Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections come of the elections before the Higher Administrative Court of Ukraine.212 Oleksandr Turchynov, who ran Tymoshenko’s campaign, “asked for a recount in more than 900 polling stations, claiming that ‘falsification’ influenced the election results.”213 In response, the head of the independent Voters Committee of Ukraine, Oleksandr Chernenko, stated that any challenge to the election should involve systemic violations that could theoretically influence the result and added that there was no proof of genuine systemic violations that would void the entire election.214 The requirement of “systemic violations” highlighted by Chernenko could limit the number of complaints and discourage frivolous claims. However, such changes or restrictions in the law should not be used to discourage challengers from bringing legitimate claims. Two weeks after the 7 February run-off elections, Prime Minister Tymoshenko conceded the presidential elections by withdrawing her legal challenge, saying that she did not believe that she would get a fair hearing and that the Court was as biased as the Central Electoral Commission. This recent example in Ukraine illustrates the difficulty of making a clear distinction between purely political allegations and legitimate and fair electoral complaints. Some candidates may refuse to accept defeat, and make frivolous and unsubstantiated charges, whereas others may have valid grounds and evidence to justify a complaint. While there are clearly difficulties in determining whether a system provides adequate remedies in response to electoral irregularities, an election complaint adjudication entity that establishes guarantees for a timely decision, a legal justification, a final decision that is no longer subject to appeal, and mandates for sanctions and penalties, will go a long way to providing an effective remedy. Peter Fedynsky, Tymoshenko Refuses to Concede Ukraine Election Defeat, VOAnews, Feb. 11, 2010, available at http://www1.voanews.com/english/news/europe/Tymoshenko-Refuses-to-Concede-Ukraine-Election-Defeat-84113287.html; see also James Marson, Ukraine Opposition to Form Coalition, Wall St. J., Feb. 12, 2010, available at http://online.wsj.com/ article/SB10001424052748703525704575060923471876374.html?mod=googlenews_wsj. 213 Daryna Krasnolutska, Timoshenko Weighs Conceding Ukraine PresIdency to Stay Premier, Business Week, Feb. 10, 2010, available at http://www.businessweek.com/news/2010-0210/timoshenko-weighs-conceding-ukraine-presIdency-to-stay-premier.html. 214 Fedynsky, supra note 212. 212 70