Returning Officer / Assistant Returning Officer — Counting Handbook

Rajasthan ULB General Election 2026 · Member (ward) posts · Counting 14 September 2026

Every instruction is sourced. Tags — [2292 ¶18(1)], [SO 157 ¶7(ग)], [MPSV Ch.6] — are explained in SOURCES. Procedures not found in an official document are not written here; see GAPS.

⚠️ At one point two official documents conflict (packeting of postal ballots) — see §9.7. Rule adopted: the later document prevails ([2292 ¶11(5)] — one packet). This is a departmental working decision, not an SEC ruling — for the detail and the caveat see GAPS §2.

🔗 Every citation tag is clickable in CITATIONS — it opens the source PDF at the exact page.

✅ Updated 23.08.2026 — this is no longer a departmental call. The original text of rule 74-A(1)(b) — "used postal ballot papers weather valid, rejected or cancelled, and counter-foils thereof" — puts valid and rejected into a single packet category, which fits [2292 ¶11(5)] exactly. Full reasoning → §9.7-A of the RO/ARO handbook.

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1. Legal basis

Counting where voting machines are used is governed by the Rajasthan Municipalities (Election) Rules, 1994 — Chapter 3, Rules 57 to 61 and 65 to 73, and for EVM counting Chapter 3-क, Rules 46-क, 62-क, 63-ख and 64-क [2292 ¶2(1)].

• Rules 62-क, 63-क and 63-ख provide for scrutiny and inspection of voting machines before counting, the actual counting of votes recorded in them, and sealing of machines after counting [2292 ¶2(2)].
• The provisions of Rules 57 to 61 and 65 to 73 — time and place of counting, appointment of counting agents and revocation of such appointments, entry to the place fixed for counting, secrecy of voting, continuous counting, recommencement of counting after a re-poll, recounting, declaration of result, and issue of the certificate of election — apply in the same manner as they apply to counting in elections conducted with ballot papers and ballot boxes [2292 ¶2(2)].

This circular supersedes the earlier order 4249 dated 22.10.2019 [2292, opening para].

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2. Two things to grasp first

(a) Counting is done polling-station-wise (booth-wise). Counting must be error-free and must leave no confusion in the mind of a candidate or their agent about the result [2292 ¶1(2)].

(b) Counting must be completed the same day. After counting and declaration of results, administer the oath to the elected members the same day, so that members can take part in the election of the Mayor / Sabhapati / Adhyaksh [2292, closing note].

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3. Date, place and time [2292 ¶3]

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4. Counting tables [2292 ¶4]

1. Decide in advance how many counting tables at each counting place — this determines how many counting supervisors and counting assistants you must appoint, and how many counting agents each candidate is entitled to appoint. The number of tables is determined by the number of wards and the number of polling stations in the ward, so that counting can proceed at the same time.
2. In large wards with more than one table in a room, number the tables serially. Leave adequate space between tables for counting supervisors, counting assistants and candidates/counting agents to sit.
3. More than one ward may be counted in one room, but counting of another ward shall begin only after the counting of one ward is complete. While a ward is being counted, only that ward's candidates/agents may remain in the room; the rest are asked to wait in a designated room within the counting centre building [¶4(3), ¶6(10)].

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5. Counting staff [2292 ¶5]

1. Under Rule 59 the RO appoints counting supervisors and counting assistants with the approval of the District Municipal Election Officer. One counting supervisor and one counting assistant per table.
2. Counting supervisors — gazetted or equivalent officers, who may also come from State Government departments or from corporations, boards and institutions subordinate to the State Government. Counting assistants — need not be gazetted, but as far as possible at the level of employees working on Supervisory Posts. 🚫 Persons connected with any political party or candidate, and staff of urban body offices, shall NOT be appointed as counting supervisor or counting assistant. They must be impartial and dutiful. Counting supervisors and assistants — including reserve staff — must be thoroughly trained.
3. The RO shall also appoint assistants, with the DEO's approval, for sealing the EVM / SDMM / DMM (where MPSV and MPMV machines were used) and other election-related papers.

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6. Counting agents [2292 ¶6], [SO 151]

6.1 Number and appointment

• Under Rule 58 a candidate or their election agent may appoint counting agents.
• The number of counting agents shall not exceed the number of tables set up for counting — including the RO/ARO's table [2292 ¶6(1)].
• Appointment is in Form-19, in duplicate. One copy goes to the RO; the second copy is presented by the counting agent before the RO at least one hour before counting begins.
• A candidate may appoint more than one agent in one letter in Form-19.
• 🚨 The signatures of the persons appointed are necessary as consent. Without such signature the appointment is not valid [2292 ¶6(1)].

6.2 Declaration and revocation

• At least one hour before counting begins, the counting agent shall read the declaration in Form-19, sign it and present it to the RO — otherwise entry to the counting centre shall not be given [2292 ¶6(2)].
• Revocation for a ward member is by submitting Form-20 to the RO; after revocation the candidate or election agent may appoint another counting agent in that person's place [2292 ¶6(2)].

6.3 Photo identity card — a condition of entry

• The list of counting agents with their photos shall be obtained by the RO from contesting candidates at least 2 days before the date fixed for counting [SO 151].
• Form-19 (in duplicate) with a passport-size photo affixed must be presented before the RO at least two days before counting day [2292 ¶6(5)].
• On both appointment letters, the counting agent signs on the affixed photo, and the candidate or their election agent certifies those photos [2292 ¶6(5)], [SO 151].
• 🚨 On counting day, only counting agents holding photo identity cards shall be permitted inside the counting hall [SO 151].

6.4 Badges

Entry to the building on counting day is only by photo badge. The badge carries — badge number · name of counting agent · name of candidate · ward number (or chairperson election, as the case may be) · room number · allotted table number. Badges are issued under the RO's signature and seal. All badges issued are also entered in a register maintained for the purpose [2292 ¶6(4)]. Candidates and their election agents are also given photo badges [2292 ¶6(6)].

6.5 Seating and movement

• 🚫 A counting agent may sit only at the table allotted, nowhere else. Only the candidate and their election agent may go to any table [2292 ¶6(9)].
• 🚫 No one may leave the counting room in the middle of counting, and once they leave, re-entry will not be allowed — tell candidates/agents this clearly [2292 ¶6(3)].

6.6 Intimation

The RO shall inform the concerned political parties and candidates of these arrangements sufficiently in advance, telling candidates along with the notice under Rule 57 [2292 ¶6(7)]. At district level the DEO shall also inform the political parties [2292 ¶6(8)].

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6.7 🔴 Forms 19 and 20 ARE held — with their original text (23.08.2026)

✏️ This module said in five places that "only Forms 19 and 20 remain unheld". That was wrong. Both forms are printed in full in the ULB Manual (printed pp. 146–147) and are reproduced verbatim below. No form is now unavailable to this module.

Form 19 — Appointment of Counting Agent [See Rule 58(3)]

The form has THREE tables — all three must be completed. This is where it goes wrong most often.

🔴 The original text of the declaration — this is what the RO administers

"Declaration of counting agents — (To be signed before the Returning Officer)

I/We hereby declare that at the above election I/We will maintain and aid in maintaining, the secrecy of the voting and shall not (except, for some purpose authorised by or under any law) communicate to any person any information calculated to violate such secrecy."

🚨 Two things that were not in the module — (1) §6.2 said the agent "reads and signs the declaration and presents it to the RO". The form goes further — the declaration is signed IN THE RO's PRESENCE and the RO counter-signs it "Signed before me". That is an act the RO must perform, not merely a paper to accept. (2) Table 2 (consent) and Table 3 (declaration) call for separate signatures. An agent who fills Table 2 and leaves Table 3 blank — that is the commonest lapse. Check it at the table.

The original text of rule 58 — what §6.1 did not carry

🔴 The third limb of 58(4) was not in the module — "an authority for entry". Taking the paper is not enough — the RO issues an entry authority. In practice that is the photo badge under [SO 151] (§6.3) — two forms of one requirement, not a conflict.

ℹ️ An internal cross-reference quirk in the rule (recorded as found): 58(4) speaks of the "second copy of his appointment under sub-rule (2)" and 58(6) of a "fresh appointment in accordance with sub-rule (2)" — whereas the duplicate is provided by 58(3) and the appointment by 58(1). This is the rule's own drafting slip; take no action on it. The intention is plain.

Form 20 — Revocation of appointment [See Rule 58(5)]

"I, … a candidate/the election agent of Shri/Shrimati … a candidate at the above election hereby revoke the appointment of Shri/Shrimati … as counting agent." · Date … · Signature of the candidate/election agent

🚨 Forms 19A and 20A stand DELETED — notification F.8(ga) ( ) Rules/DLB/19/33841 dated 16.10.19, Rajasthan Gazette Extraordinary Part 6(A), 16.10.19. If anyone produces a 19A, it is obsolete.

