Introduction
General Elections in any country presupposes a contest between two contestants at least. That presents an opportunity for the voters to decide between the two according to their political and social philosophies. However, there are exceptions also. Sometimes, due to various reasons, one of the contesting candidates gets elected unopposed without facing the elections. This has recently happened in India on April 22, 2024, when the ruling Bharatiya Janata Party candidate from Surat Lok Sabha constituency in Gujarat, Mukesh Dalal, was elected unopposed. The Returning Officer rejected the nomination papers of the Congress Party's candidates, main and substitute nominees, the previous day. Also, the eight other nominees withdrew their candidature. Resultantly, there will be no polls on May 7th as per schedule of the Election Commission of India.
Historical Background
Mukesh Dalal is the 29th Member of Parliament since 1952, when the first general elections were held in India, to get elected unopposed, including through by-polls. In the years 1952, 1957, and 1967, most MPs, five each, were elected unopposed. Since 1952, the State of J&K has returned four MPs unopposed. At the same time, only eight States, including Andhra Pradesh, Assam, Odisha, Tamil Nadu, Telangana and Uttar Pradesh have sent more than eight MPs unopposed to the Parliament. Congress leads the tally in this regard having 20 legislators sent to the Parliament, uncontested. With two each, the National Conference (NC) and Samajwadi Party (SP) come next. Only one independent candidate has been elected unopposed till date. Mukesh Dalal is the only unopposed MP from the ruling BJP in this list. In the Parliamentary seats of Sikkim and Srinagar, an MP was elected unopposed more than once.
The Notable Unopposed Members of Parliament
- Y.B. Chavan, former Deputy Prime Minister and Maharashtra Chief Minister from Nashik parliamentary constituency.
- Farooq Abdullah, former J&K Chief Minister and N.C. Chief from Srinagar parliamentary constituency.
- S.C. Jamir, former Nagaland Chief Minister and ex-Governor of four States.
- Harekrushna Mahatab, Odisha's first Chief Minister from Angul parliamentary constituency.
- PM Sayeed, former Union Minister from Lakshadweep parliamentary constituency.
- K.L. Rao, former central minister from Vijayawada parliamentary constituency in Andhra Pradesh.
Chronology of Uncontested Elections to Lok Sabha (Election Year-wise)
1. 1952 : Anand Chand
In the first general election of 1952, Anand Chand became the first and only independent candidate to be elected unopposed. He was the 44th ruler of the erstwhile kingdom of Bilaspur which happened to be a Lok Sabha seat, now a part of Himachal Pradesh. Though the Congress Party had put up a candidate against him, he withdrew later due to lack of funding and to avoid confrontation with the royalty. Congress Party accused him of taking bribes from Anand Chand. It also contested the unopposed election in the district court which ruled in favour of Anand Chand.
2. 1952 : Dr. Harekrushna Mahatab
Dr. Harekrushna Mahatab, the first Chief Minister of Orissa, was elected unopposed from the State's Angul constituency. Initially, the Ganatantra Parishad (GP), a dominant regional party, named a candidate but he withdrew perceiving that the fight against Dr. Mahatab was too tough. Again, the party's final candidate also left the fray, paving the way for his unopposed election.
3. 1952 : Manabendra Shah
A Congress Party candidate, from the Tehri Garhwal Lok Sabha constituency in erstwhile U.P. State, was elected unopposed. He was the last ruler of the erstwhile Garhwal kingdom, which was among the first princely States to join the Indian Union in 1949.
4. 1967 : Ngawang Lobzang Thupstan Chognor
He won the Ladakh Lok Sabha seat as a Congress Party candidate unopposed. Chognor is better known as the 19th Kushok Bakula Rinpoche, a Buddhist spiritual leader considered as the incarnation of Buddha.
5. 1977 : Chhatra Bahadur Chhetri & Rinchin Khandu Khrime
In Sikkim, Chhatra Bahadur Chhatri was elected unopposed despite having seven rival candidates in the fray, whose nomination papers were deemed invalid by the Returning Officer.
In Arunachal West seat, Rinchin Khandu Khrime was the only candidate to file nomination.
6. 1985 : Dil Kumari Bhandari
In 1985 bypoll in Sikkim, Dil Kumari Bhandari had an uncontested win, and she became the State's first woman representative in Lok Sabha.
7. 1989 : Mohammed Shafi Bhat
He won an uncontested election from Srinagar for the Lok Sabha amidst rising insurgency in Jammu & Kashmir in 1989.
8. 2012 : Dimple Yadav
She won the Lok Sabha election unopposed from the Kannauj Lok Sabha seat. In 2012, Akhilesh Yadav, the Samajwadi Party chief, became the Chief Minister of U.P. and he was forced to vacate his parliamentary seat. The Party named Dimple Yadav as its candidate in the ensuing elections. While the Congress, BSP and Rashtriya Lok Dal (RLD) abstained from the electoral process, the BJP and several independents and minor parties showed no interest in contesting from Kannauj Lok Sabha seat. Before polling though, an independent and a candidate from the Sanyukt Samajwadi Dal withdrew their nominations, with the expectation of Dimple winning from a Samajwadi Party's stronghold since 1998. However, BJP and Peace Party later accused the Samajwadi Party of not filing their nominations. The latter retorted by alleging that the BJP itself had asked its candidate to withdraw.
The Legal Scenario
Elections in India are conducted by the Representation of People's Act, 1951 which contain following provisions regarding uncontested elections-
1. Section 53 (3) of the Act of 1951 deals with the procedure to be adopted in case of uncontested elections. It stipulates that if the number of such candidates is less than the number of seats to be filled, the Returning Officer (RO) shall forthwith declare all such candidates to be elected. In this context, the actions of RO are governed by Section 33 of the Act which pertains to the presentation of nomination papers and requirements of a valid nomination.
Section 53(4) says: On the presentation of a nomination paper, the returning officer shall satisfy himself that the names and electoral roll numbers of the candidate and his proposer as entered in the nomination paper are the same as those entered in the electoral rolls….” Besides, in the chapter titled uncontested elections contained in the Handbook of Returning Officers (Edition 2) issued by the Election Commission of India in August 2023, stipulates that “if in any constituency, there is only one contesting candidate, that candidate should be declared to have been duly elected immediately after the last hour for withdrawal of candidature. In that event, a poll is necessary.” It further says that “all those candidates, who are returned as uncontested and (who) have criminal antecedents, must publicise the details in the prescribed format as per timeline.”
Conclusion
In a democracy, the governments are chosen by adopting an electoral process which leaves a choice before the voters to choose the best candidate out of many. But if there is only one candidate, voters have no choice but to remain content with the only candidate contesting elections. Many times, it happens in exceptional circumstances, as has been mentioned above. It ranges from the candidate's popularity, his royal lineage, celebrity status etc. Ideally, there should be a fight between at least two candidates to give a choice to the voters to elect the best candidate. It is seen generally in uncontested elections that people in general accept the verdict without referring to any malafide intentions or practices. Though such allegations of forcing other candidates by the use of muscle and money power have come to light in a few cases. There lies the danger signal for democracy. In every case of uncontested elections, the role of Returning Officer becomes very crucial. It is incumbent upon him to scrutinize the whole process before declaring any candidate as elected unopposed. Moreover, the political parties also owe a duty towards the common citizens to refrain themselves from adopting malafide electoral practices forcing other candidates out of the election race. After all, elections are the backbone of a democratic polity.