Principle 2: Thorough Investigation vidual complaints concerning electoral irregularities and that the relevant decisions are sufficiently reasoned.131 Azerbaijan’s failure to consider the evidence in the Namat Aliyev case can be contrasted with the actions of the Commission on Elections (COMELEC) in the Philippines, as described in a domestic Supreme Court case, Domingo v. Commission on Elections. The petitioner appealed to the Supreme Court after COMELEC dismissed his complaint based on insufficient evidence and lack of merit. The Supreme Court, however, upheld COMELEC’s decision because it “was arrived at only after a careful scrutiny of the evidence at hand, especially of the videotapes of the petitioner.”132 The comprehensive examination of the evidence was “clearly evident” and “quoted extensively from the pleadings and evidence of petitioners, and provided adequate explanation for why it considered petitioner’s evidence insufficient and unconvincing.”133 In the landmark Shri Raj Narain v. Smt. Indira Nehru Gandhi case, the Supreme Court of India also emphasized the importance of substantiated facts and evidence.134 In 1971, Indira Gandhi won a seat in the lower house of Parliament. Shri Raj Narain, one of her rival candidates, challenged her victory in an election petition to the High Court. After the High Court void- A particular challenge in some jurisdictions is the fact that election petitions—particularly those relating to high office (such as president)—may be heard in the first instance by an apex or appellate court that has limited capacity for fact finding (as they are, by nature, usually focused on points of law in appellate cases). ed the election, Gandhi appealed to the Supreme Court. Concluding that the High Court’s findings were not based “on any direct evidence whatsoever,” the Supreme Court overturned 131 Id. ¶ 90. 132 Domingo v. Commission on Elections, G.R. No. 136587 (S.C., Aug. 30, 1999) (Phil.), http://sc.judiciary.gov.ph/jurisprudence/‌1999/‌aug99/‌136587.htm. 133 Id. 134 Shri Raj Narain v. Smt. Indira Nehru Gandhi (1975), reprinted in Election Comm’n of India, Landmark Judgments on Election Law 87–359 (vol. I, 1999), https://eci.gov.in/files/file/6955-landmark-judgments-for-volume-i-volume-ii-volume-iiivolume-iv/. 61