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"The Court reiterates that it has interpreted Article 3 of Protocol No. 1 as containing certain positive obligations of a procedural character, in particular requiring the existence of a “domestic system for effective examination of individual complaints and appeals in matters concerning electoral rights” (see Namat Aliyev v. Azerbaijan, no. 18705/06, § 81 et seq., 8 April 2010; see also the recommendation of the Venice Commission in the Explanatory Report to the Code of Good Practice in Electoral Methods concerning creation of an effective system of electoral appeals, paragraph 51 above). The Court refers to its earlier findings under Article 13 in this case that the applicants had at their disposal at least one effective remedy. The Court does not need to define in abstracto the exact relation between the State’s positive obligation under Article 13 and its procedural obligations under Article 3 of Protocol No. 1. "
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CoE (ECHR): Case of the Communist Party of Russia and Others v. Russia, para. 124

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Case of the Communist Party of Russia and Others v. Russia

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