Political Funding In India: In The Light Of Electoral Trusts Scheme And Electoral Bond Scheme

Alice Kumar

India is considered as world’s largest democracy with its constitution, elections, political parties playing an essential and integral role in nation building. The legal statutes and regulations related to corporate funding in India have witnessed massive evolution right after its independence and especially since 2013.[2] Sadly, the political funding has always been a non-transparent affair in India, owing to the fact the nature of business houses to appease the political parties by granting funds in order to gain government approvals for their smooth functioning. This has led to establishment of a collaborative relationship since the political parties require this funding for their party affairs and to cover their election expenses.[3] In order to bring transparency, the various governments tried to curtail the opacity behind the funding process by formulating legitimate schemes (through banking channels) coupled with appropriate rewards (tax exemptions) to curb and tackle the problem of black money and parallel economy.

Malpractice in political funding started simultaneously with advent of freedom of movement. It started taking its pace towards election practices during the post-independence era.[4] The corporate giants aim to grab leverage in shaping of the government’s economic policies by funding the vendettas of political parties.[5] The leading parties were the most prominent beneficiaries of political funding and received around 34% of the total corporate contributions between 1962 and 1968 from the conglomerates and business houses.[6]

In 1969, the then Government imposed a blanket ban on corporate funding by deletion of § 293A of Companies Act1956;[7] [hereinafter referred as “the Act, 1956”] which envisioned the corporate funding to break the nexus between the businesses with the politics.[8] This made the political parties to resort to fund raising through souvenir publishing which were placed in the business houses itself depleting the very purpose of the ban.[9] This gave birth to the ‘Briefcase Period’ when huge amount of black money used to get transferred to various political parties’ accounts.[10] Further, the political compulsion, threat of selective raids and nationalisation, paved way for black market operations and other illegal mechanisms.

To curb this problem, the government in 1985 adopted a forward looking policy and lifted the ban from corporate funding to political parties.[11] Afterwards in 2013, political funding took a major turn due to the two major changes: firstly, an amendment to § 179 of the Companies Act, 2013 [hereinafter referred as “the Act, 2013”] to raise the funding limit from 5% to 7.5% of the net average profits earned in the preceding three years; and secondly, the coming up of the ‘Electoral Trusts Scheme’ [hereinafter referred as “ET Scheme”] Though the scheme can be traced back to 1996 started by the Tata Group, it received a legal sanction in as late as 2013 only.[12] In 2017 the government came up with a new scheme for political funding which is known as the Electoral Bonds Scheme [hereinafter referred as “EB Scheme”] implemented through the Finance Bill, 2017.

Underlying this article, the author has analysed the evolution of political funding in India especially by the corporate conglomerates. Part 1 of the article provides the background of how political funding has been after the independence of the country. Part 2 consists of the legal provisions and some amendments suggested by the Law Commission of India. Part 3 deals with the corporate funding from Indian as well as from the foreign sources. Part 4 consists of the schemes that various governments have enacted for political funding in India. This consists of the scrutiny of the two major schemes; the Electoral Bonds Scheme and the Electoral trusts Scheme. Part 5 has been dedicated to analyse that whether political Funding can be brought within the ambit of the Right to Information Act. In Part 6 and part 7, the author has provided the conclusion to the article and her comments respectively.

Why a Need arose to Reform the current Legal Provision?

Every government has attempted to enhance transparency in the funding process to political parties to fight the evils of corruption and black economy coupled with immense tax evasion. However, this battle is far from being won since the present legal system as well provides the scope for black money and tac evasions. Let’s try to understand the same in light of the contributions made to the political parties and the 255th Law Commission Report [hereinafter referred as “the LCR”].

Contributions to political parties

There are no limits placed on acceptance of donations by political parties,[13] unless it’s not a government company or a company which has been in existence for less than three financial years.[14] The disclosure of funds by the political parties is essential since non-transparent donations provides immense scope for money influence which soils the purity of elections.[15] Every political party has to prepare an annual report consisting of all the donations received which exceeds Rs. 20,000 and submit the same to the ECI,[16] which is essential to seek tax exemptions.[17] Any contributions made to political parties or electoral trusts,[18] and via electoral bonds,[19] are exempted from income tax. Further, the companies are also requiring to disclose the political donations in their profit and loss account including total amount so contributed and the name of the party.[20] Further, under Electoral Trust Scheme the electoral trust is required to disclose all the contributions received in its account books and maintain records for the same.[21]