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7. Stationery at each counting table [2292 ¶7]

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8. Discipline, secrecy and entry

8.1 Discipline [2292 ¶8]

🚫 Smoking in the counting room is totally prohibited. Under Rule 60(2), any person who does not obey the RO's lawful directions or misconducts shall be removed from the counting room — for which the help of police officers present outside the room may be taken.

8.2 Secrecy [2292 ¶9]

Under Rule 61, every officer, clerk, agent or person doing any work relating to counting or its records must maintain the secrecy of votes. The provisions of Section 128 of the Representation of the People Act, 1951, which also applies in municipal elections, must be explained to everyone present in the counting room before counting begins.

8.3 Entry — only four categories [2292 ¶10]

Under Rule 60(1) the RO shall admit only 4 categories of persons:

• Police: the RO may call police staff on duty into the room for law and order or a similar purpose. Normally police should not be admitted, because a candidate or party may complain that police have been unnecessarily deployed in the counting room [2292 ¶10(2)].
• 🚫 No Minister of the Government can be appointed as election agent, polling agent or counting agent. Therefore no Minister may be admitted to the counting centre unless they are a candidate [2292 ¶10(3)]

🚨 Section 134A — a government servant may not be a counting agent (added 22.08.2026)

Verbatim (Manual PDF p.45 — I read it myself): "134A. Penalty for Government servants for acting as election agent, polling agent or counting agent.— If any person in the service of the Government acts as an election agent or a polling agent or a counting agent of a candidate at an election, he shall be punishable with imprisonment for a term which may extend to three months, or with fine, or with both."

✅ The applicability chain, verified by me: s.28 of the Municipalities Act 2009 (Manual PDF p.70) lists the RP Act sections it applies, and 134A is in that list — "…132A, 133, 134, 134A, 134B, 135, 135A…". The textual substitutions touch only ss.125, 127, 134 and 136, so 134A applies unmodified.

⚠️ But get the scope exactly right — do not turn this into a power of refusal

The Minister bar [2292 ¶10(3)]	the appointment cannot be made at all; entry may be refused
🚨 Section 134A	the penalty falls on the government servant. The section does not void the appointment, and gives the RO no express power to refuse

➡ So do not simply repeat the Minister sentence for 134A. They are different.

What the RO should do in practice

1. State it expressly in the ¶6(7) notice issued with the Rule-57 notice, so candidates and parties know a government servant cannot be a counting agent.
2. On Form-19 scrutiny (2 days before counting), if such a case appears, warn the candidate or election agent at once and have a replacement counting agent appointed in that person's place.
3. Report the case to the DEO.

The Margdarsika says the same — Chapter 12 "Election irregularities", item 9: a government employee acting as a candidate's election agent, polling agent or counting agent is likewise an offence (s.134A).. - Keep movement of persons smooth in the counting room [2292 ¶10(4)].

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9. Counting of postal ballots [2292 ¶11], [SO 157]

9.1 Order and timing

• 🚨 Postal ballots are counted FIRST. They are taken up first in the same room where EVM counting is being done — but ensure that counting of postal ballots is completed before the EVM counting is complete [2292 ¶11(1)].
• 🚫 No envelope of a postal ballot received after the time fixed for commencement of counting shall be opened. Reject them without opening, keep them separately in an envelope and seal it, and write proper particulars on it [2292 ¶11(2)], [SO 157 ¶1].

9.2 Two kinds of postal ballots [2292 ¶11(3)]

For both, the Commission has issued order 1418 dated 05.02.2026 and order 1451 dated 06.02.2026 (SO 157/2026) [2292 ¶11(3)].

✅ Corrected 23.08.2026 — order 1418 has now been read in full (the Commission's own PDF, all five pages). An earlier version of this line read "Order 1418 was not read for this module." Items (1)–(13) and Annexures 1–4 → §9.4-A and §9.4-B.

9.2-A 🔍 The test of "duly attested" — who may attest (added 22.08.2026)

The flow at §9.3 below says a ballot is rejected where the declaration is "not duly signed and attested" — but it never said who is competent to attest. This is the first substantive decision of 14.09.2026 and the RO's decision is final, so it is set out separately here.

🚨 Two classes of postal voter, two different competent officers — never merge them

🚨 Two things that get missed — (1) For a detained voter the Presiding Officer is not an option — he is not posted on duty at any polling station. (2) The officer in charge of the jail need not be gazetted — order 1418 gives him as an independent alternative. Applying one class's rule to the other will get a valid ballot rejected.

The rule verbatim — rule 46-A(6)(b)

"(b) the voter shall sign the declaration in Form 16A in the presence of any gazetted officer, or of the Presiding Officer of the polling station at which he is posted on duty, and shall get his signature attested by that officer;"

Order 1418 verbatim — item (10)

"…together with that small envelope, the 'Declaration by the Elector', on which his signature has been attested by any gazetted officer or by the officer in charge of the jail, shall be enclosed in the large envelope 'B' and sent to the Returning Officer"

🔎 The practical check at the table

The attestation block of Form 16-A has spaces for the attesting officer's signature, designation, address and date. The RO tests competence from the "designation" box.

🚨 A blank designation box means competence cannot be tested at all. A signature alone is not enough.

What follows if attestation is not in the prescribed manner

Order 1418, item (12)(b) — at counting, under rule 64-A, the RO scrutinises and rejects where "the 'Declaration by the Elector' is not duly signed or attested, or is otherwise defective for any other proper reason".

⚠️ A caution for the chairperson round (21.09.2026)

SO 156 is issued in terms for "elections to member posts". For a chairperson election the same requirement comes from rule 46-A(6)(b) and Forms 16-A / 16-D, both headed "(see rules 46A(4)(a) and 78)". ➡ In the chairperson round cite the rule and the forms, not SO 156 alone.

⚠️ This caution is reasoned, not stated by the Commission. The chairperson election is indirect, and under order 1891 dated 18.02.2026 no postal ballot is printed for the chairperson post at all — so in practice the question should not arise. Confirm with the DEO if in doubt.

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9.3 Order of scrutiny [SO 157 ¶1–6]

Open Envelope-B (Form 16-ग) one by one
        │
        ├─ received after the fixed time → not opened, not counted        [¶1]
        │
        ▼
FIRST scrutinise the declaration in Form 16-क inside it                   [¶2]
        │
        ├─ declaration absent / not duly signed and attested (substantially
        │  defective) / serial number of the ballot differs from that
        │  endorsed on Envelope-A (16-ख)
        │        → 🚫 Envelope-A NOT opened; after proper endorsement,
        │          the ballot inside is REJECTED                          [¶3]
        │        → such Envelope-A + their 16-क declarations go back into
        │          Envelope-B; all such Envelope-B into one separate large
        │          packet, sealed                                          [¶4]
        │
        ▼
All declarations in 16-क found correct → separate packet, sealed          [¶5]
        │
        ▼
ONLY THEN begin opening Envelope-A (Form 16-ख)                            [¶5]
        │
        ▼
Scrutinise each ballot paper; decide the validity of the vote on it       [¶6]

9.4 Grounds on which a postal ballot is rejected [SO 157 ¶7]

🚨 A postal ballot shall not be rejected on any ground other than the above. The RO shall record a clear reason for rejection on each. The RO's decision on validity or rejection is final [SO 157 ¶7].

Explanation I — A postal ballot clearly recorded in favour of any candidate shall not be rejected merely because the mark was made otherwise than with the prescribed instrument. Marking "X" (cross) or "✓" (right tick) with a ballpen or ink is sufficient in the space specified for a candidate [SO 157].

Explanation II — A vote shall not be rejected merely because the mark is indistinct or is made more than once, if the intention that the vote is for a particular candidate or 'NOTA' clearly appears from the way the ballot paper is marked [SO 157].

9.4-A 🚨 Order 1418 has now been read in full — the preventive-detention postal ballot has its own regime

Added 23.08.2026. Only items (10) and (12)(b) of order 1418 were previously taken into this module, from the Compendium. I have now read all five pages of the Commission's own PDF myself — General_ULB_2026/2026-02-05_14180024.pdf, items (1)–(13) and Annexures 1–4.

Basis: the proviso to section 25(5) of the Act 2009 — a person kept in preventive detention has the right to vote. The Rules 1994 prescribe no procedure, so the order issues under rule 97 (removal of difficulties). It supersedes order 4200 dt 21.10.2019.

Four steps before the counting table — for the RO

🔴 The prohibition in item (6) is a secrecy safeguard. If the ballot paper's serial number were written against the voter's name in the marked copy, anyone at the count could work out who voted for whom — which would breach section 128 of the RP Act (secrecy of voting).

Items (11)–(13) — at the counting table

• (11) Only those postal ballots are included in the count that reach the RO by the time fixed for the commencement of counting.
• (13) The RO adds the valid postal votes for each candidate to that candidate's total valid votes.

