Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections dependent and impartial tribunal established by law,”99 and the United Nation Human Rights Committee further explains that “administrative mechanisms are particularly required to give effect to the general obligation . . . through independent and impartial bodies.” 100 The Committee affirmed that “an independent electoral authority should be established to supervise the electoral process and to ensure that it is conducted fairly, impartially and in accordance with established laws which are compatible with the Covenant.”101 As a key component of the overall electoral process, any body dealing with electoral complaint adjudication should seek to address this standard. Many regional instruments also stress the importance of an autonomous and impartial judge in the judicial system.102 These obligations can be extended to asserting the need for impartiality of an adjudicatory body. One cannot discuss the impartiality of an election arbiter without acknowledging a major obstacle to fair adjudication: corruption. Corruption undermines the independence of arbiters and judges, the legitimacy of electoral law, and the right to an effective remedy. It represents a major threat to democracy and human rights, the rule of law, and endangers the stability of democratic institutions.103 The fight to minimize and eradicate corruption in electoral complaint processes needs to be multi-disciplinary, including administrative matters, judicial appointments, salary levels, among other ICCPR, supra note 11, art. 14, § 1. UN Human Rights Comm., CCPR General Comment No. 31 [80], Nature of the General Legal Obligation Imposed on States Parties to the Covenant, ¶¶ 15-16, CCPR/C/21/Rev.1/ Add.13 (May 26, 2004) [hereinafter CCPR General Comment No. 31]. 101 CCPR General Comment No. 25, supra note 84, ¶¶ 17, 20, 25. A Uganda case illustrates the importance of the compliance with the right to a fair trial, when a court stated that “to operationalize this constitutional provision [Article 28 of the Constitution: Right to Fair Hearing] with regard to the resolution of electoral disputers among contestants, rule 4 of the Parliamentary Elections (Election Petitions) Rules, S.I 141-2 was made under S93 of the Parliamentary Elections Act.” The Court then recalled that this right to a fair hearing is underogable and is “extremely important in the adjudication of matters between parties.” The constitutional provision reflects international standards and is the legal basis used to implement such guarantees within the electoral dispute resolution process. Electoral Commission v. Bakireke, (2009) U.G.C.A. 12 (Ct. App.) (Uganda), available at http://lawviatheinternet.org/ug/cases/UGCA/2009/12.html. 102 European Association of Judges, Judges’ Charter in Europe, art. 1 (March 20, 1993); 6th Conference of Chief Justices of Asia and the Pacific Region, Beijing Statement of Principles of the Independence of the Judiciary in the LAWASIA Region (August 1995), available at http://lawasia.asn.au/objectlibrary/147?filename=Beijing percent20Statement.pdf; IberoAmerican Summit of PresIdents of Supreme Justice Tribunals and Courts, Caracas Declaration (March 4-6, 1998); Conference on the Judiciary in the Arab Region and the Challenges of the 21st Century, Recommendations of the First Arab Conference on Justice (“Beirut Declaration”) (June 14-16, 1999). 103 Council of Eur., Conf. of European Ministers of Justice, Res. No. 1, 21st Conf. (June 10-11, 1997). 99 100 38