Finally, every elected candidate in the parliamentary constituency has to furnish information of its assets and liabilities to the speaker of Lok Sabha/ Rajya Sabha within 90 days of taking oath for their parliament seat.[22] In United Kingdom, there are no caps on individual or corporate funding,[23] however donations above £200 can be received only from permissible donors (including a UK registered; individual on an electoral register; political party; company; a trade union; building society; limited liability partnership; friendly/building society; or unincorporated association).[24] Further, foreign donors are banned however, corporations with partial government ownership or government contracts from donating are not restricted.[25] Furthermore, all anonymous donations under £500 in PPERA,[26] and £50 under RPA, 1983 are prohibited.[27]

255th Law Commission Report: The need for reforms

The money power has been violating the purity of elections and disturbing the level playing field in elections.[28] This is because money power plays an essential role while contesting elections in India. The 255th Law Commission Report provides for several reasons why financial electoral reforms are need of the hour for Indian electoral arena. Firstly, an electoral advantage is sort with financial superiority thus providing greater chances of victory for richer candidates and parties, which ordinarily tend to increase votes of a candidate.[29] Further, this raises the concerns with respect to equality and the equal footing between the richer and poorer candidates.[30] Secondly, the black money, lobbying, bribery, and quid pro quo corruption is prevalent which violates various laws and ECI notifications.[31] Finally, the election finance reform idea is more philosophical in nature than legal which amounts to institutional corruption.[32]

An Analysis of Corporate Funding 
Funding from Indian Sources

The Companies Act, 1913 was passed when India was under the British rule. The act did not consist of any provisions which ban the corporate donations to political parties and thus the courts has to allow them.[33] However, the judiciary warned the parliament about the inherent danger of permitting corporate funding to political parties since it may even throttle democracy in India.[34] The dangers are manifold since it will lead to greed of political favouritism by providing bait by way of contributions with the highest bidder gaining unfair advantage over its rival trader companies.[35] However, parliament ignored this by allowing corporate funding under Companies Act, 1956 [“the Act, 1956”] by inserting Section 293A.

Section 293A of the Act, 1956 provides that a company (excluding a government company and a company which has been in existence for less than three financial years) may contribute any amount not exceeding 5% of its average net profits during three previous financial years.[36] Such contributions has to be made only after a resolution passed in the meeting of board of directors and there has to be a legal justification for making and accepting it.[37] Further, if any donation, subscription, payment or any advertisement made directly or indirectly by or on behalf of any political parties which is likely to affect its support shall be deemed to be political contribution.[38] These contributions has to be disclosed in the profit and loss account of the of the company including the total amount and the name of the party or person to whom it is made.[39]

Similar provisions were also included in the Companies Act, 2013 [“the Act, 2013”]. Rule 8 of the corresponding rules to Section 179 of the Act, 2013 provides that in addition to the powers specified in Section 179, the board has a power to make political contributions by passing a resolution, which is deemed to have justification in for making such contribution.[40] This contribution has to be recorded in the profit and loss account of the company,[41] Thus, there cannot be any shareholder scrutiny over it, thus the maximum scrutiny can take place while auditing the financial statement to ensure the contributions are legitimate ones. The legislature had an intention to include shareholders, consent before making any political contribution which was removed from the act.[42] In United Kingdom, the corporate funding has to be prior approved by the shareholders before making it,[43] which is absent under Indian Companies Act, 2013.

These contributions made directly or indirectly does not fall under the ambit of Corporate Social Responsibility on the companies.[44] Further, the Act, 2013 increased the contribution bar from 5% to 7.5%.[45] However, the Finance Act, 2017 removed the requirement of acceptance and the minimum bar on the contributions.[46] Furthermore, the payment cane be only made through an account payee cheque or draft drawn on a bank or use of electronic clearing system through a bank account or any instrument pursuant to may scheme notified under any law for contribution to the political parties.[47] The scheme referred to in this section is the Electoral Bonds Scheme. For ensuring the compliance with this provision, the penalty was increased from 3 times to 5 times of the total amount contributed as compared to the Act, 1956.[48] This penalty has been reduced in terms of imprisonment for officer in default from 3 years to 6 months.[49]

Funding from Foreign Sources

The Finance Bill, 2018 has amended the definition of foreign company under Section 2 of the Foreign Contributions (Regulations) Act, 2010 [“FCRA”] which provides that a company in which foreign entity who have business in India whose holdings do not exceed 50% of the of the company’s ownership capital shall not amount to a funding from a foreign source. Thus, such companies can now donate under Section 182 of the Act, 2013. Further, there is a lacuna with respect to funding through their subsidiaries and thus foreign companies can now use their subsidiaries even without majority stake to contribute to the political parties.[50]

However, despite of various statutes governing the political funding, there were still grey areas and loopholes. Thus, different governments attempted to remove these loopholes by enacting several schemes with common objective to hamper corruption involved in the process.

