Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections tion, or an invalidation of particular ballots are clear, transparent and easily understandable before the election takes place.60 Indonesia provides an illustration of the consequences of dangerous ambiguities in election law and the failure to rectify these before elections.61 Irregularities in the election law for the 2009 legislative elections left the seat allocation process open to interpretation and legal challenge. Despite identification of problems before the election, the National Election Committee (Komisi Pemilihan Umum [KPU]) and other actors failed to sufficiently remove the ambiguity through regulation or preemptive clarification.62 Following the KPU’s 24 May 2009 announcement of the seat allocation, different legal challenges were brought before both the Constitutional Court and the Supreme Court.63 These two courts released decisions resulting in mutually exclusive seat allocations and on 1 September 2009, the Constitutional Court, which has the final authority for resolving election challenges, settled the dispute. Disappointed candidates filed a case requesting judicial review of the laws regulating the judicial powers of the Constitutional Court and the Supreme Court, claiming that Indonesia’s laws gave the Courts the same authority and created legal uncertainty. The Constitutional Court rejected the request in early 2010, E.U. Election Observation Mission, Mexico PresIdential and Parliamentary Elections Final Report 50 (2006) [hereinafter E.U. Mexico Report], available at http://aceproject.org/regionsen/countries-and-territories/MX/reports/mexico-presIdential-and-parliamentary-elections/ view; see also John Hardin Young, Recounts, in International Election Principles: Democracy and the Rule of Law 301 (John Hardin Young ed., 2009). 61 IFES, A Free, Fair and Credible 2009 Election in Indonesia Through Targeted Election Management Assistance 5, 19 (2009); Law on Legislative Elections (2008) (Indon.). 62 IFES produced and disseminated a brief for policy makers and stakeholders prior to the election that outlined the inconsistency and recommended preemptive clarification. IFES, A Free, Fair and Credible 2009 Election in Indonesia Through Targeted Election Management Assistance 6 (Feb. 24, 2010). 63 Id. at 20-21. The dispute arose from the omission of the word “remainder” in the election law that opened up legal uncertainty. KPU did not directly address this issue before the elections and thus, those standing to benefit from literally interpreting the flawed language challenged the KPU’s Regulation No. 15 arguing that it did not correctly construe the law. From an election administrative perspective, the KPU’s approach in Regulation No. 15 was the more sound interpretation of the law. Complainants were asking the Supreme Court to interpret the law in a way that would go against the one person-one vote rule. The Supreme Court went along with this literal interpretation of the law even though it was a mistake from a technical point of view. The Constitutional Court later reversed the Supreme Court’s ruling. Id. 60 28