Chapter 1: International Standards areas.104 Corruptive activities such as bribe-taking can put in jeopardy equal access to justice, the fair and independent appointment of arbiters, or even the impartiality of the ruling on a case. There is a need to ensure that judges and arbiters who adjudicate electoral complaints are ethical, “especially in countries where the judiciary is plagued by incompetence, executive domination and systemic corruption.”105 i. Tests for impartiality Making determinations as to what constitutes “impartial” is not necessarily a clear-cut process. However, several courts have enumerated workable standards that can be adopted by countries around the world. For instance, the European Convention calls for a fair and public hearing within a reasonable time by an independent and impartial tribunal established by law,106 and the European Court has produced extensive case law on this right to a fair trial — including some decisions dealing with the resolution process of an electoral complaint. In Salov v. Ukraine, the Court found that the judge at issue did not meet the requirement of impartiality, because there were insufficient legislative and financial protections against outside pressure on the judge hearing the case.107 The Court stated that “in order to establish whether a tribunal can be considered ‘independent’ . . . regard must be added to the manner of appointment of its members and their term of office, the existence of safeguards against outside pressures and the question whether it presents an appearance of independence.”108 The decision shows that protecting the impartiality of judges and arbiters requires numerous efforts. Indeed, states should examine all of the elements discussed in the paragraph below to frame a system that will deter corruption or bias in the adjudicatory bodies. It requires the relevant legislative body to design the complaint adjudication system in the light of all of these factors that can potentially undermine impartiality. Council of Eur., European Comm. of Ministers, Res. No. (97) 24, 101st Sess., pmbl (Nov. 6, 1997). 105 Keith Henderson & Violaine Autheman, IFES, Global Best Practices, Rule of Law White Paper Series, A Model State of the Judiciary Report: A Strategic Tool For Promoting, Monitoring and Reporting on Judicial Integrity Reforms at the Country, Regional and Global Levels 16 (2004); Dr. Marcin Walecki, IFES, Political Money and Political Corruption: ConsIderation for Nigeria 6, tbl. 1 (2003), available at http://www.ifes.org/publication/98dac604e5ef5ec603 e632890259160d/Money_Corruption_Nigeria.pdf 106 European Convention, supra note 26, art. 6, § 1. 107 Salov v. Ukraine, Eur. Ct. H.R., App. No. 65518/01, Judgment of 6 Dec. 2005, ¶¶ 78-98. 108 Id. ¶ 80. 104 39