Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections standard that is helpful in ensuring that accepted interpretations are applied as much as possible. For example, the United Nations Human Rights Committee in General Comment no. 25 affirmed that “the right of persons to stand for election should not be limited unreasonably by requiring candidates to be members of parties or of specific parties.” 84 Regional courts have established tests to ensure that states are meeting minimum standards in protecting the right of political participation. For instance, the European Court of Human Rights (ECtHR) has construed the right to stand for an election as a principle that is implicitly included in the right to participate in government. The ECtHR has focused mainly on two criteria to determine whether a state has upheld this right: arbitrariness or lack of proportionality; and, whether there is interference with the free expression of the opinion of the people. In its ruling in Zdanoka v. Latvia, a case brought by an applicant who was excluded from standing as a candidate for election to the Latvian parliament, the Court detailed the test used to verify compliance with the right to stand for an election. She had been disqualified, pursuant to the Latvian Parliamentary Elections Act 1995, on the ground that she had “actively participated” in the activities of the Communist Party of Latvia (CPL) after 13 January 1991.85 In its ruling, the Court first specified that the standards derived from Article 3 of Protocol No. 1 of the European Convention are less stringent than those applied under Articles 8 to 11 of the Convention.86 The Court held that states are not restrained to a specific list of “legitimate aims” to justify limitations UN Human Rights Comm., Covenant on Civil and Political Rights (CCPR) General Comment No. 25, Art. 25: The Right to Participate in Public Affairs, Voting Rights and the Right of Equal Access to Public Service, ¶ 17, CCPR/C/21/Rev.1/Add.7 (July 12, 1996) [hereinafter CCPR General Comment No. 25] (“If a candidate is required to have a minimum number of supporters for nomination this requirement should be reasonable and not act as a barrier to candidacy.”), available at http://www.unhcr.org/refworld/docId/453883fc22.html; Declaration on Elections, supra note 54, art. 4, § 9 (“States should ensure that violations of human rights and complaints relating to the electoral process are determined effectively by an independent and impartial authority, such as an electoral commission or the courts.”). 85 Zdanoka v. Latvia, Eur. Ct. H.R., App. No. 58278/00, Judgment of 16 March 2006, ¶ 155(b). 86 European Convention, supra note 26, arts. 8-11 (establishing rights to respect for private and family life; freedom of thought, conscience and religion; freedom of expression; freedom of peaceful assembly; and freedom of association with others, and guaranteeing that for the freedoms of assembly and association,“[n]o restrictions shall be placed on the exercise of these rights other than such as are prescribed by law and are necessary in a democratic society in the interests of national security or public safety, for the prevention of disorder or crime, for the protection of health or morals or for the protection of the rights and freedoms of others,” although refusing to “prevent the imposition of lawful restrictions on the exercise of these rights by members of the armed forces, of the police or of the administration of the State”). 84 34