CDL-AD(2020)025 - 14 - in the Grand Chamber judgment Mugemangango v. Belgium of 10 July 2020 that “a judicial or judicial-type remedy, whether at first instance or following a decision by a non-judicial body, is in principle such as to satisfy the requirements of Article 3 of Protocol No. 1”. Regardless of which body decides on the validity of election results, the law must guarantee procedural safeguards, such as impartiality, precise norms to limit the discretion of the authority, guarantees of a fair, objective and reasoned decision, in order to prevent arbitrary decisions and to be in accordance with the Convention.68 46. In summary, a majority of countries provide for a judicial review, at least in last instance, as recommended by the Code of good practice in electoral matters. There are also cases of countries allowing electoral complaints before the Constitutional Court or an equivalent body in first and final instance. In electoral matters like in other fields, the judiciary, including a specialised electoral jurisdiction, remains a guarantee of impartiality of the whole process, provided that it offers enough guarantees of independence. 47. The number of levels of appeals is another important element to be taken into account for assessing the effectiveness of the remedies regarding electoral disputes. Several levels of appeals may be a guarantee for electoral stakeholders. However, for certain types of preelection disputes, multiple levels of administrative and judicial appeal can potentially disrupt the electoral calendar and create uncertainty. A balance is therefore necessary between an effective remedy and ensuring smooth and continuous electoral processes, i.e. without disruptions endangering the continuity of the electoral cycle as a whole. C. Other procedural issues concerning competent bodies 48. Decisions on complaints and appeals in the electoral field are overwhelmingly taken in a collegial composition, be they by election commissions or courts, except for cases related to voter registration or disputes related to election day, where a decision by a single judge is common; this can be explained by the necessity to issue a very quick decision. Apart from such cases, the composition of the body deciding on complaints and appeals in electoral matters should preferably be a collegiate one.69 Moreover, the Venice Commission regularly recommended to provide clear and consistent complaints and appeals procedures so as to avoid any conflicts of jurisdiction.70 concerned complaints on the election results concerning the subsequent distribution/annulment of parliamentary seats (eligibility to stand for parliament) which were decided by the parliament itself, with no possibility of appeal to judicial bodies. In the Grosaru decision, the European Court of Human Rights found that neither the parliament nor the Central Election Office were impartial decision-making bodies. As for the Central Election Office, seven of its members were judges from the Supreme Court, but the remaining 16 members were MPs, which allowed for politically motivated decisions. See also 2019 Amicus curiae brief for the Grand Chamber of the European Court of Human Rights in the case of Mugemangango v. Belgium on the procedural safeguards which a state must ensure in procedures challenging the result of an election or the distribution of seats, para. 27, 50, and the Grand Chamber judgment of the European Court of Human Rights Mugemangango v. Belgium of 10 July 2020, para. 70, 76, 97-99, 137-139. 68 Mugemangango v. Belgium of 10 July 2020, para. 135, 137-139. 69 See for instance 2010 Joint Opinion on the Amendments to the Electoral Code of the Republic of Belarus as of 17 December 2009, para. 65. 70 See 2003 Joint Recommendations on the Electoral Law and the Electoral Administration in Armenia, para. 50; 2010 Opinion on the draft election code of the Verkhovna Rada of Ukraine, para. 15; 2013 Joint Opinion on the Draft Amendments to the Laws on election of people’s deputies and on the Central Election Commission and on the Draft Law on repeat elections of Ukraine, para. 98; 2013 Joint Opinion on Draft Amendments to Legislation on the Election of People’s Deputies of Ukraine (CDL-AD(2013)026), para. 66; 2012 Opinion on the Federal Law on the election of the Deputies of the State Duma of the Russian Federation, para. 41-42, 114-115; 2018 Joint opinion on the law for amending and completing certain legislative acts (Electoral system for the election of Parliament) of the Republic of Moldova, para. 53; 2018 Joint opinion on the draft election code of Uzbekistan, para. 13.