🚨 Item (12) — the detention ballot's own rejection list — rule 64-A

Do not merge this with the list at §9.4 above — that one is [SO 157 ¶7] and applies to the election-duty postal ballot. Two classes, two lists — exactly as §9.2-क has two classes and two attesting authorities.

✅ The proviso to (d) and Explanation I at §9.4 say the same thing. In both classes a tick or a cross is a valid mark — this is the most frequently mistaken rejection at the counting table. The vote is valid even if the stamp was not used.

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🔴 §9.4-B — An internal discrepancy in Annexure-4 of order 1418 — report it to the DEO

This is not my conclusion; it is a quotation of two printed lines. I read both myself — Annexure-4, Part 1, page 5 of order 1418.

Annexure-4 is the instruction sheet that is sent to the detained voter along with the ballot paper. Two lines are printed in its Part 1, side by side —

Which line governs a municipal member's postal ballot

➡ Three independent sources agree — on a municipal member's postal ballot the voter has exactly one vote.

🔴 And now a fourth — the proviso to rule 64-A makes Form 16-D itself the test

64-A. Counting and rejection of postal papers.— (1) … the provisions under rule 64 shall apply in relation to rejection of postal ballot papers referred to in sub-rule (4) of rule 46-A.

Provided that postal ballot paper shall be rejected if recording of vote therein is NOT in accordance with the directions contained in Form 16 D.

🔴 This is decisive. Form 16-D says "the number of members to be elected is one … you have only one vote". So if a detained voter takes Annexure-4 item (a) literally and puts two marks, his ballot must be rejected under the proviso to rule 64-A — the RO has no discretion at all.

✅ That makes the recommendation above stronger: tell the DEO before Annexure-4 is printed. This is not a printing nicety — it is a valid vote at stake.

⚠️ I am not calling this "the Commission's mistake". Annexure-4 is a template that also serves Panchayati Raj / multi-post elections (which is why MPMV machines exist there). The "two" in item (a) may well be a residue of that template. The order itself says it is issued "for recording votes at elections to the office of member of a municipality".

🚨 What to do — two steps

1. Tell the DEO in writing — before Annexure-4 is printed and dispatched. This is the sheet that goes into the detained voter's hands. If he takes (a) literally and puts two marks, his vote dies under item (c) of the very same annexure.
2. At the counting table: if such a ballot arrives with two marks — the RO does what the rule says ([SO 157 ¶7(c)] / rule 64) — reject it and record the reason. 🔴 Item (a) of Annexure-4 gives the RO no power to count two votes — an instruction sheet can neither add seats to a ward nor amend rule 64.

One more thing from Annexure-1 — the identifier's box

Annexure-1 ('Declaration by the elector') of order 1418 differs from Form 16-A in one respect — its attestation clause carries an identifier option:

"… signed by Shri … (elector), whom I personally know / whose identity has been established by Shri … (identifier), whom I personally know, in my presence to my satisfaction."

Below it the form has boxes for the identifier's signature and address, and for the attesting officer's name · signature · designation · address · date.

✅ This confirms the "designation box" test at §9.2-क. 🔴 And one caution: an empty identifier box is not by itself a defect — the form itself says "signature of the identifier, if any". If the attesting officer has kept the "I personally know" limb, no identifier is needed at all. Do not reject on that ground.

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9.5 Before and after rejection [SO 157 ¶8–9]

• ✅ Before rejecting, give every candidate or election agent present a reasonable opportunity to inspect the postal ballot — 🚫 but do not allow them to touch any postal ballot.
• Mark "नामंजूर/प्रतिक्षेपित" (rejected) on every rejected ballot and endorse the reason briefly in your own hand or with a rubber stamp.

9.6 Counting, announcement and packets

• The RO shall count all valid votes given in favour of each candidate or 'NOTA', record the total in the result sheet Form-21 and announce it [SO 157 ¶10].
• For the candidates' information, the total votes received as postal ballots by each candidate should be counted and announced to them [2292 ¶11(4)].

9.7 Making up the packets — the rule adopted

Two official documents conflict on the number of packets:

✅ Rule adopted: the later document prevails

Follow [2292 ¶11(5)] — the bundles are separate, but both go together into ONE sealed packet.

⚠️ This is a departmental working decision — not an SEC ruling. No official document says the later instruction supersedes the earlier one on this point. The caveats are recorded in GAPS §2 (SO 157 is a statutory order while 2292 is an administrative circular; and 2292 expressly supersedes only order 4249 dated 22.10.2019, not SO 157).

Practical safeguard, consistent with both texts: Both documents agree the bundles themselves are separate — that is common ground. So tie and label the valid bundle and the rejected bundle separately, then place both into the single sealed packet. This complies with 2292 to the letter while preserving the separation SO 157 intended.

Both agree: the packet is sealed with the RO/ARO's seal plus the seals of willing candidates, election or counting agents, and inscribed with the name of the municipality, ward number, date of counting and a brief description of the contents.

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9.7-A ✅ This is no longer a departmental call — rule 74-A settles it (23.08.2026)

§9.7 above described this as a "departmental executive decision", not the Commission's. That position has changed — it is resolved by a source higher than either document: the text of the rule itself.

The original (English) text of rule 74-A(1)(b) — from the ULB Manual, verbatim:

"(b) the packets of used postal ballot papers weather valid, rejected or cancelled, and counter-foils thereof;"

(the misprint "weather" is in the original text — it means "whether". Quoted as found.)

🔴 The rule itself puts "valid, rejected or cancelled" into a single packet category. It does not create separate packets for valid and rejected.

✅ So the decision at §9.7 was right — and it now rests on the text of the rule, not merely on "the later document wins". Give that as the basis in training — "rule 74-A(1)(b)", not "we picked the later document".

🚨 Remember one exception — the counterfoils. Rule 74-A(1)(b) puts the counterfoils in the same category, but item (6) of order 1418 directs that they go into a separate sealed packet — because the counterfoil carries the voter's signature [order 572, item 2(f)]. ✅ No conflict: the rule does not require them to be kept together; it only says neither may be opened without a court order. Follow item (6) of order 1418.

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10. Counting the votes recorded in the machines

10.1 Distribution of Control Units [2292 ¶12]

• Where a ward has more polling stations, CUs are distributed to counting tables in the serial order of polling stations — polling station 1's CU → counting table 1, station 2 → table 2, and so on. Keep a record of the distribution and display its chart on the board in the counting rooms [¶12(1)].
• Only the Control Unit is required for counting; the Ballot Unit is not. Even so, BUs received from polling stations should be kept with the CUs, ward-wise and polling-station-wise, at the collection centre. A BU is taken into the counting hall only when a candidate or their agent demands inspection, or its inspection otherwise becomes necessary in a special case [¶12(2)].

🚨 Exception: in BEL's post MK-V model EVM, the Ballot Unit must be connected to the Control Unit to obtain the result [2292 ¶12(2), ¶18(4)]. For MPSV/MPMV, only the CU is required [2292 ¶19].

• The relevant account of votes in Form 14-ग for that polling station must also be provided at the counting table along with the CU [¶12(3)].

10.2 Opening the carrying boxes [2292 ¶13]

1. CUs are received from polling stations duly kept in their carrying boxes and sealed by the Presiding Officers.
2. As each box reaches the counting table, check the seal affixed by the Presiding Officer.

   Even if a carrying box seal is not found intact, there is no possibility of tampering with the CU inside — provided the seals on that unit, and especially the strip seal and the pink paper seal, are intact [¶13(2)].

3. Remove the box seals; take out the CU and place it on the counting table so that candidates/agents present can inspect the strip seal, special tag and pink paper seals [¶13(3)]. The same procedure applies to the Ballot Unit for BEL MK-V.

10.3 Checking seals and identification marks [2292 ¶14–15]

• Check the serial number of each CU and satisfy yourself that it is the same CU given to the Presiding Officer for that polling station, and that the Candidate Set Section seal is the one affixed before the machine was issued. The Presiding Officer has also affixed a strip seal and a seal on the special tag.

  Even if any of these seals is damaged, there is no possibility of tampering — provided the pink paper seal on the inner cover of the Result Section is intact [¶14].

• Before counting, allow candidates/election/counting agents to inspect the paper seals and other important seals and to satisfy themselves that the seals are intact. You must also satisfy yourself that no machine has been tampered with [¶15].
• 🚨 If you are satisfied that a machine has in fact been tampered with, do not count the votes recorded in it, and follow the "postponement of counting" procedure [¶15].

10.4 Matching the paper seal serial number [2292 ¶16]

1. On opening the outer cover of the Result Section you will see the inner cover sealed with the Presiding Officer's seal — check that seal too.

   Even if that seal is damaged, there is no possibility of tampering — provided the pink paper seal is intact and has not been tampered with [¶16(1)]. There will be two paper seals in the inner cover. Match the serial number on the paper seal with the serial number given in the paper seal account prepared by the Presiding Officer at item no. 9 in Part I of Form 14-ग. Let the candidates/agents present also match it [¶16(1)].

