On 5th July, 2013 the Supreme Court of India in S. Subramaniam Balaji vs. State of Tamil Nadu and Ors.; (2013) 9 SCC 659 had directed the ECI to frame guidelines governing election manifestos in consultation with all the recognized political parties. Supreme Court further directed that a separate head for guidelines for election manifesto released by a political party can also be included in the Model Code of Conduct for the Guidance of Political Parties & Candidates.