Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections complaint forms and instructions.35 Such efforts provided greater transparency of the complaints process and built stakeholders’ confidence.36 Transparency requires that adjudicatory bodies publish their decisions. Publication increases public trust, eases the burden on future plaintiffs, and clarifies any future action that a plaintiff could bring.37 The European Commission, in its report on the 2006 elections in Nicaragua, stated that the lack of publication of decisions was “not in line with any acceptable international standards and illustrates a lack of transparency, a lack of acceptable judicial formalities, and also a thoroughly inadequate degree of reasoning in terms of electoral justice.”38 Some states go further. For example, Armenia, Moldova and Uzbekistan recognized in the Convention on the Standards of Democratic Elections, Electoral Rights and Freedoms that “legal acts and decisions relating to the citizen’s voting rights, freedoms and obligations cannot be applied if they are not officially communicated to the public.”39 During the 2009 Afghan elections, the ECC complied with its obligation to publish its decisions.40 Indeed, the ECC released substantive information on its website throughout the investigation and adjudication process. Similarly, the Central Election Committee in Georgia created a searchable web-based election complaint database both in Georgian and English that Id. See also Schramm et al., supra note 2, at 11-12 (“Transparency of the complaints process was increased by publishing more detailed information on complaints at an early stage. A summary of each campaign complaint was posted on the CNE website. In addition, a copy of complaints with Identification of the complainant blacked out was made available for examination by the public in the CNE complaints office.”) 37 The National Election Committee (Cambodia) drafted a set of rules of procedures for handling complaints relating to electoral matters. This manual clearly states the obligation to publish the National Election Committee decision at each stage of the complaint process. Whether it is the Commune/Sangkat Election Commission, the Regional Election Commission, or the National Election Commission, the date at which the complaint will be resolved or was resolved, the date and place of the hearing and the final decision or appeal should be published. National Election Committee, Manual: Procedures for Handling Complaints Relating to the Violations on the Law, Regulations and Procedures During the Electoral Campaign, Voting, Ballot Counting and Result Announcement Period, pts. I. B., II.B, II.D.2.5, II.D.2.6, available at http://www.necelect.org.kh/English/voterReg/Complaint_Manual.pdf. 38 European Union (E.U.) Election Observation Mission, Final Report: PresIdential and Parliamentary Elections Nicaragua 23, 63-64 (2006) [hereinafter, E.U. Nicaragua Report], available at http://ec.europa.eu/external_relations/human_rights/election_observation/nicaragua/ final__report_en.pdf. 39 European Commission for Democracy Through Law (“Venice Commission”), Convention on the Standards of Democratic Elections, Electoral Rights and Freedoms in the Member States of the Commonwealth of Independent States, art. 7, § 3, Opinion No. 399/2006 (Jan. 22, 2007) [hereinafter Commonwealth Convention], available at http://www.venice.coe.int/ docs/2006/CDL-EL(2006)031rev-e.pdf. 40 Exclusion decisions, fines issued, and complaints dismissed were listed on the ECC website during the 2009 election cycle, but had been removed by the end of 2010. 35 36 20