Introduction measure to prevent election grievances from becoming a catalyst for violence and disorder. In contrast, the violence in Kenya following the 2007 presidential elections demonstrated the insufficiency of the electoral complaint mechanism.3  The Kenyan constitution and the electoral law on presidential and parliamentary elections provided for the determination of challenges, but only after the results were announced. Moreover, as in many Commonwealth countries, the Kenyan courts had jurisdiction to adjudicate electoral complaints, but delays in ruling, corruption and an overall lack of competence undermined public trust in the judiciary. Much of the violence would probably have been avoided if principles and procedures to receive and hear the allegations of irregularities and fraud had been in place.4 Despite the universal importance of legal structure to deal with election complaints, the origination of these systems varies from country to country. Some countries, such as Ethiopia, respond quickly with ad hoc attempts to maintain electoral integrity after unexpected conflict arises. The 2005 Ethiopian elections were mired in alleged irregularities, and the election authority responded by creating committees to review complaints and investigate potentially meritorious allegations. The near-disaster in the 1994 Dominican Republican elections resulted in the quick implementation of an electoral complaints system that created a more stable election in 1996.5 Other democracies, such as Uruguay and Brazil, have taken a longer-term approach, recognizing concerns of electoral corruption in their early history and thus making use of major Independent Review Commission on the General Elections, Kenya National Dialogue and Reconciliation (“Kriegler Commission”), Report of the Independent Review Commission on the General Elections Held in Kenya on 27 December 2007 141 (2008) [hereinafter Kriegler Commission Report] (“[A] material contributor to the tension at KICC, broadcast live to the country, was the absence of an effective electoral dispute resolution mechanism to resolve the mounting challenges to the integrity of the results from Kibaki strongholds.”), available at http://www.dialoguekenya.org/docs/FinalReport_consolIdated.pdf; see also Christopher Fomunyoh, Center for Humanitarian Dialogue, Mediation des Conflits Electoraux [Mediation of Electoral Conflicts] 13-14 (2009) (discussing 2006 presIdential elections in the Democratic Republic of the Congo), available at https://www.ndi.org/files/Mediation_des_Conflits_Electoraux_FRE.pdf. 4 Kriegler Commission Report, supra note 3, at 139. 5 National Democratic Institute for International Affairs (NDI) & The Carter Center, The 1996 PresIdential Election in the Dominican Republic 45-46 (1998), available at http://aceproject. org/regions-en/countries-and-territories/DO/reports/Final percent20Report percent20Dominican percent20Republic percent201996.pdf/view. 3 5