The French EDRS is a combination of constitutional and administrative jurisdictions. The administrative jurisdiction is autonomous, belonging to the Council of State (Conseil d’État), and hearings may proceed during the preparatory phase of an election. Under the constitutional jurisdiction, certain decisions of the Council of State may be reviewed and challenges to electoral results heard. In certain cases connected with the electoral register, challenges may be brought before a court of original jurisdiction (Tribunal d’instance) and eventually before the Court of Cassation (Cour de Cassation), both of which are part of the judicial branch, and whose rulings are final. 181. Examples of EDRSs that combine constitutional and administrative jurisdictions include Spain, where the final decision on a challenge to an election is made by the autonomous Constitutional Court, which can be resorted to after exhausting the possibilities of an administrative remedy before the Administrative Court, which is part of the judiciary. Another example is Portugal, where the final decision on a challenge to election results is directly entrusted to the Constitutional Court (Tribunal Constitucional), which is part of the judicial branch. 182. A significant number of the Central and East European countries that have recently undergone democratic transitions have given their Constitutional Court the last word in the EDRS when it comes to challenges to election results. These include Bulgaria, Croatia, Moldova, Montenegro, Romania and Slovenia, as well as Armenia, the Czech Republic, Georgia and Slovakia for which the corresponding court is part of the judicial branch. In Indonesia and Niger the final resolution of electoral disputes is also entrusted to a constitutional court, which in Indonesia is part of the judicial branch. 183. It is also possible to classify under this model the cases of Burkina Faso, Cambodia, Cameroon, Kazakhstan and Mozambique, which give a Constitutional Council which is not part of the judiciary the power to make the final decision on challenges to election results. iii) Administrative courts 184. A third type of EDRS, which is not widely used, gives jurisdiction over the final resolution of electoral challenges to an administrative court that can be either autonomous or part of the judicial branch. 185. Mindful that electoral challenges are generally brought against the actions, procedures and decisions of the EMB, some countries have vested jurisdiction over contentious electoral cases in an administrative court, either making it autonomous in keeping with the French tradition of administrative justice (entrusting it to the Council of State and even calling it that) or situating it within the judicial branch. 72

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