International Foundation for Electoral Systems written decision must be delivered by the SEC to the submitter of the complaint via email and immediately published on the SEC website.134 However, decisions are not provided directly to any other parties, impacting the fairness of proceedings for respondents or other interested parties. Transparency and open justice can enhance the acceptance of judicial decisions. As noted by the Virginia Supreme Court in Richmond Newspapers Inc v Virginia, “[p]eople in an open society do not demand infallibility from their institutions, but it is difficult for them to accept what they are prohibited from observing.”135 Conducting hearings in the open gives the public the opportunity to understand the system as a whole as well as the particulars of the case being heard.136 The Richmond case concerned members of the media who had sought access to a courtroom during a murder trial, and the court was asked to consider whether a trial may be closed to the public upon the unopposed request of a defendant, without any demonstration that closure is required to protect the right to a fair trial, or for some other overriding consideration. The court ultimately found that, absent an overriding interest articulated in findings, the trial of a criminal case must be open to the public. With respect to open hearings for electoral disputes, in both Macedonia and Mexico proceedings are not open to the public. Closed door proceedings can be a challenge for open justice, as transparency ties directly to the impartiality of judges and arbiters, an essential element of public confidence in the judiciary. As the U.S. Commission on Trial Court Performance Standards has observed: “independence of the judiciary is not likely to be achieved if a court does not manage itself…and account publicly for its performance.”137 In terms of access to judicial information more broadly, the UNHRC has stressed that states should proactively put information of public interest into the public domain ensuring “easy, prompt, effective and practical access to such information.” 138 In its Guide to Strengthening Judicial Integrity and Capacity, the United Nations Office on Drugs and Crime notes that transparency requires not just public and media access to court proceedings, but also access to court documents. The guide stresses that access to judgments, administrative information related to the court, as well as data on judicial caseloads, clearance rates, court fees and the use of budgetary allocations enables public scrutiny.139 Positive follow-on effects with implications for procedural justice result from increased transparency. The media is better able to report court proceedings, maintain higher standards and counter misconception if they have access to better information. Another side of the same coin is the dissemination of general legal information to judges and legal practitioners. Without reliable access to laws, regulations, jurisprudence and other primary legal sources, judges, lawyers and court users are left without clear guidance on how the law should operate 134 Rulebook on the Manner and Procedure for Deciding upon Complaints art. 43 (Maced.). Richmond Newspapers Inc v Virginia 448 US 444 (1980) at 571-572 136 Ibid. 137 BJA and NCSC, Trial Court Performance Standards with Commentary (1997), p. 18. 138 See UNHRC General Comment no.34 on Article 19: Freedoms of opinion and expression, CCPR/C/GC/34, 102nd session, Geneva, 11-29 July 2011, para. 19. The UNHCR explicitly acknowledges that this applies to the judiciary in addition to the executive and legislature. 139 UNODC Guide to Strengthening Judicial Integrity and Capacity, 86-88 135 36