Schemes on Political Funding
Electoral Trusts Scheme

The ‘Electoral Trusts Scheme’ was passed on January 31, 2013 with a view to bring transparency in the process of political funding. Since even the private firms were brought into tits ambit, for the first time they can donate money to political parties without any restrictions in exchange of disclosing the amount.[51]

Key Features of the Scheme

The Electoral Trusts Scheme lays a procedure to make voluntary contributions and distribution of the same to political parties via electoral trusts.[52] The companies registered under Section 25 (now section 8, the Act, 2013),[53] are eligible to form an electoral trust. They have to include electoral trusts in their name, shall have a permanent account number and shall distribute the contributions received by it to political parties registered under section 29C of the RPA.[54] Their aim should not be to earn profits and shall make appropriate arrangements for recording the receipts from the contributors in accordance with rule 17CA[55] The contributions can be made by an individual who is citizen of India, a company registered in India or an HUF, Association of Persons or Body of Individuals resident in India.[56]

Further, the trust shall issue receipts including; name and address of the contributor, Permanent Account Number [“PAN”] of the citizen and Passport Number who is a non – resident citizen, amount and mode of contribution including name and branch of bank and date of receipt, name and PAN of trust and name and designation of the person issuing such receipt.[57] A trust shall not accept contributions from non-citizen and foreign entities irrespective of its incorporation and from another electoral trusts.[58] The payments can be made only via account payee cheque or draft from authorised bank, or by electronic transfer to its bank account and not by cash.[59] Further the trusts shall maintain list of persons who made contributions and books of account and other documents of its receipts and expenditure and get it audited by an authorised accountant.[60] These records have to be certified by Commissioner or Director of Income Tax along with audit report.[61]

Electoral Bonds Scheme

During 2017-18 Union Budget Speech, former Finance Minister Mr. Arun Jaitley introduced the scheme of poll financing called the ‘Electoral Bonds Scheme’ in order to achieve ‘Transparency in Electoral Funding’.[62] It provides that the political parties registered with the Election Commission of India [“ECI”] are exempted from paying income income-tax on the political donations made under this scheme via electoral bonds.[63]

Key Features of the Scheme

The scheme provides for electoral funding via electoral bonds. Sub-section (a) of §2 of the scheme defines electoral bond as a bond which is a bearer banking instrument in the nature of a promissory note not carrying the name of the buyer or payee.[64] The bond can be purchased by a person either singly or jointly by a citizen of India or incorporated in India with other individuals.[65] A person includes an individual, Hindu Undivided Family, a company, a firm, association of persons or body of individuals whether incorporated or not, every artificial juridical person not falling in other categories or any agency, office or branch owned or controlled by any such person.[66]

Further, the donations can only be made to the registered political parties (registered under § 29A of the Representation of the People Act, 1951 [“RPA”]) and secured at least 1% of the votes polled in the Lok Sabha or Legislative Assembly through a bank account with the authorised bank.[67] The Know Your Customer [“KYC”] norms of the Reserve Bank of India [“RBI”] will be applicable to the scheme and empowers the authorised bank to call for additional information.[68] Furthermore, the denominations of the bonds include Rs. 1,000, 10,000, 1,00,000, 10,00,000 and 1,00,00,000 which are valid for 15 days from the from the date of issuance,[69] or shall be deposited to the Prime Minister Relief Fund.[70]

These bonds can be issued for first ten days of January, April, July, October and for additional 30 days in the year of general elections as specified by the Central Government.[71] The bonds are non-tradable,[72] and no interest, commission, brokerage or any other charges is payable by the purchaser.[73] A desirous buyer can purchase the bonds in physically from specified 29 branches of State Bank of India (in New Delhi, Gandhinagar, Chandigarh, Bengaluru, Bhopal, Mumbai, Jaipur, Lucknow, Chennai, Kolkata and Guwahati) or through online application accompanied with specified documents (Annexure II) which is non-refundable in nature.

