Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections election. However, the Court highlighted the necessity for the Parliament to regularly review the statutory restrictions to the right to stand for an election, “with a view to bringing it to an early end.”95 Similarly, in a recent case on repeat parliamentary elections irregularities, the ECtHR ruled that Georgia was in violation of Article 3, Protocol 1 of the European Convention. The Court made its decision on the legal basis of the Georgian Labour Party’s right to stand for election.96 The Court ruled that the Central Electoral Commission’s decision of 2 April 2004 to annul the election results in the Khulo and Kobuleti electoral districts were not made in a transparent and consistent manner. The Commission had not adduced relevant and sufficient reasons for its decision, nor had it provided adequate procedural safeguards against an abuse of power. Through this decision and others, the ECtHR has outlined general standards that apply to electoral adjudication processes. The International Covenant on Civil and Political Rights Article 14.1 All persons shall be equal before the courts and tribunals. In the determination of any criminal charge against him, or of his rights and obligations in a suit at law, everyone shall be entitled to a fair and public hearing by a competent, independent and impartial tribunal established by law. The Universal Declaration of Human Rights Article 10 Everyone is entitled in full equality to a fair and public hearing by an independent and impartial tribunal, in the determination of his rights and obligations and of any criminal charge against him. From these and other examples, it can be reasonably concluded that states should establish laws and regulations that define both the struc Zdanoka v. Latvia, Eur. Ct. H.R., App. No. 58278/00, Judgment of 16 March 2006, ¶ 135. The applicant party in this case complained about the conduct of the repeat parliamentary election on March 28, 2004 where Khulo and Kobuleti voters had been deprived from their right to vote. Georgian Labour Party v. Georgia, Eur. Ct. H.R., App. No. 9103/04, Judgment of 8 Oct. 2008, ¶ 104. 95 96 36