Why in news?

U.S. President Donald Trump posted on Truth Social that India's Chief Election Commissioner Gyanesh Kumar had asked his administration how American elections function without a mandatory photo ID. Trump also noted that only 1% of India's 64.64 crore voters in the last general election voted by mail, unlike the widespread use of mail-in voting in the U.S.

He used this exchange to renew his push for Congress to pass the Safeguard American Voter Eligibility (SAVE America) Act, which would mandate documentary proof of citizenship for voter registration and a photo ID to vote.

What’s in Today’s Article?

• How U.S. Elections Differ from India's?
• Is Non-Citizen Voting a Real Problem in the U.S.?
• The SAVE America Act: Provisions and Opposition
• Parallel with India's Special Intensive Revision (SIR)

How U.S. Elections Differ from India's?

• Article I, Section 4 of the U.S. Constitution (the Elections Clause) gives State legislatures authority over the "times, places, and manner" of federal elections, while allowing Congress to alter such rules.
• Unlike India, the U.S. has no national election authority — the Federal Election Commission only regulates campaign finance, while registration, balloting, and counting are handled by county and municipal jurisdictions.
• Two key federal laws shape U.S. voting:
  • the National Voter Registration Act, 1993 (requiring States to offer registration at motor vehicle and public assistance offices) and
  • the Help America Vote Act, 2002 (funding new voting machines and State-wide elector databases).
• Voter eligibility remains a State subject, and registration is elector-initiated — citizenship is self-affirmed under penalty of perjury rather than documented upfront.
• Thirty-six States require some form of ID at polling booths, and 23 require a photo ID specifically.
• India's System
  • India's system works differently. The Election Commission of India (ECI) compiles electoral rolls through house-to-house enumeration and has superintendence over the entire registration process.
  • Eligible electors receive an Electoral Photo Identity Card (EPIC), though other documents like Aadhaar are also accepted at polling booths.

Is Non-Citizen Voting a Real Problem in the U.S.?

• Independent studies suggest non-citizen registrations in the U.S. are almost always accidental, with only a small fraction actually voting.
• The Trump administration's claims have faced scrutiny: after announcing in July that 2,78,000 non-citizens were found on rolls across four States (including 15,903 in Nevada), the Department of Homeland Security later told Nevada officials it had identified just 185 potential non-citizens, describing the earlier figure as merely a "ceiling."
• Surveys do show broad public support for photo ID requirements at polling booths — but this falls short of the stricter citizenship-proof-at-registration requirement proposed under the SAVE America Act.

The SAVE America Act: Provisions and Opposition

• Passed by the House of Representatives in February along party lines, the SAVE America Act would require every new or updating voter to submit a passport, birth certificate, or naturalisation papers alongside a government photo ID.
• Mail-in voters would need to enclose a copy of their photo ID. States would cross-check names against U.S. Department of Homeland Security records, and election officials registering undocumented voters could face up to five years in prison.
• Analysts estimate that over 20 million eligible American citizens lack ready access to a passport or birth certificate, with young first-time registrants particularly affected.
• This concern has driven Democratic opposition, stalling the Bill in the Senate.

Parallel with India's Special Intensive Revision (SIR)

• India's ECI-led SIR process, aimed at "purifying" electoral rolls, requires electors to self-enumerate on forms distributed door-to-door, which are then scrutinised against records from the previous SIR conducted over two decades ago.
• All three phases of the SIR have shown anomalies — by phase 2, over 7 crore names were deleted, accompanied by a sharp fall in gender ratios across most States.
• An analysis found a religious skew in deletions in West Bengal, which affected electoral outcomes there. Despite these irregularities, the Supreme Court upheld the SIR as within the ECI's statutory mandate.
• Critics note a structural similarity between the two processes: both the SIR and the SAVE America Act shift the burden of proving eligibility onto individual electors, departing from earlier systems where officials proactively identified and enrolled eligible citizens.

Conclusion

Trump's remarks highlight starkly different electoral architectures — the U.S.'s decentralised, elector-initiated, State-led system versus India's centralised ECI-driven process.

Both nations now face contested reforms — the SAVE America Act and India's SIR — that shift verification onus onto voters, raising similar concerns about disenfranchisement despite claims of ensuring electoral integrity.