2. If it does not match, then either there is a mistake in the paper seal account, or prima facie it is a cause for suspicion of tampering. Decide by examining the serial numbers of unused paper seals returned by the Presiding Officer, the complaints made by candidates or agents at the polling station, and other relevant circumstances. If you find it to be a clerical mistake, ignore the discrepancy [¶16(2)].

10.5 Where tampering is found [2292 ¶17]

If satisfied that a machine has been tampered with, or that the machine is not the one issued for that polling station:

• set the machine aside;
• do not count the votes recorded in it;
• report the case to the Commission;
• 🚨 it is not necessary to postpone the entire counting

🚨 Tendered ballots — never counted (added 22.08.2026)

Rule 63-A(3) (Manual PDF p.119 = printed p.110 — read by me):

"No envelope containing the tendered ballot papers shall be opened and no such votes shall be counted."

✅ The "do not open the packet" limb is already in this handbook — items (i), (v), (vii) arrive sealed from Presiding Officers and are not needed at counting, so they are sealed straight into the iron chest on receipt; rule 74-A bars opening them without a court order. 🚨 What was missing is the second limb — "no such votes shall be counted" — as a citable rule.

The "total number of tendered votes" row in Forms 21 and 22

Why it is there	for the record only
Does it add in?	🚨 No — it enters no candidate's total and does not affect the result

➡ If an agent in a narrowly-decided ward demands that tendered votes be counted, cite rule 63-A(3) directly. The demand has no basis in law..

10.6 Ascertaining the result [2292 ¶18]

• If necessary, press Result-1 again so candidates/agents can note the result [¶18(2)].
• After the result is noted, close the Result Section cover and switch the CU OFF [¶18(3)].
• MK-V / M3A: the related Ballot Unit must be connected to the CU to determine the result; the rest of the procedure remains the same [¶18(4)].

10.7 Completing Form 14-ग Part-II [2292 ¶20]

1. The counting supervisor records the number separately for each candidate and for NOTA in Part-II. 🚨 Verify that the total number of votes shown in Part-II equals the total shown against item 5 of Part-I of the same form. After it is correctly completed, the counting supervisor signs; the signatures of candidates or their agents present near that table are also obtained on Form 14-ग.
2. The form is then handed to the RO/ARO, who, after satisfying themselves that it is properly filled and complete, also signs. The signed form goes to the officer preparing the final result sheet (Form-21).

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10-A. 🔴 The original text of rule 63-A — the seal checks are not procedure, they are a statutory precondition to counting

Added 23.08.2026. The seal checks at §13–§16 have so far been drawn from [2292]. Where their legal basis lies was nowhere stated. It is in the opening words of rule 63-A(1).

63-A. Counting of votes.— (1) After the returning officer is satisfied that a voting machine has in fact NOT been tampered with, he shall have the votes recorded therein counted by pressing the appropriate button marked "Result" provided in the control unit, whereby the total votes polled and votes polled by each candidate shall be displayed … on the display panel provided for the purposes in the unit.

🔴 What this means

🔴 This is why the seal checks cannot be skipped. If the RO presses Result without having satisfied himself, the count has taken place without the precondition in rule 63-A(1) — a direct ground in an election petition. Say it that way in training: "this is a condition in the rule, not a precaution."

🚨 Rule 63-A(2)(b) — who signs Part II

"(b) Part II of Form-14 C completed in other respects and signed by the counting supervisor and also by the candidates or their election agents or their counting agents present;"

Two points: (1) the counting supervisor's signature is mandatory. (2) on the other side — the candidate OR his election agent OR his counting agent, whichever is present. 🔴 Any one of the three suffices; do not demand all three.

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11. Final result sheet (Form-21) [2292 ¶21]

🚨 First this — rule 66 fixes FIVE contents for Form 21

(verified from the rule text itself on 22.08.2026 — Manual PDF p.109)

"66. Preparation of result sheet of counting.— After the completion of the counting the returning officer shall prepare the result in Form 21 containing:— (i) the names of the candidates for whom valid votes have been given, (ii) number of valid votes given for each candidate. (iii) total number of votes given to NOTA (none of the above). (iv) number of votes declared invalid. (v) number of tendered votes."

Item	Content	What goes in it at Balotra
(i)	names of candidates	—
(ii)	valid votes for each	—
(iii)	total votes to NOTA	—
🚨 (iv)	number of votes declared invalid	normally nil on an EVM — but do not leave it blank; write "NIL"
🚨 (v)	number of tendered votes	take it from item 7 of Form 14-C

🔴 Do not let item (v) cause confusion — teach both together: a tendered vote is never counted [rule 63-A(3)] — but its number is entered in Form 21. Both are true: not counted, but counted up.

⚠️ Items (iii), (iv) and (v) were inserted/substituted by notification F.8(ga)( ) Rules/DLB/18/24669 dated 19.02.2019 — which is why older material shows only (i)–(iii).

1. Form-21 is filled after both the machine counting and the postal ballot counting. It is filled by adding, for each candidate, the candidate-wise votes recorded in the machines (including NOTA) and the candidate-wise valid votes found in postal ballots (including NOTA).
2. If the Commission has directed a re-poll at any polling station, the counting result of that re-poll must be included in the result sheet. 🚨 The grand total must not be struck until the re-poll result has been included.
3. 🚨 Verify the correctness of the grand total — any difference materially affects the poll result and the declaration made on the basis of that form. Any discrepancy will be taken seriously by the Commission and will be cause for strict disciplinary action.

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12. Recount [2292 ¶22]

1. Normally every vote recorded by a machine is valid and no dispute arises. At most a candidate/agent may not have properly noted the result. If re-verification is needed, press the result button and the result is displayed again.
2. Even though machines largely obviate the need for a recount, the provisions of Rule 67 still apply. Accordingly, when counting is complete and Form 21 is prepared: - declare the total votes received by each candidate and by NOTA; - pause the proceedings for one or two minutes; - if a candidate (or in their absence their election/counting agent) demands a recount, ascertain how much time they need to give a written application; if the time asked is reasonable, permit it and announce it.
3. On receiving an application, consider the grounds stated and give your decision. 🚨 Your decision is final, but record briefly the reasons for your decision in each case.
4. If you accept an application wholly or partly, have the votes recorded in the machine recounted according to your decision. Postal ballots too are recounted if you so decide. After the recount, revise the result sheet as necessary, announce the revisions, then complete the result sheet and sign it.

   🚨 The result will not be affected by the votes received by NOTA; rather, the candidate receiving the highest number of votes shall be declared elected [¶22(4)].

5. 🚨 The right to demand a recount under Rule 67 does not mean a recount can be accepted merely on a candidate's asking. The party demanding it must prove that prima facie the particulars of votes appear incorrect and that a recount is necessary in the interest of justice [¶22(5)].
6. 🚨 After you have completed the result sheet and signed it, no candidate has the right to demand a recount. Reject any such demand [¶22(6)].

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12-A. 🚨 The original text of rule 67 — §12 above is its practical form

Added 22.08.2026. This module previously said that "the detailed grounds for a recount under Rule 67 (the text of the Rules is not held)". That was wrong — the original text is available in full in the ULB Manual and is reproduced verbatim below.

67. Announcement of results and recounting of votes.— (1) After the preparation of the result sheet as per rule 66, the returning officer shall announce the total number of votes polled by each candidate. (2) After such announcement has been made the candidate or, in his absence, his counting agent may apply in writing to the returning officer to recount the votes either wholly or in part, stating the grounds on which he demands such recounting. (3) On such application being made the returning officer shall decide the matter and may allow the application in whole or in part or may reject it in toto, if it appears to him to be frivolous and unreasonable. (4) Every decision of the returning officer under sub-rule (3) shall be in writing and containing the reasons therefor. (5) If the returning officer decides under sub-rule (3) to allow the recounting … he shall do recounting according to rule 64 and amend the result sheet to the extent necessary after such recounting and announce the amendment so made by him. (6) After the total number of votes polled by each candidate has been announced under sub-rule (1) or under sub-rule (5) … returning officer shall complete and sign the result sheet and no application for recounting shall be entertained thereafter: Provided that no step under this sub-rule shall be taken on the completion of the counting until the candidates and election agents present at the completion thereof have been given a reasonable opportunity to exercise their right conferred by sub-rule (2).

🚨 Four things only the original text gives you

✅ §12 above does not conflict with rule 67. 2292 ¶22 restates rule 67 step by step. Teach them together — §12 for what to do, §12-A for the words to write it in.

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13. Postponement of counting [2292 ¶23]

1. If counting must be suspended or postponed before completion, seal all voting machines and all other election papers. If candidates/agents wish to affix their own seals on each machine and packet, permit them.
2. Keep all sealed machines and packets in a separate room and seal and secure the room with your seal and the candidates' seals. Alternatively, candidates may also put their own locks alongside yours.

