Principle 4: independent and Impartial Investigators Objectivity of the Investigation Body Independence can refer to the formal structural independence from other branches of government. Guarantees of structural independence can only be secured by constitution or statute.447 Although structural independence is an important indicator of objectivity or impartiality, it is essential to keep in mind that the institutions responsible for investigating electoral challenges can be independent in name but not in nature. This can become a particular problem in countries in which an independent election commission conducts the investigation and resolution of complaints because such a system “concentrates electoral power in one single body, creating the risk of eventual abuses without checks by a different body.”448 In Indonesia, for example, the authority of Bawaslu (the Election Supervisory Body) to both supervise electoral conduct and to investigate and resolve disputes has led to the perception that the institution lacks necessary neutrality.449 International experts have recognized, however, that investigations occurring in mixed models of electoral management can nevertheless demonstrate independence and impartiality.450 For these reasons, the second dimension of independence—the normative idea of independence of action—becomes “more important than the formal ‘structural’ independence.”451 Investigative bodies should strive to adopt a culture of independent decision-making regardless of their structural composition. Both strong leadership and involvement of civil society can contribute to instilling an institutional ethos of independence of action.452 As the European Court of Human Rights has repeatedly affirmed, in addition to structural and normative independence, another important element 447 See generally Orozco-Henríquez et al., supra note 101, at 90–91 (providing examples of constitutional and statutory provisions ensuring independence for election dispute resolution systems in regular courts, constitutional courts, administrative courts, specialized electoral tribunals, and electoral management bodies). 448 Id. at 136 (discussing the advantages and disadvantages of different types of electoral dispute resolution systems, including an electoral management body with judicial powers). 449 Internal survey response from an Indonesian election specialist (Jun. 17, 2013) (on file with IFES). 450 See Orozco-Henríquez et al., supra note 101, at 88; see also Wall et al., supra note 366, at 22–23. 451 Wall et al., supra note 366, at 22. 452 Cf. id. at 23; see generally IFES, Leadership in Crisis: Ensuring Independence, Ethics and Resilience in the Electoral Process (2020), https://www.ifes.org/sites/default/files/leadership_in_crisis_ensuring_independence_ethics_and_resilience_in_the_ electoral_process_2.pdf. 127