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Dear Chairman Prach Chan,

I am writing on behalf Human Rights Watch to inquire about irregularities found in official “1102” forms, recording election results from Phnom Penh polling stations in the June 2022 commune elections.

Human Rights Watch is an independent international human rights organization that conducts research and advocacy on human rights issues in over 100 countries around the world. We have been reporting on the situation in Cambodia for more than three decades. Our work is considered consistently credible by governments, United Nations agencies, international organizations, and media outlets around the world.

Human Rights Watch recently conducted a systematic analysis of all available “1102” forms recording election results in Phnom Penh during the June 2022 commune elections, and found numerous significant irregularities that raise serious concerns. These irregularities suggest that election fraud and vote tampering may have occurred and that ballots across Phnom Penh were not properly counted and reported.

Our analysis relies on official polling station result forms published online by the National Election Committee (NEC) several days after the June 5, 2022 vote. In that election, there were 23,602 polling stations across the country, including 2,197 stations in Phnom Penh. The NEC required each station to submit a results form, called an “1102 form,” after counting the ballots at that station on Election Day. The NEC later published those forms online and these served as the basis for official vote counts.

Human Rights Watch reviewed all available forms from polling stations in Phnom Penh for several reasons. First, the city’s voting results in 2022 were markedly different from past elections. For example, the Cambodian People’s Party (CPP) won 33% of polling stations in the capital in the 2017 commune elections but in the 2022 election, the CPP reportedly won 99.9% of the polling stations in Phnom Penh. Moreover, in the 2022 election, the Candlelight Party (CLP) reported widespread intimidation of their party polling station observers in Phnom Penh that severely hampered their ability to observe the vote casting and counting. During the ballot counting in 2022, local independent monitors and volunteers reported in multiple polling locations in Phnom Penh that officials shuttered windows and conducted the vote counting processes behind closed doors. This practice of limiting observation of the vote counting was not widely reported in previous elections.

In our review of the “1102” forms from 2,155 polling stations in Phnom Penh, we found the following irregularities:

  • Name of contesting party or vote count was not recorded on form – 3% of stations.
    • In approximately 3% of the polling stations, the “1102” form published by the NEC is missing the names of contesting parties, the number of votes they received, or both. In many cases, these forms are actually signed by observers despite the clear irregularities. The NEC apparently either not did notice these irregularities or chose not to investigate why observer(s) signed a “1102” form that did not contain all necessary information, including most crucially the name of each contesting party and the number of votes each received. It is unclear how the NEC tabulated results from these polling stations.
  • Number of votes do not correctly add up on the “1102” form – 19% of stations.
    • The number of votes listed on the “1102” form does not correctly add up in the case of 19% of the polling stations examined. The forms are designed to repeat certain numbers, such as the number of ballots cast, to guard against manipulation and tampering. This occurred even though there are formulas/instructions printed on each “1102” form to ensure these numbers add up, such as “Number of ballots in box = Number of ballots cast = Total ballots – (Unusable ballots + remaining ballots).”

      In many cases, the numbers that did not add up appear to be attributable to incorrectly listing “Total ballots” as “Ballots cast,” or “Spoiled/invalid ballots” as “Unusable ballots.” In other cases, the error in recording the votes was unclear. But in all cases, numbers that did not add up meant that the station’s ballots were not properly accounted for. Yet despite this fundamental problem, the forms were still certified by the polling station staff and submitted to the NEC.
  • Corrections, correction fluid, or crossed-out sections on “1102” forms – 15% of stations.
    • Correction fluid or crossed-out content is visible on 15% of “1102” forms. While tolerance for a certain number of mistakes is reasonable, the 15% error rate is notable. In many cases, officials made the corrections in multiple places on the form. Many of the corrections were made in critically important areas such as the party/vote count sections or the total ballot sections. Officials conducted the voting in polling stations, but the actual tallying of votes was often written on separate papers, with the final results then being copied onto the “1102” forms. For this reason, uncovering that there were significant corrections on the “1102” forms in the vote count area raises serious concerns.
  • “1102” form missing other numbers – 3.5% of stations.
    • In “1102” forms from 3.5% of polling stations, there are numbers other than vote counts that were missing from the form. The missing numbers were most often the breakdown of valid votes, spoiled/invalid votes, and total votes underneath the vote counts. In some cases, this meant that there appeared to be no spoiled votes, which is unlikely when hundreds of ballots are cast per polling station.
  • Only CPP-aligned observers in polling station – 44% of total stations.
    • About 44% of the polling stations in Phnom Penh only had party observers from the CPP and/or non-party observers from CPP-led groups. Across the country, 88% of non-party observers came from government aligned groups such as the Union of Youth Federations of Cambodia, led by Prime Minister Hun Sen’s son Hun Many, or Cambodian Women for Peace and Development, led by Deputy Prime Minister Men Sam An. Observers documented a campaign of intimidation and harassment across the country against people registered as CLP election observers. Non-CPP observers are crucial to ensuring that votes are appropriately counted, and results are not tampered with in polling stations.

Human Rights Watch has documented violent attacks and persecution against the political opposition in March and April 2023. Media reports also have exposed other instances of intimidation, harassment, and selective prosecution in the courts to prevent or deter individuals from organizing or exercising their right to participate in politics.

Human Rights Watch seeks written information that will help us understand what happened and reflect the NEC’s perspective when we publish our findings on this matter. Our questions are attached as an annex to this letter.

For your reference, please also find attached more details of our findings with sample 1102 forms included.

Thank you for your consideration of this important matter. We look forward to hearing from you by June 26, 2023.


Elaine Pearson
Executive Director, Asia Division
Human Rights Watch

Annex I

1. Can the NEC please explain how the following irregularities occurred during tabulation of votes on the 1102 forms?

a. A contesting party or vote count was not recorded on form 1102 – 3% of total stations. How then did the NEC calculate these forms?
b. Numbers do not correctly add up on form 1102 – 19% of total stations. Did the NEC seek clarifications for these discrepancies, and if so, what was the result?
c. Corrections, correction fluid or cross-outs on form 1102 – 15% of total stations. Did the NEC investigate these changes, and if so, what was the result?
d. Form 1102 is missing other numbers – 3.5% of total stations. Did the NEC seek clarifications for these discrepancies, and if so, what was the result?
e. Only CPP-aligned election observers were present in 44% of the total number of polling stations. Can you comment on reports of pre-election intimidation of CLP-aligned election observers and how this might have influenced efforts towards achieving a free and fair electoral process? Did the NEC take any steps to communicate concerns about the reported environment of harassment and intimidation to relevant authorities?

2. Did the NEC investigate the above-mentioned irregularities in Phnom Penh election stations during the June 2022 commune elections? If so, what were the results of the NEC’s investigations?

3. What plans does the NEC have in place to prevent similar irregularities from reoccurring during the upcoming July 2023 national elections?

4. What actions does the NEC plan to implement to address the instances of intimidation and physical attacks reported by the Candlelight Party that Human Rights Watch has documented, and that media outlets have reported?

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