In India, the post of Election Commission and Chief Election Commissioner is in the news these days. Serious allegations are being made by the opposition regarding Chief Election Commissioner Gyanesh Kumar and the matter has also reached the Supreme Court regarding his functioning and Special Intensive Review (SIR). On October 5, the Supreme Court refused to give an interim order on the demand to suspend Gyanesh Kumar, but sought answers from the Election Commission and the Centre. Amidst this debate, it is interesting to understand to what extent the electoral structure like India is found in other big democracies of the world.
In fact, every country has created a different institutional model for conducting elections. Somewhere there is an independent National Commission, somewhere the role of the judiciary is important and in some countries the electoral responsibility is divided between the Centre, State and local administration. Therefore, it is not necessary for a post like 'Chief Election Commissioner' to exist in every democracy.
Election responsibility decentralized in America
The US does not have a National Chief Election Commissioner to conduct elections for the entire country like India does. The administration of elections there takes place mainly at the level of states and local bodies. Election related responsibilities may be with different officials in different states. The Federal Election Commission mainly monitors the rules related to election finance and political campaigns. Therefore, in the American system, it would not be right to call any one person the election chief of the entire country.
In Britain the Commission and local authorities play different roles
In the United Kingdom the Electoral Commission oversees matters relating to electoral rules, political parties and electoral finance. But voting is conducted through local level officials. Returning Officer plays an important role in every constituency. For this reason, Britain does not have a single national election leader like India's CEC.
Model of Federal Returning Officer in Germany
In Germany, the post of Federal Returning Officer (Bundeswahlleiter) exists for federal elections. This officer plays important responsibilities in election preparation, administrative coordination and federal level electoral process. However, separate election officials also work at the state and local levels. Therefore the German model is different from the Central Election Commission of India.
Administration and the role of the Constitutional Council in France
Elections in France are administered primarily through the Ministry of the Interior and local administration. At the same time, the Constitutional Council plays a role in monitoring and settling disputes on some important electoral matters, including presidential elections and referendums. There is no independent National Election Commission and CEC structure like India.
Local election commission is important in Japan
Local Election Management Committees play an important role in Japan's electoral system. A large part of voting and election administration is conducted through these institutions. At the national level also, election administration is in place, but unlike in India, there is no post of a Chief Election Commissioner at the helm of the entire election system.
Unique combination of elections and judiciary in Brazil
Brazil's model is quite different from other countries. There the Superior Electoral Court is the central institution of the electoral system. It plays an important role in election administration as well as in matters related to election disputes and rules. It is chaired by a person associated with the judiciary, so it cannot be considered a direct parallel to India's CEC.
Independent Commission in Indonesia and South Africa
In Indonesia, General Elections Commission i.e. KPU is the main national body that conducts elections. It consists of several members and a Chairman leads the Commission. The Independent Electoral Commission in South Africa independently administers elections and its chairperson plays a key role in the leadership of the institution. Both countries appear to have a model of independent national electoral institution like India, but the constitutional rights and structure of posts are different.
National and regional systems in Australia
The Australian Electoral Commission administers federal elections in Australia. Within it there are posts like Chairman and Electoral Commissioner. States and territories also have their own electoral bodies. Therefore, election administration there is run through an institutional structure rather than an individual.
Why is the role of CEC different in India?
The Election Commission of India is a constitutional body that administers elections to the Lok Sabha, state assemblies and the President and Vice President. The Commission consists of the Chief Election Commissioner and other Election Commissioners. Gyanesh Kumar took over as the 26th CEC of India on 19 February 2025. The current controversy has certainly raised the question as to how collective the decision process should be in such a large electoral system. But examples from around the world show that democracies have not adopted a uniform model for election management. Somewhere there is an independent commission at the centre, somewhere the judiciary is involved and somewhere local bodies handle a major part of the elections. This difference makes India's CEC system the most important point to understand in global comparison.