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14. Where a machine is destroyed or damaged [2292 ¶24]

Under Rule 55 the Commission may direct that counting be stopped and, if necessary, order a fresh poll. If before completion of counting the RO reports that a machine used at a polling station:

→ send a report of all such facts to the Commission immediately and await the Commission's directions on counting the votes of that polling station.

🚨 Rule 55(3) — and this goes well beyond "await directions"

Verbatim (Manual, printed p.97 = PDF p.106 — I read the page image myself): "Where a report has been sent to the State Election Commission under sub-rule (1), the returning officer shall not commence counting of votes till he gets a clearance to do so from the State Election Commission."

Two things differ from the sentence above —

	What we said	What the rule says
Scope	"the votes of that polling station"	🚨 "counting of votes" — not confined to any station
Nature	"await directions" (passive)	🚨 "clearance" — an affirmative permission is required

➡ If a report has gone to the SEC under rule 55(1), the RO must not commence counting at all until the Commission clears him. This is statutory — no circular can displace it.

The four rule 55(1) triggers: (a) a ballot box or voting machine unlawfully taken out of the Presiding Officer's custody, or destroyed/lost/damaged/tampered with such that the result cannot be ascertained · (b) mechanical failure of a voting machine during the recording or counting of votes · (c) an error or irregularity in procedure likely to vitiate the poll · (d) booth capturing such that the result cannot be ascertained.

🚨 Why it bites on this calendar: the chairperson (21.09) and vice-chairperson (22.09) counts open immediately after the poll, so a rule 55(1) report can still be pending with the SEC at the moment the RO would otherwise open the count. Members: poll 09/11.09, count 14.09 — the same exposure.

⚠️ Do not conflate this with §10.5. §10.5 ("it is not necessary to postpone the entire counting", 2292 ¶17) and Order 5681 Part D both operate after counting has lawfully commenced. Rule 55(3) governs commencement only. There is no conflict between them.

💡 Alongside, rule 55(6): where the Presiding Officer is of opinion that booth capturing has taken place and voting machines are in use, he shall immediately CLOSE the control unit so that no further votes can be recorded, and detach the balloting unit from the control unit.

🚨 §14.1 — where the poll was ADJOURNED (added 22.08.2026)

This is a completely different trigger from the rule-55 list. None of §14's six grounds (machine removed / destroyed / damaged / mechanical failure / process vitiated / booth capturing) covers a poll adjourned for a flood or a riot with the machine perfectly intact. That is why it is set out separately.

(a) When a poll may be adjourned — rule 53(1) (Manual PDF p.105, read by me)

"If at any election it is not possible to take the poll at any polling station or the proceedings at any polling station are interrupted or obstructed by riot, violence, disturbance of the public peace, natural calamity, the presiding officer for such polling station may adjourn the poll and shall forthwith inform the returning officer who shall in turn report to the Commission."

(b) 🚨 The bar on counting — rule 53(2), and it operates automatically

"Whenever a poll is adjourned the returning officer shall as soon as may be with the previous approval of the State Election Commission, notify the date and hours during which and the polling stations at which the poll shall recommence and shall not count the votes cast at any such election until such adjourned poll shall have been completed."

Scope	🚨 "the votes cast at any such election" — the election, not merely that station
Nature	automatic — no separate direction from the Commission is needed to trigger it
Resumption date	notified by the RO with the SEC's previous approval

(c) The Commission's direction — the whole ward's count stops

Order F.4(1)(8)नपा/रानिआ/2009/4650, dated 04-11-2019 — Compendium document (59), printed pp. 249–250 (I read both the page image and the order number myself):

"Where a report has been sent under rules 53, 55 or 62A of the said rules, the Returning Officer shall stop the counting in such election, since in municipal elections the ward is the constituency, and if a re-poll takes place at even one polling station its result may affect the result of that ward."

"…the Returning Officer shall stop the remaining counting of that ward and shall proceed further only on receiving directions from the Commission. The Returning Officer must send the report of all such cases from all the polling stations of that municipality together."

🚨 Three things ROs most often get wrong

#
1	The stop is not limited to that polling station — the whole ward's remaining count halts
2	One consolidated report covering every polling station of the municipality — not separate ones
3	"send the complete report with all the facts in one go, so that there is no unnecessary delay in the Commission's decision" — piecemeal reporting is itself the cause of delay

The Commission has annexed model forms to that order for these reports — use those.

(d) Rule 62-A(4) — tampering discovered during counting

"Under sub-rule (4) of rule 62A, if during counting the Returning Officer is satisfied that a voting machine has in fact been tampered with, he shall not count the votes recorded in that machine and shall report to the Commission in accordance with the procedure laid down in rule 55."

➡ So a problem arising mid-count is routed through rule 55 — and then, under 4650, the rest of that ward's counting stops as well.

⚠️ Do not conflate this with §13 and §14 — three different things

	What it is	When
§13 "suspension of counting" [2292 ¶23]	halting a count already running	during counting
Order 5681 "result deferred"	deferring one machine's result	during counting
🚨 Rule 53 "adjournment of poll"	the poll itself is adjourned	on poll day

The wording is similar; the meanings are not. Teach all three side by side so the difference lands.

(e) How an adjourned poll is completed — Margdarsika ch.10

• The Presiding Officer seals both units and all election papers in the presence of the polling agents and keeps them safe — "as if the poll had concluded normally"
• The re-poll resumes from the point at which it stopped; electors who had already voted do not vote again
• The RO supplies the same marked roll and the same Form 14-क register, plus a new voting machine

(Sub-section (e) rests on Margdarsika ch.10 — I did not open that page in this check; rule 53(2), order 4650 and rule 62-A(4) above I read myself.) Counting after a re-poll [¶25]: fix a date, time and place and give written intimation to every candidate or election agent. Follow the same detailed procedure, so far as applicable.

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15. Declaration of results [2292 ¶26]

• After counting, the RO prepares the particulars in Form-21 and, unless otherwise directed by the SEC, declares the results.
• 🚨 The candidate who has received the highest number of valid votes shall be declared elected.

15.1 Tie — lottery

If after counting there is a tie and the addition of just one vote would entitle one of them to be declared elected:

1. the RO shall immediately draw a lottery in the presence of such candidates or their election agents;
2. a record of the proceedings shall be prepared, with signatures of those present if they so sign;
3. the record shall be kept in a separate envelope with other papers in safe custody;
4. an appropriate entry shall be made in Form-21 and Form-22 against the votes of the candidate in whose favour the lot was drawn;
5. 🚨 the entire lottery proceedings shall be videographed.

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16. Certificate of election and documents [2292 ¶27–28]

• The RO gives the certificate of election in Form-23 to members declared elected. On giving it, obtain a receipt from the candidate with their due signature. Send the receipt and result-related documents to the State Election Commission [¶27].

Documents to be prepared after the result [¶28]:

All must carry the RO's signature, with name, date and place written below the signature, and the RO's seal clearly affixed. Instructions on sending these to the Commission were issued by order 1374 dated 04.02.2026 (statutory order 155/2026) [¶28].

✅ Corrected 22.08.2026 — that order has now been read. An earlier version of this line read "That order was not read for this module." The Compendium, order (66), printed p. 273 was read first-hand — the four documents, the three-day deadline and the Mangal font / MS Word condition are set out in full in the Appendix below. It supersedes order 4228 dt 21.10.2019 (S.O. 126/2019).

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17. Re-sealing the machines after counting [2292 ¶29]

17.1 ECIL machines — the CU is NOT sealed

🚨 The MPSV / MPMV EVMs manufactured by ECIL are NOT to be sealed. Only the SDMM and DMM used in these machines are to be sealed [¶29(1)].

• SDMM sealing — Commission's letter 705 dated 20.01.2026
• DMM sealing — Commission's letter 826 dated 23.01.2026
• After sealing the SDMM, the MPSV EVM — and after sealing the DMM, the MPMV EVM — can be re-used for a forthcoming poll with a new SDMM and a new DMM respectively [¶29(1)].

✅ Corrected 22.08.2026 — both letters are now held and have been read in full. An earlier version of this line read "Letters 705 and 826 are not available — the actual sealing method cannot be stated here." They were never published on the circulars page, but both are printed in full in the Compendium — 705 at printed pp. 214–221 · 826 at printed pp. 222–229.

🚨 The one thing that matters most — colour: the two procedures are structurally identical; the only differences are which module is sealed and the colour — SDMM = 💛 PINK · DMM = ⬜ WHITE (paper seal, envelope and both stickers). Do not mix the colours. The full method (four conditions, steps (a)–(m), box sizes, iron box, treasury) → SDMM / DMM Sealing After Counting — the procedure.