Judicial Analysis

The question for constitutionality of the Electoral Bonds Scheme was challenged in Association for Democratic Reforms and Anr.,[74] case where the Supreme Court passed an interim order owing to soon reaching elections in 2019. The court ordered that all the political parties who have received donations through Electoral Bonds are required to submit the detailed particulars of the donors against each bond including the amount, the bank name and the date of credit.[75]

The views of the ECI are relevant to note here which was filed via an affidavit.[76] Firstly, the donations received through an electoral bond has been taken out of the ambit of the Contribution Report prescribed under Section 29C of the RPA, making it difficult to determine its violation (donations from government and foreign sources).[77] Secondly, the removal of limit on the donations (7.5% of the net annual profit) by companies opens a path for donations by shell companies.[78] Thirdly, earlier where the companies had to declare their political donations in their profit and loss account is now reduced to mentioning of the total amount under this head.[79] However, the concerns of Ministry of Finance, Department of Economic Affairs is concerned about the hidden identity of the donor since this will affect citizens’ right to know about the contributions and its source.[80] Further, the removal of caps on election contributions was challenged as it will open foreign contribution avenues.[81] This hamper the transparency with respect to political funding in great respect.[82]

Thus, the Supreme Court has clearly not addressed the issues raised by ADR, the ECI or the Ministry of Finance and has justify the claim by providing that it tried to ensure a balance between political parties and the adequate safeguards against the competing claims which are still pending.[83]

Right to Information over Political Contribution

The way in which political parties collect funds has led to high levels of corruption and thus they should be regulated by strict principles in relation to collection of funds.[84] Though political parties need large funds for the purpose of elections however, this should come openly from the supporters.[85] “The little man may think over before making his choice of electing law breakers as law makers.”[86] The voters exercise their right to expression by casting votes and thus some essential details about the contesting candidates should be made available to them including the assets possessed by them and their relatives including bank balance details.[87]

Further, the political parties are public authorities since they enjoy complete and unfettered tax exemption under IT Act, since electoral trusts funds political parties which uses public funds and work in public domain.[88] They should give information in the larger public interest since this information has to be anyways be submitted to the ECI by electoral trusts..[89] this information does not amount to ‘personal information’ under Section 8, Right to Information Act since it applies to individuals and not entities working for public good.[90]

Further, the electoral trusts are required to report and work in a transparent manner and maintain list of donors and audited financial which does not include either Intellectual Property or trade secret as this is not a trade.[91] Thus, the details of the donors of the electoral trusts should also be disclosed moreover, this information is already with public authority.[92]

Conclusion and Suggestions

The article has analysed the evolution of political funding in India through various statutes, case laws and schemes. Moving onto to the Act, 2013 provides that corporate funding to political parties can be done by a resolution passed by the board of directors. This has been criticised since only a handful of people can decide as to how to utilise the company’s capital while ignoring a huge chunk of shareholders who are the true owners of the company. Thus, it becomes essential to add shareholders scrutiny over this matter and such decisions should be passed by the shareholders as well in an annual general meeting which was also the intention of the legislature as can be seen by the 21st standing committee report on the Companies Bill, 2009. We need similar kind of provisions in the Indian Companies Act which is present under the UK’s statute governing corporate houses. Further, the act is silent upon the regulation of such donations. Ideally, SEBI should be the sole regulator for auditing such donations.

Further, the Electoral Bonds Scheme has been criticised that the electoral bonds do not have the names of the donor. However, the author believes that this is essential to break the quid pro quo relationship between the corporates and the political parties. It works in the same manner as the voting system in which the name of the voter is not revealed to the anyone. Moreover, the SBI branches should be directed to provide the details of the purchaser of electoral bonds to the SEBI, ECI and Income Tax Department to ensure that no malpractices take place by way of political donations.

Further, the scheme consists of only political parties and is silent on the application of the scheme on independent political candidates. Furthermore, the main aim of donations is that it should benefit the neediest population. However, the scheme provides that the donations via electoral bonds can be made only to those parties who have secured at least 1% of votes polled in the Lok Sabha or Legislative Assembly. Thus, this benchmark sort to defeat the very purpose of donations since it is arbitrary in nature.

As this issue is again in the limelight for the petition filed before the Supreme Court in 2018, the Apex Court’s stance on this issue will be a game changer.

