accreditations since the OAC is only a recommending body. However, the Commission must indicate in writing within 48 hours of receipt of the recommendations that it objects to any of them. However, it may be useful to get clarity on the nature of the ‘recommendations’ that the OAC is entitled to issue – are they recommended names of accredited observers or do they include a list of applicants that have been rejected? The risk here is that whilst it appears that the Commission is the ultimate deciding body it is not clear that it has the power to revisit the applications that have been rejected. If it does not have sight of these rejects, then its role as the ultimate decision-making busy is in reality very limited, with greater power resting in the OAC. • Also of concern is that there is no provision for the rejected applicants to seek recourse against the decision of the OAC. This may lie with the courts under the normal laws of the country but it would be lengthy and time-consuming, especially given the urgency of such matters in periods leading up to elections. It would be better to have clear provisions enabling an appeal process against the decision of the OAC, in particular given that the Ministers have the right of objection against specific applicants whereas there is no provision for hearing the side of the applicants in such circumstances. • Overall, ZESN notes that the Observers’ Accreditation Committee (“OAC”) which is responsible for the accreditation of both local and foreign election observers is comprised of a high number of political nominees. If the aim was to reduce political interference in the accreditation of observers, this is not fully achieved given the domination of political nominees. ZESN recommends that the composition of the OAC be exclusive decision of the body charged with running elections, i.e. the Commission. Ministers, who are usually also contestants in an election, should have no role in the accreditation of observers since all other candidates in an election who are not Ministers do not have the same facility. Likewise, it is not necessary to give power to the Ministers of Government to invite persons to apply for accreditation to observe elections. Indeed, on the same basis, Ministers’ right of objection against certain observers is not justified given that other contestants or parties with an interest in an election do not have the same 23