.

The Bihar SIR of 2025 shows what such a revision involves. The Election Commission ordered it on 24 June 2025, treated the 2003 roll as probative, and required persons not on that roll to submit one of eleven listed documents. According to the Supreme Court’s judgment of 27 May 2026 in Association for Democratic Reforms v. Election Commission of India (2026 INSC 564), the rolls stood at about 7.89 crore before the revision; the draft roll of 1 August 2025 had about 7.24 crore, and the final roll of 30 September 2025 about 7.42 crore. The Court upheld the exercise. It accepted the Commission’s reason that, since 2003, only summary revisions had been done, and that relying on them alone for two decades could let inaccuracies build up. During the case it directed that Aadhaar be accepted as a twelfth document of identity, while the reports of the judgment record that Aadhaar is not proof of citizenship.

What India could take from Indonesia

The first lesson is about the spine of the system. Indonesia’s list rests on a population database that already exists, so the rolls start each cycle from a base of identified residents, and the field work verifies rather than creates. India does not yet have such a spine for the roll. There is a step in that direction: the Registration of Births and Deaths (Amendment) Act, 2023, passed by the Lok Sabha on 1 August and the Rajya Sabha on 7 August 2023, provides for a national database of registered births and deaths which “may be made available” to authorities maintaining other databases, including the electoral rolls, with the Central Government’s approval for each use, as summarised by PRS Legislative Research. If that database becomes complete and timely, it can take over the routine work of removing the dead and adding the newly eligible, which is the work that the 1,65,76,654 deletions of 2024 represent. Intensive revisions could then be reserved for the exceptional case.

The second lesson is about the safety valve. Every list contains errors, and the question is what happens to the citizen on the day of polling. Indonesia’s answer, an identity card plus a lawful fallback, is humane and easy to understand.

The strongest objection

The objection is that the Indonesian model cannot be copied. Indonesia’s fallback rests on an identity card tied to the civil registry. India’s closest equivalent, Aadhaar, is accepted for identity but, as the Supreme Court made clear, is not proof of citizenship, and a citizenship test is the very thing a roll must apply under Article 326. A rule that lets anyone with an identity card vote when absent from the list would, in India’s setting, widen the gap that the SIR tries to close.

That is right, and it is why the transferable lesson is the sequence and not the device. Indonesia first built the registry, then relied on it. India should do the same: complete and link the birth and death database so that the roll is largely fed from reliable civil records; retain the notice, hearing and appeal that the Court found sufficient; and consider a narrow, verified fallback only when the registry is strong enough to bear it. The Indonesian experience also shows that an alert court matters: it was the Constitutional Court that kept technical requirements from defeating the vote.

Conclusion

Both democracies want a list that is complete, accurate and open to correction, and both know that a roll too loose invites doubt about the result while a roll too tight shuts out citizens. Indonesia reaches the balance through its civil registry and a lawful fallback at the polling station. India reaches it, for now, through periodic intensive revision, upheld by the Supreme Court and backed by notice and appeal. For a country of India’s size, the better path is the one that makes intensive revision rarer: a reliable civil registry feeding the roll all year round.

Notes and References

1. “Lok Sabha elections 2024: 97 crore registered to vote, 2 crore young electors added, says EC”, Business Today, 9 February 2024, https://www.businesstoday.in/amp/india/story/lok-sabha-elections-2024-97-crore-registered-to-vote-2-crore-young-electors-added-says-ec-416904-2024-02-09

2. “KPU: Daftar Pemilih Tetap Pemilu 2024 Capai 204,8 Juta Orang”, DDTCNews, July 2023 (determination at the national plenary of 2 July 2023), https://news.ddtc.co.id/berita/nasional/1795475/kpu-daftar-pemilih-tetap-pemilu-2024-capai-2048-juta-orang

3. “Laksanakan Coklit Data Pemilih, KPU: Ini Tunjukkan Pemilu Tetap Berjalan”, Sekretariat Kabinet RI, 14 March 2023, https://setkab.go.id/laksanakan-coklit-data-pemilih-kpu-ini-tunjukkan-pemilu-tetap-berjalan/

4. “Kunci Penyelamat Daulat Rakyat” (on Law No. 7 of 2017, Article 348(8), Article 210(1) and Constitutional Court decision no. 20/PUU-XVII/2019), Detik News column, https://news.detik.com/kolom/d-4501122/kunci-penyelamat-daulat-rakyat

5. Association for Democratic Reforms v. Election Commission of India, W.P.(C) No. 640 of 2025 and connected matters, judgment of 27 May 2026, 2026 INSC 564, Supreme Court of India (paragraphs up to 108 read directly), https://api.sci.gov.in/supremecourt/2025/35785/35785_2025_1_1501_71617_Judgement_27-May-2026.pdf

6. “Revision of Electoral Rolls in Bihar”, judgment summary, Supreme Court Observer, 2026, https://www.scobserver.in/reports/challenge-to-the-ecis-revision-of-electoral-rolls-in-bihar-judgement-summary/

7. “The Registration of Births and Deaths (Amendment) Bill, 2023”, PRS Legislative Research, https://prsindia.org/billtrack/the-registration-of-births-and-deaths-amendment-bill-2023

Frequently asked questions

How big is Indonesia’s voter list compared with India’s?
Indonesia’s permanent voter list for 2024 was 204,807,222 voters, while India had over 96.88 crore registered electors in February 2024, nearly five times as many.

How does Indonesia build its voter list?
It starts from the civil registry, synchronising population data with the existing permanent list, and field officers then check entries on the ground in a process called coklit.

What fallback does Indonesia give a voter who is missed?
A holder of the electronic ID card who is on neither list can vote with that card under Article 348(8) of Law No. 7 of 2017, as the Constitutional Court read it in decision 20/PUU-XVII/2019.

What does the article suggest India should do?
Complete and link the births and deaths database so that the roll is fed from civil records, keep notice, hearing and appeal, and consider a narrow verified fallback only when the registry is strong enough.

Further reading from AFPR: Counting the Counters: SIR Across the States, Phase by Phase

Further reading

Pay by UPI

UPI QR code for Adhyayan Foundation, payable with any UPI appSave QR to your phone
  1. Scan with Google Pay, PhonePe, Paytm, BHIM or your bank's UPI app. On a phone, save the code and use Scan from gallery, or pay to the UPI ID below.
  2. Pay to Adhyayan Foundation and add in the note.
  3. Confirm here with the UPI reference (UTR) shown in your app after payment.

UPI ID

Payments are received by Razorpay on behalf of the Adhyayan Foundation for Policy and Research. Questions: afpr.office@gmail.com