Photo Credits: The Quint

About The Author

Alice is currently a final year student, pursuing B.A. LL.B. Business Law Honours from National Law University Jodhpur. Her interests lie in Corporate Law and Constitutional Law.  

  1. This article is authored by Ms. Alice, pursuing B.A.LL.B. (Business Law Hons.) at National Law University, Jodhpur. 

  2. Sahoo & Tiwari, Financing elections in India: A scrutiny of corporate donation, (Apr. 04, 2019), https://www.orfonline.org/expert-speak/financing-elections-india-scrutiny-corporate-donation-49750/ [hereinafter Sahoo & Tiwari]. 

  3. Anuja & Prasad, Electoral bonds boon or bane for India’s political funding system? (Dec. 04, 2019), https://www.livemint.com/politics/policy/electoral-bonds-boon-or-bane-for-india-s-political-funding-system-11575424422379.html [hereinafter Anuja]. 

  4. Id. 

  5. Samya Chatterji & Niranjan Sahoo, Corporate Funding of Elections: Strengths and Flaws, Observer Research Foundation issue brief #69 (Feb., 2014) [hereinafter Chatterji]. 

  6. V. Venkatesan, Chequered Relations, Frontline, http://www.frontline.in/navigation/?type=static&page=flon

    net&rdurl=fl1616/16160100.htm, (last visited on Mar. 14, 2013) [hereinafter Venkatesan]. 

  7. Companies Act, 1956, § 293A, Act No. 1 of 1956 (India) [hereinafter Companies Act, 1956]. 

  8. Venkatesan, supra note 5. 

  9. Sahoo & Tiwari, supra note 1. 

  10. Id. 

  11. Chatterjee, supra note 3. 

  12. Sahoo & Tiwari, supra note 1. 

  13. The Representation of the People Act, 1951, § 29B, Act No. 43 of 1951 (India) [hereinafter RPA, 1951]. 

  14. The Companies Act 2013, § 182, Act No. 18 of 2013 (India) [hereinafter Companies Act, 2013]. 

  15. Gajanan Krishnaji Bapat v. Dattaji Raghobaji Meghe, (1995) 5 SCC 347. 

  16. RPA, supra note 12, § 29C. 

  17. RPA, supra note 12, § 29C (4); The Income Tax Act, 1961, § 13A, Act. No. 46 of 1961 (India) [hereinafter ITA]. 

  18. ITA, supra note 16, § 80 GGB. 

  19. Electoral Bond Scheme, 2018, Clause 13, Gazette Notification No. 20 (Jan. 2, 2018) (India) [hereinafter EBS, 2018]. 

  20. Companies Act, 2013, supra note 13, § 182 (3). 

  21. Income -Tax (First Amendment) Rules, 2013, Clauses 2 (11), (12), Notification No. 8/2013, F. No. 142/20/2012-TPL (Jan. 31, 2013). 

  22. RPA, supra note 12, § 75A. 

  23. Political Parties, Elections and Referendums Act, 2000, § 54 (2)(b), 2000 Chapter 41 (Nov. 30, 2000) (United Kingdom) [hereinafter PPERA]; The Representation of the People Act, 1983, Schedule 2A, 1983 Chapter 2 (Feb. 8, 1983) (United Kingdom) [hereinafter RPA, 1983]. 

  24. PPERA, supra note 22, § 54. 

  25. Law Commission of India, Electoral Reforms, ¶ 2.24,6, Report No.255, D.O. No.6(3)/240/2013-LC(LS), (Mar. 12, 2015) [hereinafter LCR No. 255]. 

  26. PPERA, supra note 22, § 52(2. 

  27. RPA, supra note 12, Schedule 2A. 

  28. LCR No. 255, supra note 24, ¶¶ 2.4-2.18. 

  29. Kanwar Lal Gupta v. Amar Nath Chawla, (1975) 3 SCC 646; Ashok Shankarrao Chavan v. Madhavrao Kinhalkar, (2014) 7 SCC 99. 

  30. Id. 

  31. PUCL v. Union of India, (2003) 4 SCC 399. 

  32. Lawrence Lessig, Republic Lost 16, 107-114 (2011). 

  33. Rajindar Sachar, Clean Politics Demands No Corporate Funding to Political Parties, Vol XLVII No. (19, Apr.25, 2009), https://www.mainstreamweekly.net/article1322.html. 