17.2 Other machines — how the CU is re-sealed [¶29(2)]

Under Rule 63-ख, after the result has been entered in Form 14-ग Part-II and Form 21, the CU is re-sealed with the RO's seal and with the seals of willing candidates/agents. 🚨 Re-sealing must be done in such a manner that the result recorded in the CU is not erased and the unit retains the memory of that result.

Please note: removing the battery is necessary so that it does not swell over time and damage the machine. However, removing the battery does not erase the result recorded in the CU, because the CU retains its memory even if the battery is removed [¶29(2)(i)].

Address tag after counting [¶29(2)(v)]:

⚠️ This tag differs from the poll-day address tag — it adds the date of counting. Compare [SO 145 ¶5].

17.3 Storage [¶29(3)–(5)]

• Re-sealed CUs go into specially prepared large boxes for safe storage.
• Except for the Ballot Units of BEL's MK-V model, other BUs will ordinarily not need to be opened at counting. If a BU is taken out for inspection or verification, put it back in its carrying box and seal it afterwards.
• BUs are also kept in specially prepared large boxes. All CUs and BUs used are thus made ready to be taken to the storage place.

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18. Sealing other election papers [2292 ¶30]

Under Rule 74-क the specified packets shall not be opened, nor their contents inspected, nor produced before any person or authority, without an order of a competent court [¶30(1)].

Where voting machines were used, these papers are:

When sealed:

• Items (iii) and (viii) are prepared at the time of counting itself and sealed with your seal immediately after counting ends. This is in addition to the seals of any candidates/agents who wish to affix theirs. Tell candidates present that they must affix their seals — it is in their own interest [¶30(2)].
• Items (i), (v) and (vii) are received duly sealed from the Presiding Officers. Since they are not needed at counting, seal each immediately on receipt at the place of receiving election papers and put it in an iron chest [¶30(3)].
• 🚨 Appoint a responsible officer-in-charge to supervise the actual sealing — otherwise important papers may go astray, causing complications and confusion when a competent court orders their production [¶30(4)].
• Each iron chest shall have two locks, and each lock shall be sealed [¶30(5)].

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19. Recording the proceedings [2292 ¶31]

After the machines and papers are sealed at the counting place itself, record the proceedings mentioning:

Then sign the proceedings and obtain the signatures of candidates/agents present and willing. Place the proceedings in an envelope and seal it; keep the sealed envelope with the packets of election papers.

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20. Safe custody of election records [2292 ¶32]

1. 🚨 Immediately after the declaration of result, on the same day, all machines and the sealed chest containing the packets shall be kept in safe custody under two locks in the government treasury / sub-treasury or a place designated by the DEO. - key of one lock → the treasury officer or another officer of the treasury/sub-treasury authorised under the Treasury Code; - key of the second lock → the Election Officer themselves or a senior officer nominated for the purpose.
2. The armed police guard deployed outside the room before counting began must not be removed after counting ends until the machines and records are sent to the treasury/sub-treasury or the designated place. As far as possible, the same guard party should be deployed during transport, and this fact must be mentioned in that party's log book.

Thereafter: reserve machines to the district warehouse; machines used in the poll in the RO's safe custody. Limitation for an election petition is 30 days; if filed, machines stay sealed until three months after its disposal (and until disposal of any appeal); otherwise machines are cleared 30 days after declaration of results [2184 ¶15].

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20-A. 🚨 Three strong-room / counting requirements of order 2184 — previously missing

Added 22.08.2026. Source read first-hand: the Compendium, printed page 189 (PDF p. 202) — order 2184 dated 26.02.2026, points 13 and 14.

✅ Caveat lifted: it was earlier uncertain whether order 5446 dated 04.08.2026 had superseded or renumbered point 13 of 2184. All three pages of 5446 were read on 22.08.2026 — it contains no supersession clause. Its own words are: "… detailed directions were issued by letters 2184 … 705 … 826 … 2292 … In respect of the said orders, important directions are being sent, a brief point-wise account of which is as follows…" — that is, 5446 is a short reminder circular, not a replacement. 2184 and 2292 remain fully in force.

(a) Candidates may seal the strong room and may watch it [2184 ¶13(i)]

"… the strong room of the voting machines shall be kept sealed by the Returning Officer. Candidates or their election agents shall also be permitted to affix their seals on the doors / windows of the strong room, and they shall also be permitted to keep watch over the strong room from an adequate distance."

🚨 These are two separate rights — affixing a seal, and watching from a distance. Neither may be refused. When the strong room is sealed, record the offer made to such candidates / agents as are present to affix their seals.

(b) 🚨 A re-polled polling station has two machines and two tags [2184 ¶13(vi)]

"Where a re-poll is held, the machine originally used for the poll at that polling station shall also be kept in the strong room, with a tag clearly marked 'गणना नहीं करनी है' (not to be counted) affixed on that Control Unit, and it shall be kept sealed. When a re-poll is held, a tag clearly marked 'पुनर्मतदान की वोटिंग मशीन—गणना की जानी है' (re-poll voting machine — to be counted) shall be affixed on the new machine. Both kinds of tag shall be signed by the Returning Officer."

⚠️ Do not confuse this with the ordinary seal check at §13. Here the original machine's carrying box is never opened at all — it never reaches the counting table. Only the re-poll machine is counted. (Rule basis — rule 55(2): once the Commission declares a poll void, no vote cast at that poll is counted.)

(c) Videography of the EVM processes [2184 ¶14]

"For transparency it is also directed that the activities carried out at the various stages of the voting machine — the preparation of the voting machine, the sealing of the voting machine, the sealing of the strong room, the opening of the strong room and the like — shall also be videographed. The record of that videography shall be properly maintained, which shall be maintained as an election record, and, like other records, a certified copy of it may be issued."

🚨 Two consequences: (1) videography is not confined to the lottery — opening the strong room is also on camera; (2) that record is an election record — a certified copy of it may be demanded, and it can be used in an election petition. Losing the record is itself a lapse.

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20-B. 🔴🔴 Order 2285 dt 09.03.2026 (S.O. 160/2026) — ECIL machines are stored differently

Added 23.08.2026. I read both pages myself — General_ULB_2026/2026-03-09_2285.pdf. This order was previously on the "not read" list at GAPS §6.

Basis: the proviso to rule 73 — "after the declaration of the result at an election the used voting machines shall be kept by the returning officer in safe custody in such manner as the State Election Commission may direct." It supersedes order 3718 dt 01.10.2019 (S.O. 119/2019).

Items (1) and (2) — the general regime

1. Immediately after the declaration of the result, the CUs are placed in their carrying boxes and sealed in the manner stated under rule 63-ख. 🚨 The Balloting Units that were opened during the counting are likewise placed in their carrying boxes and sealed. The RO then places all the carrying boxes in large boxes / trunks prepared for the purpose, and on the same day keeps them in safe custody under two locks at the place appointed.
2. The key of one lock stays with the DEO or the Deputy DEO himself. The key of the second lock is handed over by the RO himself, or to another officer designated by the DEO for the purpose.

🔴🔴 Item (3) — a completely separate regime for ECIL MPSV / MPMV — this is Balotra's case

Original text: "Where the election has been held with the Multi Post Single Vote (MPSV) and Multi Post Multi Vote (MPMV) EVMs of Electronics Corporation of India Limited (ECIL), after the declaration of results the carrying boxes of these EVM machines need NOT be sealed, and they are NOT to be stored along with the EVMs mentioned at points 1 and 2. Since these EVMs can be used again for polling, they shall be kept in safe custody in a separate Warehouse."

"Where the election is held with these machines, after the declaration of results only the SDMM and the DMM used in the Control Units are to be sealed and kept in safe custody." — SDMM → letter 705 dt 20.01.2026 · DMM → letter 826 dt 23.01.2026.

🚨 In one table — where each machine goes after the count

🔴 This is the row that applies at Balotra — per press note 6722, Balotra has MPSV/MPMV, not M3A → BALOTRA §2.

✅ How this sits with §20 — no conflict

§20 above [2292 ¶32] says that "all the voting machines and the sealed trunk containing the above packets" go "under two locks". 2285 was issued on the very same day (09.03.2026) and carves out an exception for the ECIL machines. Read them together:

✅ Order 5446 ¶13(iv) (04.08.2026) repeats the same thing — "all EVM machines shall be deposited in the warehouse of the district concerned without any delay, so that these machines can be used again in elections." Three orders (2285 ·3 · 5446 ¶13(ii),(iv) · 2292 ¶29(1)) all say the same thing.

