Chapter 1: International Standards Court of Ghana recognized “the crucial question of the timing for making referrals to the High Court.”155 In Republic v. High Court, the Court held that “whenever there are no disputed facts to be resolved, for either a determination of whether or not a genuine question for interpretation has arisen, or for a formulation of the issues for referral, it [the referral] ought to be made without delay.”156 Courts must be held to a timeline that addresses the unique importance of timing in election complaints. Courts are not the only entities that acknowledge the importance of timing in electoral matters. Whether electoral complaints are solved by the judiciary or by an independent entity, the electoral law should provide for expeditious proceedings. Indeed, the Independent High Electoral Commission in Iraq, in Article 7, § 2 of its electoral law, states that “the Board shall promulgate necessary procedures for resolving such disputes, including procedures for filing a claim and conducting expedited factual inquiries, and may delegate jurisdiction to resolve disputes in the first instance to the Electoral Administration.”157 The judge or arbiter should then make all necessary efforts to settle the issue as quickly as possible. Scholars and non-governmental organizations continually stress the importance of expedited proceedings in electoral complaint adjudication.158 In 1994, the National Democratic Institute drafted recommendations on an electoral Republic v. High Court (Fast Track Division) Accra, [2006], S.C.G.L.R. 514, 539 (Ghana), available at http://www.judicial.gov.gh/c.i/content/EX percent20PARTE percent20ELE percent20COMMI percent20 percent20(METTLE-NUNOO.htm. 156 Id. 157 Independent High Electoral Commission of Iraq, Coalition Provisional Authority, Order No. 92, art. 7, § 2, May 31, 2004, available at http://www.ihec.iq/downloads/cpa_92_ieci_en.pdf. 158 Robert Dahl, IFES legal policy advisor, affirmed that “almost all democracies provIde for some form of judicial review of election related matters, either through the normal judicial hierarchy or expedited review by higher courts.” Robert A. Dahl, IFES, Electoral Complaints Adjudication and Dispute Resolution: Key Issues and GuIding Principles 3 (2008), available at http://210.69.23.129/download/d_6/IFES.doc. The Carter Center addressed the same issue following Ghana's PresIdential Elections in 2008, finding that “[t]he major obstacle regarding electoral dispute resolution in Ghana has been the low confIdence that people have in the ability of the courts to provIde timely responses to election-related complaints.” Preliminary Report, Carter Center Finds Ghana's PresIdential Run-off Elections Credible and Peaceful, The Carter Center (Dec. 30, 2008), http://www.cartercenter.org/news/pr/ ghana_prelim_123008.html [hereinafter, Carter Center Ghana Report]. But Ghana seems to have understood the importance of timing. Indeed, the E.U. election observation mission in Ghana acknowledged that “[a]lthough one of the shortcomings of the appeal system is the lack of deadlines imposed by law,” the Chief Justice prioritized “election-related cases insIde the courts.” E.U. Election Observation Mission, Final Report: PresIdential and Parliamentary Elections 2008 Ghana, at 27 (2009). The Carter Center added that for example the judiciary established special branches to hear cases, and approved “weekend work hours for the courts.”Carter Center Ghana Report, supra. 155 55