Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections Election Commission will look at convincing evidence to determine if, for example, there has been a violation of the rules on electoral expenditure and means of election campaigns, or, if any candidate has committed a dishonest and unfair act in the conduct of the elections.190  Similarly worded standards have been adopted in many international cases involving human rights.191 Clear and convincing seems to have become the default standard of evidence in international civil law.192 In his 2007 article on electoral complaint adjudication, Steven Huefner recommends that the United States adopt the clear and convincing standard for election cases, which have been dealt with inconsistently by different states using all three standards.193 He argues that this standard will be proper to use in electoral disputes as the U.S. election processes, though imperfect, have “earned a strong presumption of correctness.” Thus, the rebuttable presumption to void or modify an election result should require more than a 51 percent probability that “the official certification is not trustworthy.”194 Huefner justifies his preference for the clear and convincing test to prove an irregularity and to prove that this irregularity alters the outcome or at least renders it uncertain. He added: “Accepting clear and convincing evidence that the result is not reliable is likely to correct more election defects without destabilizing the system, but in turn calls for the kinds of greater guidance . . . about what remedy to impose.”195 Organic Act on the Election of Members of the House of Representatives and the Installation of Senators, arts. 57, 103, 107 (2007) (Thailand) (“In the case where during a period of time under Section 49 there is convincing evIdence that any person gave, offered to give or promised to give money or properties for the benefit of inducing a voter to vote for any candidate or political party . . . .”). 191 Terminology largely synonymous with clear and convincing evIdence used by various international courts includes references to the need for evIdence that is “clear and cogent” or “cogent and compelling,” as well as stipulations that tribunals needed to be “convinced.” See, e.g., HCJ 6659/06 Anonymous v. The State of Israel [2008] (Isr.) (applying “clear and convincing” standard); HCJ 11225/03 Bishara v. Att’y Gen. [2006] (Isr.) (requiring “clear, convincing, and unambiguous evIdence”); Military and Paramilitary Activities in and Against Nicaragua (Nicar. v. U.S.), 1986 I.C.J. 14 (June 27) (applying an unnamed standard between reasonable doubt and preponderance of the evIdence), available at http://www.icj-cij.org/ docket/files/70/6503.pdf. 192 Louis Henkin, How Nations Behave: Law and Foreign Policy 142 (2d ed. 1979); Dinah Shelton, Judicial Review of State Action by International Courts, 12 Fordham Int’l L.J. 361 (1989); Christopher Greenwood, International Law and the United States’ Air Operation Against Libya, 89 W. Va. L. Rev. 933 (1987). 193 Huefner, supra note 25, at 314. 194 Id. 195 Id. 190 64