d) International challenges 407. Electoral rights are human rights and several have been enshrined in various international instruments (see chapter 2, section 2). Some of these universal or regional instruments have agencies and procedures for reinforcing, on the basis of subsidiarity and complementarity, means for protecting and defending that which is established domestically. The subsidiary nature of international challenges means that domestic means and mechanisms must be exhausted first before recourse is had to a universal or regional mechanism. In addition, the complementary nature of such challenges emphasizes the fact that international mechanisms do not replace but at best are additional to the means of protection provided for domestically. The jurisdiction of international bodies in charge of overseeing the implementation of electoral and human rights needs to be specifically recognized by the state party to the corresponding international instrument, treaty, covenant or convention. 408. The international means for bringing electoral challenges are those legal instruments provided for in international treaties and conventions by which those with the standing to do so may have recourse, on a subsidiary and complementary basis, to the competent body (for example the European Court of Human Rights or the Inter-American Court of Human Rights) after exhausting the domestic remedies provided. This enables a complainant to challenge an act or judgement that is alleged to violate either electoral rights or a right enshrined in the relevant international instrument. In due course, the international body with jurisdiction resolves the dispute. Its decision is binding if the state party has recognized its jurisdiction. 409. It should also be possible for another international organization to issue non-binding recommendations to a given state party to an international instrument, so long as the state recognizes its jurisdiction. For example, the United Nations Human Rights Council is made up of 47 member states, elected directly and individually by the members of the General Assembly, based on an equitable regional distribution. The Council addresses situations in which human rights, including political and electoral rights, have been violated (dealing in particular with grave and systematic violations), and makes recommendations on the promotion and protection of human rights. It maintains a system of special procedures and a complaints procedure and presents an annual report to the General Assembly. 410. At the regional level, the European Court of Human Rights may receive applications from any person, NGO or group of individuals claiming to be the victim of a violation by a state party of the rights, including electoral rights, set out in the 1950 European Convention for the Protection of Human Rights and Fundamental Freedoms. If the Court finds that there has been a 142