The obligations stemming from Article 1 of the ECHR and Article 3 of Protocol 1 to the ECHR cover not only the organisation, but also the conduct of such elections. If elections are organised, they must be “free and fair”. If they fail to respect the preconditions of a) respect for freedom of expression, assembly and association; b) stability of electoral legislation and its protection from political manipulation; c) procedural guarantees such as organization of elections by an impartial body, election observation, an effective system of appeal, funding and security, they fail to meet the obligation for the annexing State to secure the enjoyment of the right to free and fair elections of the population of the annexed territory. These preconditions appear difficult to meet for elections organised in an occupied territory.