Chapter 1: International Standards occurred.”208 In this case, the applicants brought a claim before the ECtHR and argued that the Bulgarian electoral authorities had not complied with the final judgments that were issued by the domestic court and had therefore deprived the applicants of their right to be elected to Parliament. The government of Bulgaria argued that the domestic remedies had not been exhausted and thus, the applicant’s claim should be dismissed. The Court ruled in favor of the applicants and concluded that they “did not have at their disposal effective remedies in respect of their complaint under Article 3 of Protocol No. 1 . . . and holds that there has been a violation of Article 13 of the Convention.”209 One way to provide an effective remedy in response to electoral irregularities is by modifying the electoral law and more specifically the provisions dealing with complaints adjudication. For example, in the 2004 presidential elections in Ukraine, the court system was flooded with complaints and the Supreme Court, based on the large number of allegations of electoral irregularities, ordered that a new election be conducted. Prior to the 2010 presidential elections, changes were made to the electoral law to avoid a repetition of the 2004 elections. The Ukrainian example also demonstrates the difficulties in determining whether an effective remedy exists, particularly in emerging democracies, and within the politically charged atmosphere inherent in electoral conflict. On the eve of the 2010 presidential elections, “experts [were] warning that Ukraine’s presidential elections law [was] so flawed that it could permit a repeat of the large-scale fraud that triggered the Orange Revolution.”210 But, following the second round on 7 February international election monitors reported that the elections were free and fair, and world leaders accepted the victor.211 Despite these endorsements, the ousted incumbent, Yulia Tymoshenko, accused her opponent of fraud and challenged the out- Id. Id. ¶ 83. 210 Mark Rachkevych, Can Ukraine’s PresIdential Election Be Stolen Again?, Kyiv Post, Nov. 26, 2009, available at http://www.kyivpost.com/news/politics/detail/53728/. 211 Luke Baker, NATO, EU Follow U.S., Welcome Ukraine's Yanukovich, Washington Post, Feb. 12, 2010, available at http://www.postchronicle.com/cgi-bin/artman/exec/view.cgi?archive=184&num=284224. 208 209 69