[42] The Report of the Constitutional Reform Commission recommended that the Chairman of the Elections Commission should be selected by a consensual process in keeping with the Constitution as reflected in the 1995 amendment.23 As far as the selection of the Chairman was concerned, therefore, it was intended that the process would be consensual. [43] Article 62 of the Constitution contains an important provision for the holding of free and fair elections in Guyana. Article 62 provides that elections shall be independently supervised by the Elections Commission in accordance with the provisions of Article 162. The importance of the independence of the Elections Commission therefore cannot be overstated. [44] Several issues have been raised before us which have been comprehensively dealt with in the judgment of the Honourable President of the Court, Mr Justice Saunders. One of the questions which has been posed is whether the President is obliged to give reasons for his actions under Article 161(2). [45] Article 161(2) provides: Subject to the provisions or paragraph (4), the Chairman of the Elections Commission shall be a person who holds or who has held office as a judge of a court having unlimited jurisdiction in civil and criminal matters in some part of the Commonwealth or a court having jurisdiction in appeals from any such court or who is qualified to be appointed as any such judge, or any other fit and proper person, to be appointed by the President from a list of six persons, not unacceptable to the President, submitted by the Leader of the Opposition after meaningful consultation with the non-governmental political parties represented in the National Assembly: Provided that if the Leader of the Opposition fails to submit a list as provided for, the President shall appoint a person who holds or has held office as a judge of a court having unlimited jurisdiction in civil and criminal matters in some part of the Commonwealth or a court having jurisdiction in appeals from any such court or who is qualified to be appointed as any such judge. 23 See: page 209 of The Report of the Constitutional Reform Commission.