Election Investigations Guidebook International human rights-based standards for the resolution of election disputes have recognized the universal importance of independent and impartial institutions in the electoral complaint resolution process.431 In General Comment No. 32 to the ICCPR, the United Nations Human Rights Committee emphasized that the right to an independent and impartial tribunal is “an absolute right that may suffer no exception.” 432 In other words, it is a right applicable in all circumstances. 433 The Declaration on Criteria for Key Characteristics of Independent and Impartial Bodies: › Fairness › Objectivity › Conflict of interest disclosure › Integrity and incorruptibility › Functional and non-retaliatory immunity Free and Fair Elections accordingly emphasizes that electoral complaints should be resolved by “an independent and impartial authority.”434 The same foundational principles of objectivity, independence, neutrality, and impartiality—which should characterize the electoral dispute resolution system as a whole—also apply to the investigative process. International guidelines state that investigators and investigative bodies are obliged to “maintain objectivity, impartiality, and fairness throughout the investigative process and conduct [their] activities competently and with the highest levels of integrity,”435 a duty that extends to individuals and institutions responsible for investigating electoral disputes. Without structural and procedural safeguards to ensure independence and impartiality, public perception that election investigations favor a particular side in a dispute could endanger the democratic legitimacy and the credibility of the entire electoral process. 431 See generally GUARDE, supra note 1, at 37–50; Carter Center, Guide to Electoral Dispute Resolution 10–28 (Jan. 2010), http://www.cartercenter.org/resources/pdfs/news/peace_publications/conflict_resolution/Election-Dispute-Guide.pdf. 432 General Comment No. 32, supra note 374, ¶ 19. 433 OHCHR Manual, supra note 374, at 113–154. 434 Inter-Parliamentary Council, Declaration on Criteria for Free and Fair Elections art. 4, ¶ 9 (Mar. 26, 1994), http://www. ipu.org/cnl-e/154-free.htm. 435 Conference of International Investigators, Uniform Guidelines for Investigations ¶ 3 (2d ed. 2009), http://www.un.org/‌Depts/‌oios/‌investigation_manual/ugi.pdf; cf. UNDP, Legal Framework for Addressing Non-Compliance with UN Standards of Conduct ¶ 74 (2010), http://www.undp.org/content/dam/undp/documents/about/transparencydocs/UNDP_Legal_Framework_for_Addressing_Non_compliance_with_UN_Standards_of_Conduct.pdf (“All investigators . . . shall be independent. They have a duty of objectivity, thoroughness, ethical behavior, and observance of legal and professional standards.”). 124