Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections prohibition of the exercise of another function is highly recommended at a minimum during the election period. iv. Challenges and obstacles in developing democracies The limits of domestic systems and the restraints created by everyday practicalities in developing democracies should also be recognized. To provide for an impartial arbiter within the electoral complaints system, states should comply with standards regarding the appointment, the removal or the remuneration of judges and arbiters, as described above. However, developing countries often deal with additional internal issues such as a limited pool of skilled personnel or limited financial resources. For example, difficulties arose in Armenia in 2006, when the Constitutional Court ruled on a conflict of interest claim pertaining to the election management body and the administration of justice.126 The Armenian election code incorporates the Venice Commission guidelines of 2002, stating that the electoral commission should include at least one member from the judiciary.127 However, the Constitutional Court pointed out that as a transitional country, Armenia suffers from a dearth of judges that can adjudicate even trivial matters. Thus, if some judges are appointed to administrative roles as members of the electoral commissions, they must also serve other judicial functions. The Court recognized that serving both functions would reduce the impartiality of such a commission, as the administrative and judicial roles could easily come into conflict. This case stressed the challenges that can arise for developing countries attempting to achieve compliance with international standards, and the unfortunate reality that more stringent guidelines that enforce the principle of impartiality may not always be possible to imple Advisory Opinion on the Compliance of Article 35.1.3, Second Sentence, Article 35.1.4, and Article 36.1 of the Armenian Electoral Code with the Armenian Constitution, (2006) D.C.C. 664 (Const. Ct. Arm.) (“[T]he role of impartial and independent electoral commissions is vital, but [] in ’transitional countries’ impartial judicial power is also of pivotal importance. This is why Article 98 of the Constitution prevents judges from holding any office which is not relevant to his official duties. Including judges in electoral commissions, as prescribed by the Electoral Code, is at odds with the administration of justice, with the independence of the judiciary, increases the possibility of conflicts of interest, and undermines the impartiality of judges and courts when resolving electoral disputes.”), headnotes available at http:// www.concourt.am/english/decisions/common/doc/english_codices/664.htm. 127 The Armenian Electoral Code requires the appointment of one judge within the electoral commission. Electoral Code, arts. 35, 36 (2005) (Arm.), available at http://www.venice.coe. int/docs/2007/CDL-EL(2007)010-e.pdf. 126 46