Chapter 1: International Standards that is, when a case has been fully adjudicated, and neither party can appeal the decision any further. In a 2001 report reviewing the electoral complaint adjudication process in the Republic of Kazakhstan, the OSCE underlined that enforcement cannot take place until all domestic remedies have been exhausted and final decisions have been reached.241 For example, a run-off election cannot be ordered by a court if the decision is still subject to an appeal. Moreover, enforcement requires the cooperation of the diverse authorities responsible for the implementation of administrative or judicial decisions. Electoral authorities, prosecutors and the police should understand the decision taken by the complaints adjudication body and should carry out sanctions and penalties.242 The European Court of Human Rights in Petkov v. Bulgaria stressed that the “rule of law — one of the fundamental principles of a democratic society — entails a duty on the part of the State and public authorities to comply with judicial orders or decisions against them.”243 However, whether it is due to a lack of financial resources or to a lack of will, the enforcement of sanctions and penalties is not always effective in developing democracies. This unfortunately can lead to the denial of the right to an effective remedy and must be addressed if the electoral process is to be respected by the electorate and participants in the democratic process. 7. Effective Education of Stakeholders As noted above, public trust is a key element in an effective electoral process. The state is obligated to “ensure that those responsible for the various aspects of the election are trained.”244 States should implement training programs for election workers, as well as national civic education programs that will enable the public to become familiar with election pro Kazakhstan Report, supra note 225, at 6. Petkov v. Bulgaria, Eur. Ct. H.R., App. nos. 77568/01, 178/02 and 505/02, Judgment of 11 June 2009, ¶ 55 (“The applicants complained of the electoral authorities’ refusal to comply with the final judgment of the Supreme Administrative Court declaring their striking off the lists of candidates null and voId, and of their resulting inability to stand in the parliamentary elections on 17 June 2001.”). 243 Id. at ¶ 62; see also Hornsby v. Greece, Eur. Ct. H.R., App. No. 18357/91, Judgment of 19 Mar. 1997, ¶¶ 40-41. 244 Declaration on Elections, supra note 54, art. 4, § 2. 241 242 77