  34. Jayantilal Ranchchoddas Koticha v. Tata Iron & Steel Co. Ltd., ¶ 18, 1957 27 CompCas 604 Bom. 

  35. Iron and Steel Co. Ltd., In re [1957] 27 CompCas 361, 364 Cal. 

  36. Companies Act, 1956, supra note 6, §§ 293A (1), (2). 

  37. Id. 

  38. Companies Act, 1956, supra note 6, § 293A (3). 

  39. Companies Act, 1956, supra note 6, § 293A (4). 

  40. Companies Act, 2013, supra note 13, Rule 8, § 179. 

  41. Companies Act, 2013, supra note 13, §182 (3). 

  42. Ministry of Corporate Affairs, The Companies Bill, 2009, 21st Report, Standing Committee on Finance, (2009-2010) (Aug. 31, 2010) (India). 

  43. Chatterji, supra note 3. 

  44. The Companies (Corporate Social Responsibility) Rules, 2014, Rule 4 (7), REGD. NO. D. L.-33004/99 (Feb. 27, 2014) (India). 

  45. Companies Act, 2013, supra note 13, § 182 (1). 

  46. Id. at proviso to § 182 (1). 

  47. Id. at § 182 (3A). 

  48. Id. at § 182 (4). 

  49. Id. 

  50. Mohammed Kudrati, Foreign Funding for Political Parties: All You Need to Know, BoomLive, (Mar. 26, 2019), https://www.boomlive.in/foreign-funding-for-political-parties-all-you-need-too-know/. 

  51. Electoral Trust Scheme and Basics About Electoral Trusts in India, GK Today, (Mar. 26, 2016), https://www.gktoday.in/gk/electoral-trust-scheme-and-basics-about-electoral-trusts-in-india/ 

  52. The Electoral Trusts Scheme, 2013, Clause 2, Income Tax Notification No-09/2013, (Jan. 31, 2013) (India) [hereinafter ETS, 2013]. 

  53. Companies Act, 1956, supra note 6, § 25. 

  54. ETS, 2013, supra note 52, Clause 4. 

  55. Id. at clause 6. 

  56. Income -Tax (First Amendment) Rules, 2013, Clause 2 (2), Notification No. 8/2013, F. No. 142/20/2012-TPL, (Jan. 31, 2013) [hereinafter IT First Amendment]. 

  57. Id. at clause 2 (3). 

  58. Id. at clause 2 (4). 

  59. Id. at clause 2 (5). 

  60. Id. at clauses 2 (11), (12). 

  61. Id. at clause 2 (14). 

  62. Anuja, supra note 2. 

  63. Finance Bill, 2017, Clause 11, Part F, Act No. 7 of 2017 (India). 

  64. EBS, 2018, supra note 18, Clause 2(a). 

  65. Id. at clauses 3 (1), (2). 

  66. Id. at clause 2(d). 

  67. Id. at clauses 3 (3), (4). 

  68. Id. at clause 4. 

  69. Id. at clauses 5, 6. 

  70. Id. at clause 12 (2). 

  71. Id. at clause 8. 

  72. Id. at clause 14. 

  73. Id. at clauses 9, 19. 

  74. Association for Democratic Reforms and Anr. v. Union of India and Ors., WP (Civil) No. 333 of 2015 [hereinafter ADR v UoI]. 

  75. Id. ¶ 13. 

  76. Association for Democratic Reforms and Anr. v. Union of India and Ors., WP (Civil) No.880 of 2017 (Counter Affidavit on Behalf of ECI Respondent 03). 

  77. Id. ¶¶ 7.2, 7.3. 

  78. ADR v. UoI, supra note 74, ¶ 7. 

  79. Id. 

  80. Id. ¶ 4. 

  81. Id. 

  82. Id. ¶

  83. Id. ¶ 12. 

  84. Dr. P. Nalla Thampy Tetah v. Union of India and Ors., 1985 Suppl. SCC 189. 

  85. Id. 

  86. Union of India and Ors. v. Association for Democratic Reforms and Ors., ¶ 54, AIR 2002 SC 2112. 

  87. Id. ¶ 55. 

  88. Anil Bairwala v. Parliament of India, CIC, CIC/SM/C/001386. 

  89. The Election Commission of India, Vide Letter No..56/Electoral Trust/2014/PPEMS, June 06, 2014. 

  90. Naresh Trehan v. Rakesh Kumar Gupta and Ors., (2015) 216 DLT 156. 

  91. Neeti Biyani v. ITO, ¶19, MANU/CI/0475/2016. 

  92. Id. ¶21. 

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