CONSTITUTIONAL AND STATUTORY FRAMEWORKS OFELECTORAL MANAGEMENT: A COMPARATIVE STUDY OFELECTION COMMISSIONS IN INDIA, THE UNITED KINGDOM, ANDTHE UNITED STATES

Abstract

Electoral management bodies constitute the institutional backbone of democratic governance. Their independence, legal foundation, administrative capacity, and operational autonomy determine the legitimacy of electoral outcomes. This research paper undertakes a comparative study of the constitutional and statutory frameworks governing election commissions in India, the United Kingdom, and the United States. While India follows a centralized constitutional model with a permanent Election Commission, the United Kingdom and the United States adopt predominantly statutory and decentralized mechanisms. Through an examination of constitutional provisions, legislative enactments, institutional design, and judicial interpretations, this paper analyses how differing political traditions and constitutional philosophies shape electoral governance. The study highlights structural disparities, functional strengths, and democratic vulnerabilities inherent in each model, and argues that India’s constitutional embedding of electoral management provides greater legal protection for electoral independence than the Anglo-American statutory approaches.