Background
The case challenged amendments to the Representation of the People Act, 1951, particularly:
- Introduction of open ballot system in Rajya Sabha elections
- Removal of the requirement that a candidate must be an elector of the concerned state
Key Issues
- Whether Rajya Sabha elections are part of legislative proceedings
- Whether anti-defection law (Tenth Schedule) applies to such elections
- Validity of open ballot and domicile removal
Judgment
The Supreme Court upheld the constitutional validity of both reforms.
Key Observations
- Rajya Sabha elections are not proceedings of the House
They are part of the electoral process, not legislative functioning. - Tenth Schedule does not apply
Anti-defection law applies only to voting inside the House, not elections. - Open ballot is valid
It promotes transparency and party discipline, without violating secrecy of voting. - Domicile requirement removal upheld
Strengthens the idea of national integration over strict federal representation.
Significance
- Clarified that election voting ≠ legislative voting
- Established that anti-defection law cannot control Rajya Sabha elections
- Strengthened transparency in indirect elections