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21. Counting day at a glance

1 week before poll date  → written notice to candidates (Rule 57)               [¶3(4)]
2 days before counting   → counting agents' photo list + Form-19        [SO 151], [¶6(5)]
1 hour before counting   → agent signs Form-19 declaration; no entry without photo badge
──────────────────────────────────────────────────────────────────────────────────────
START → explain s.128 secrecy to everyone present                                  [¶9]
  1. Postal ballots first (finish before EVM counting finishes)                [¶11(1)]
  2. CUs to tables in polling-station order                                    [¶12(1)]
     🚨 re-polled station: the ORIGINAL machine stays sealed, tag "गणना नहीं करनी है";
     count only the one tagged "पुनर्मतदान की वोटिंग मशीन—गणना की जानी है"   [2184 ¶13(vi)]
  3. Box seal check → CU out → strip/special tag/pink seal inspection             [¶13]
  4. CU serial number + Candidate Set seal verified                               [¶14]
  5. Paper seal serial ↔ Form 14-ग Part-I item 9                                  [¶16]
  6. ON → remove seal over result button → Result-1 → candidates + NOTA           [¶18]
  7. Form 14-ग Part-II; total = Part-I item 5; signatures                         [¶20]
  8. Form-21 = machine votes (incl. NOTA) + valid postal votes (incl. NOTA)       [¶21]
  9. Declare → pause 1–2 minutes → recount demand?                             [¶22(2)]
 10. Highest votes elected (NOTA does not affect); tie → lottery + videography [¶22(4)],[¶26]
 11. Form-22 declaration · Form-23 certificate + receipt                       [¶26-28]
 12. Seal SDMM/DMM (ECIL CU not sealed) · re-seal other CUs + address tag         [¶29]
 13. Paper packets sealed · iron chest, two locks, both sealed                    [¶30]
 14. Record proceedings + signatures + sealed envelope                            [¶31]
 15. Same day → treasury, two locks · armed guard until transport done            [¶32]
 16. Same day → administer oath to elected members (for chairperson election) [closing note]

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🚨 Appendix — Order 5446 dated 04.08.2026 (new counting directions)

Added 21.08.2026. This order post-dates the building of this module, so it was not here before. I read the page image _r/new/o5446_p03.png myself — signed Rajesh Verma, Chief Electoral Officer and Secretary, 04.08.2026, endorsement 5447-50.

Point (13) — Counting

🚨 The critical point — what gets sealed after counting, by model

⚠️ This is the easiest place to slip. The older material says "the ECIL CU is not sealed" — true for MPSV/MPMV, but do not carry it across to M3A. On an M3A both the CU and the BU are sealed.

Point (12) — Strong room and counting premises

• "After the poll the voting machines shall be collected and kept in safe custody at the municipal headquarters itself (at the counting venue). The strong room shall be kept sealed by the Returning Officer."
• (i) CCTV cameras at suitable places for the security of the strong room
• (ii) Fire safety measures in the strong room
• (iii) 🚨 Two-tier security at BOTH the strong room and the counting premises

Point (14) — Security procedure for the voting machines

• (i) Commission protocols to be followed at every stage — preparation, sealing, sealing of the strong room, transport, storage, distribution, counting, FLC, commissioning, maintenance of the machine register. 🚨 "Also ensure that the political parties are informed of the entire process."
• (ii) 🚨 "Full responsibility for keeping the voting machines secure at the designated places and at each level rests with the District Election Officer" — who shall coordinate with the police.

⚠️ Do not confuse this with "clear after 30 days"

Point 13(iv) requires the machines to be deposited in the warehouse without delay. That is not the same as clearing them — under order 2184 ¶15, where no election petition is filed the machines are cleared 30 days after the declaration of the result. Depositing ≠ clearing. Two separate steps.

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🚨 Appendix — Order 5681 dated 08.08.2026, Part D: "During counting"

Added 21.08.2026. I read the page image _r/new/o5681_p03.png myself — signed Rajesh Verma, Chief Electoral Officer and Secretary, 08.08.2026, endorsement 5682-87.

D-1 🚨 If the result does not display on the CU during counting

"If, because of a fault in the EVM during counting, the result is not being displayed on the CU, then in such a situation the Returning Officer shall defer the result and ensure that the services of an authorised engineer are obtained. If the authorised engineer cannot extract the result from the EVM, the Returning Officer shall inform the State Election Commission through the District Election Officer. Further action in the matter shall be taken as directed by the Commission."

Three steps, in this order — the RO does not decide this alone:

1. RO  DEFERS  the result of that machine   (the whole count is not stopped)
        |
2. Services of an  AUTHORISED ENGINEER  are obtained
        |
3. Still no result  ->  RO -> DEO -> State Election Commission
                        further action on the Commission's directions

🚨 Note the word "defer". Only that machine's result is deferred; counting at the other tables carries on.

D-2 🚨 The CU battery can go LOW during counting

"At any time during counting the CU battery may go into LOW mode. In such a situation, so that counting continues smoothly and without interruption, District Election Officers should keep some new batteries in reserve at the counting venue."

➡ This is the DEO's advance preparation, not the RO's. New batteries must be held in reserve at the counting venue. Hunting for a battery on counting day means counting stops.

The escalation route for any CU display problem

"Note:– if any of the above problems appears on the CU display panel, contact — through the Zonal Magistrate of your area, via the Sub-Divisional Officer — to obtain the services of an authorised engineer."

Route: counting table ➜ Zonal Magistrate ➜ Sub-Divisional Officer ➜ authorised engineer

And on the panchnama (end of Part C)

• A panchnama (the annexed table) is to be prepared
• Column 3 records the clock error, or the time displayed on the machine
• 🚨 The polling agents' signatures are to be taken on the panchnama
• After the election is over, the panchnama is kept attached to the Presiding Officer's diary

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🚨 Appendix — Order 5021 dated 21.07.2026 (law and order at the counting venue)

Added 21.08.2026. I read the page images _r/new/o5021_p03.png and o5021_p04.png myself — signed Rajesh Verma, Chief Electoral Officer and Secretary, 21.07.2026, endorsement 5026-5031, reference प 7(1)(3) पंचा/रानिआ/14-15.

⚠️ On scope: the reference number carries "पंचा" (Panchayat), but the text speaks of both the polling station and the counting venue and is addressed to District Magistrates / DEOs. It has been treated as applying to ULB — that is an interpretation, not an express statement in the order. Confirm with the DEO if in doubt.

🚨 Item 1.14 — electronic devices barred at the counting venue

Verbatim: the Commission directs that, to prevent campaigning within the prohibited area around a polling station on poll day and to maintain law and order at the counting centre at the time of counting, no person other than staff deployed on election duty shall be permitted to bring or use cordless phones, wireless sets, electronic gadgets and the like within 100 metres of a polling station. "Likewise, within the boundary controlling any person's entry to the counting venue, or within the cordoned area maintained by the security forces," such devices shall not be permitted either. Anyone found with such devices in violation shall have them seized by the officers in charge of security. After counting is over and the election results have been declared, the seized devices shall be returned.

🚨 Two different boundaries — do not merge them

⚠️ The order gives no distance for the counting venue. If anyone says "100 metres around the counting venue" — the order does not say that. The boundary is the cordon / entry-control line, which will differ at every venue.

Practical points

Link to the Margdarsika: [MG ch.5(11)] mentions only "mobiles, cordless phones etc." Order 5021 widens this — wireless sets and electronic gadgets too, with an express carve-out for staff on duty.

⚠️ Item 1.9 — liquor barred on counting day as well (unverified)

⛔ नवीनतम आदेश — जो मार्गदर्शिका और संकलन दोनों पर भारी पड़ते हैं records that item 1.9 bars the use, sale and distribution of liquor from 48 hours before the close of the poll and on counting day as well — i.e. extending beyond the 48-hour window of RPA s.135-C to cover counting day.

✅ Now verified (22.08.2026) — I read page 2 (_r/new/o5021_p02.png) myself. The text reads:

"The use, sale and distribution of liquor shall be prohibited from 48 hours before the close of the poll and on the counting day."

🚨 So the whole of counting day is dry — this goes beyond the Model Code's own window (MCC (IV)(4) covers only poll day and the 48 hours before it).

Two more points from that page: item 1.10 — vehicle checking from the date of withdrawal, and intensified from four days before the poll · item 1.11 — no more than three vehicles in an election rally.

⚠️ And the order's own disclaimer — say this in training

Item 2: "These directions are indicative, not comprehensive and final. Officers concerned with law and order shall therefore take all such steps as will make the election free, fair and peaceful."

➡ The list is not exhaustive. The DEO and SP may go further.

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🚨 Appendix — Order 1374 dated 04.02.2026 (S.O. 155/2026): within three days of the result

Added 22.08.2026. This is the order this module's "what we are not teaching today" list named. I have now read it myself — Compendium order (66), printed p. 273. Supersedes the earlier order 4228 dt 21.10.2019 (S.O. 126/2019).

Under rule 68 read with rule 72 — so that the names of elected members can be published in the Gazette, the RO shall send the Commission, 🚨 within three days of the declaration of results —

🚨 Before sending, every document must bear the RO's signature, name, designation and seal. The DEO must also ensure they went within the time limit.

⚠️ Check the Mangal-font requirement before counting day — the soft copy must be in that font.

