Elected Heads of Government (based at the Carter Center of Emory University in Atlanta, Georgia and headed by the former United States President Jimmy Carter) and the Secretariat of the Commonwealth to observe elections that were then approaching. A proposal was made by the Carter Center for the appointment of the Chairman of the Commission. This proposal, known as the ‘Carter Formula’, provided for the submission by the opposition parties of a list of the names of six persons from among whom then President Hoyte would select a Chairman. The Carter Formula was eventually incorporated into the 1995 Act which amended Article 161. The 1995 Act provided that: …the Chairman of the Elections Commission shall be a person who holds or who has held office as a judge of a court having unlimited jurisdiction in civil and criminal matters in some part of the Commonwealth or a court having jurisdiction in appeals from any such court or who is qualified to be appointed as any such judge, or any other fit and proper person, to be appointed by the President from a list of six persons, not unacceptable to the President, submitted by the Minority Leader after consultation with the political parties represented in the National Assembly, other than the party to which the President belongs: Provided that if the Minority Leader fails to submit a list as provided for, the President shall appoint a person who holds or has held office as a judge of a court having unlimited jurisdiction in civil and criminal matters in some part of the Commonwealth or a court having jurisdiction in appeals from any such court or who is qualified to be appointed as any such judge. [18] This formula was enshrined in the 1995 Act, but the operation of that Act came to an end by virtue of a clause limiting its operation up to a specified date. This meant that the original provision for unilateral appointment by the President, as contained in the 1980 Constitution, was revived after that date. But the matter did not rest there. [19] A Constitutional Reform Commission (‘the Commission’) was established in January 1999. The Commission engaged in extensive consultations and public education initiatives.7 The largest number of recommendations made to the Commission, by both individuals and political parties, concerned the 7 Constitution Reform Commission, ‘Report of the Constitution Reform Commission to the National Assembly of Guyana’ (17 July 1999), 45 at [4.1] and p 48 at [4.8].