Guide on Article 3 of Protocol No. 1 – Right to free elections found that the applicant’s complaint had been examined by a body which had not provided the requisite guarantees of its impartiality and whose discretion had not been circumscribed with sufficient precision by provisions of domestic law. The safeguards afforded to the applicant during the procedure had likewise been insufficient, having been introduced on a discretionary basis. 108. Finally, the Court has confirmed that electoral disputes could not be examined under Article 6 of the Convention, which the Court has found inapplicable. It took the view that an applicant’s right to stand for election to the French National Assembly and to keep his seat was a political one and not a “civil” one within the meaning of Article 6 § 1, such that disputes relating to the arrangements for the exercise of that right lay outside the scope of Article 3 of Protocol No. 1 (Pierre-Bloch v. France, 1997, § 50). Nor was the criminal limb of Article 6 engaged as regards penalties imposed for non-compliance with electoral rules (ibid., § 61). In Geraguyn Khorhurd Patgamavorakan Akumb v. Armenia (dec.), 2009, the applicant NGO had been an observer during parliamentary elections. Following a subsequent dispute as to the failure of the Central Election Commission to transmit various documents, the Court took the view that the outcome of the proceedings in question had not been decisive of the NGO’s civil rights and that it did not therefore fall within the scope of Article 6 § 1 of the Convention. European Court of Human Rights 28/35 Last update: 30.04.2021