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🚨 Penal provisions that bite at the counting place — the full text (added 22.08.2026)

This module says "explain section 128" in five places — but its text appeared nowhere. It does now. All texts read directly from the ULB Manual 2026 (RPA 1951 extracts).

1️⃣ Section 128 — secrecy of voting (Manual PDF p.43)

"128. Maintenance of secrecy of voting.— (1) Every officer, clerk, agent or other person who performs any duty in connection with the recording or counting of votes at an election shall maintain, and aid in maintaining, the secrecy of the voting … (2) Any person who contravenes sub-section (1) shall be punishable with imprisonment for a term which may extend to three months or with fine or with both."

✅ Read this out before counting begins — "explain it" now has content.

2️⃣ Section 135A — booth capturing reaches the counting place (Manual PDF p.46)

"135A. Offence of booth capturing.— (1) Whoever commits an offence of booth capturing shall be punishable with imprisonment not less than one year but which may extend to three years and with fine, and where committed by a person in the service of the Government, not less than three years but which may extend to five years and with fine."

Clause (d) of the Explanation is the counting clause:

🚨 "(d) seizure of a place for counting of votes by any person or persons, making the counting authorities surrender the ballot papers or voting machines and the doing of anything which affects the orderly counting of votes;"

🔴 This is the most important point here: booth capturing is usually taught as a poll-day offence — clause (d) carries it to the counting hall. If there is a rush or coercion at the counting place, this is the section — not order 5681 Part-D.

3️⃣ Section 136 — other offences (Manual PDF p.47)

The clause that matters most at counting:

"(f) without due authority destroys, takes, opens or otherwise interferes with any ballot box or ballot papers then in use for the purposes of the election;"

Penalty — sub-section (2):

🔴 Tell the counting staff plainly: the same act that costs an ordinary person 6 months costs you, on duty, 2 years — four times over. That is what produces care.

✅ All four sections apply to municipal elections — section 28 of the Act of 2009 imports sections 125–136 of the RPA 1951 (see the section 134-A block).

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📘 The post-counting rules — 70, 71, 72, 73, 75-A and the enabling rule 77-A (added 22.08.2026)

All texts read directly from the ULB Manual 2026 — Election Rules 1994.

🔑 Rule 77-A — which rules apply where an EVM is used (Manual PDF p.113)

"77-A.— In relation to voting and counting of votes, custody, inspection and disposal of election papers etc., where voting machine is used,— (a) the provisions of Chapter III, except rules 30 to 32, 34, 35, 37, 38, 40, 44 to 50, 54, 62 to 64, 74 and 75 shall, so far as may be, mutatis mutandis apply, and any reference in those provisions to ballot paper shall be construed as including a reference to such voting machine; (b) in lieu of those rules, the corresponding -A rules apply…"

🚨 This is the basis on which rules 55(3), 66, 67, 68, 69 and 70 apply to EVM counting at all. And every reference to "ballot paper" is to be read as including the voting machine.

🔴 Rule 70 — destruction or loss at the time of counting (Manual PDF p.111)

"70.— (1) If at any time before the counting of votes is completed, any ballot papers used at the polling station are unlawfully taken out of the custody of the returning officer or accidentally or intentionally destroyed or lost or damaged or tampered with to such an extent that the result of the poll of that polling station cannot be ascertained, the returning officer shall forthwith report the matter to the State Election Commission."

The Commission then does one of two things — sub-rule (2):

🚨 Know the difference from rule 55 — this is the commonest confusion:

Rule	Whose custody	When
55	🚨 the Presiding Officer's	at or after the poll
70	🚨 the Returning Officer's	at any time before counting is completed

➡ If something happens between the strong room and the counting table on 14.09, it is rule 70, not 55. In both, the report goes to the Commission, and the decision is the Commission's, not the RO's.

✅ Rules 71, 72, 73 — immediately after the result

🗄️ Rule 75-A — how long things are kept (Manual PDF p.120)

🚨 Note the word "previous" — approval obtained afterwards will not do.

✅ Read with rule 74-A(2): a sealed control unit shall not be opened, inspected or produced except under the orders of a competent court — and that is the window in which the election petition (30 days) falls.

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🚨 At the counting table — which envelope may be opened, and which may not (added 22.08.2026)

This is not poll-day material — it is a legal question at the counting table. The RO wants papers in order to reconcile — but some envelopes may not be opened without an order of a court.

✅ First the fact — the sealing split

(Source: Annexure-15A — see EVM/hi §envelopes)

🔴 Now the law — rule 74-A(1)

"74-A. Production and inspection of election papers.— (1) While in the custody of the returning officer, (a) packets of unused postal ballot papers with counterfoils; (b) packets of used postal ballot papers whether valid, rejected or cancelled, and counterfoils; (c) packets of used or unused tendered ballot papers; (d) packets of the marked copy of electoral roll; (e) packets containing the register of voters in Form 14-A; (f) packets of the declaration by electors and the attestation of their signatures — shall not be opened, inspected or produced except under the orders of a competent court."

🎯 Put the two side by side

🎯 This is the whole point of the section: the envelopes that are sealed (E-1…E-8) hold precisely the papers that rule 74-A(1) forbids opening without a court order. The sealing is not a coincidence — it is the rule being obeyed.

🔴 The practical danger on counting day

When a reconciliation will not tally, the first instinct is — "take out the marked copy and count it."

🔴 That is exactly what must not be done. Opening E-1 breaches rule 74-A(1)(d).

✅ The figures wanted are already in E-9 (Form 14-C) and E-11 (the diary) — and both of those are unsealed. Take them from there. If it still will not tally → report to the Commission under rule 70.

✅ Verified first-hand: rule 74-A text from Manual PDF p.119; the envelope list from Annexure-15A.

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🚨 A Minister may not enter the counting place — Model Code, Part (VII) item 7 (added 22.08.2026)

Source: the Commission's booklet "Model Code of Conduct 2026", printed p.10 (I read the page image myself — _r/mcc/mcc_p14.png)

"Ministers of the Central or State Government shall not enter any polling station or counting place except in their own capacity as a candidate, or a voter, or an authorised agent."

🔗 Read with rule 60 — admission to the place fixed for counting. And the Margdarsika [MG Ch.3(6)] likewise says "'public servant on duty' does not include Ministers, Ministers of State or Deputy Ministers".

✅ The RO will then have two grounds — the Code and the Margdarsika — if the question arises on 14.09.

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🗺️ Every counting rule — a one-page verified map (23.08.2026)

Why this map. Everything in this module has so far come from circular [2292]. A circular cannot change a rule. So the original text of every rule that governs counting has been read first-hand from the ULB Manual and set out below. Any statement in this module can be checked against this table.

Basis: rule 77-A (above) — at an EVM count these Chapter III rules apply unchanged; rules 62–64, 74 and 75 are replaced by the -A series.

— The Chapter III-A (-A series) rules —

🆕 Three new points — rules 59, 61 and 65

🔴 Rule 59 — the RO cannot appoint counting staff on his own

"59. Appointment of counting supervisor and counting assistants.— Subject to the provision of rule 77, the returning officer may with the previous approval of the District Municipal Election Officer, appoint as many counting supervisors and counting assistants as may be needed by him to assist him in the counting."

🚨 The appointment requires prior approval. Even a substitution of staff on counting day should carry the DEO's previous approval — if given orally, get it confirmed in writing afterwards.

ℹ️ A cross-reference quirk, recorded as found: rule 59 opens "Subject to the provision of rule 77", whereas rule 77 of the Rules 1994 is "Printing and clerical errors in electoral rolls" (I read both texts myself; there is no second rule 77 in the Rules). Take no action on it — the operative requirement is the DEO's previous approval, and that is plain.

🔴 Rule 61 — the secrecy duty binds the agents too

"61. Maintenance of secrecy of voting.— Every officer, clerk, agent or other person who performs any duty in connection with the recording or counting of votes at an election shall maintain and aid in maintaining the secrecy of voting and shall not communicate to any person any information calculated to violate such secrecy."

🚨 Three points: (1) it is not confined to staff — "agent" is expressly included. (2) "recording or counting" — that is the phrase which carries s.128 of the RP Act into the counting hall. (3) It is also the text of the Form 19 declaration (§6.7) — rule and form say the same thing.

🔴 Rule 65 — if the counting has to be stopped

"65. Counting to be Continuous.— The returning officer shall as far as practicable proceed continuously with the counting and shall, during any interval when the counting has to be suspended, keep the ballot paper packets and all other papers relating to election sealed with his own seal and the seal of such candidate or election agent as may desire to affix their seal and take sufficient precaution for their custody during such interval."

✅ This is the legal basis of §13 [2292 ¶23]. §13's "a separate room, the RO's seal plus the candidates' seals, and candidates may add their own locks" is the practical form of rule 65's "sufficient precaution". 🚨 Note the words "as far as practicable" — suspending is not forbidden, but the moment you suspend, the sealing becomes mandatory.