Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections language is mirrored by almost all major international legal documents. Although they may use different terms, many regional human rights systems provide individuals with similar rights.204 The Inter-American Court of Human Rights provides a strong example of the right to an effective remedy and its different components. In Miyagawa v. Peru, the Court heard a claim concerning a violation of Articles 23 and 25 of the American Convention.205 Specifically, the applicant alleged that the National Elections Board arbitrarily and illegally deprived her of her right to stand for an election as an independent candidate, and further that this violation led to the denial of the right to vote for hundreds of thousands of Peruvian citizens. In its ruling, the Court reinforced the importance of an adequate remedy, holding that the obligation of the state is not limited to the mere existence of courts and tribunals or the possibility of accessing the court, but must instead provide a “real possibility to file a remedy,” an opinion that addressed the merits of the case and the judicial authority to restore the enjoyment of rights at issue.206 Regional or international human rights courts can hear electoral complaints and provide effective remedies to challengers after the exhaustion of all available and effective remedies at the domestic level. In Petkov v. Bulgaria, the ECtHR interpreted the right to an effective remedy and affirmed that “the scope of the Contracting States’ obligations varies depending on the nature of the applicant’s complaint.”207 The Court added that the remedy must be “effective in practice as well as in law in the sense either of preventing the alleged violation or remedying the impugned state of affairs, or of providing adequate redress for any violation that has already Article 25 of the American Convention provIdes everyone “the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal . . . and the competent authorities shall enforce such remedies when granted.” American Convention, supra note 14, art. 25. Article 13 of the European convention refers to the right to “an effective remedy before a national authority.” European Convention, supra note 26, art. 13. 205 Miyagawa v. Peru, Case 11.428 Inter-Am. Comm’n H.R., Report No. 119/99, OEA/Ser.L./V/ II.106, doc. 3 rev. ¶ 1262 (1999), available at http://www1.umn.edu/humanrts/cases/119-99. html. 206 The claim evoked the constitutionality of political rights and more specifically, the right to register as an independent candidate. Castañeda Gutman v. Mexico, Case 12.535, InterAm. Comm’n H.R., Report No. 113/06, ¶¶ 92, 140 (2008). 207 Petkov v. Bulgaria, Eur. Ct. H.R., App. nos. 77568/01, 178/02 and 505/02, Judgment of 11 June 2009, ¶ 74. 204 68