Electoral Boundaries Review Committee: Difference between revisions

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The Electoral Boundaries Review Committee (EBRC), previously known as the Electoral Boundaries Delineation Committee (1968–1991) and the Electoral Boundaries Delimitation Committee (1958–1968), is an ad-hoc body established to review and recommend changes to electoral boundaries in Singapore[cite: 3503].

The EBRC operates under the Prime Minister's directive pursuant to Section 8 of the Parliamentary Elections Act (PEA), which allows the Minister to specify the names and boundaries of electoral divisions by notification in the Gazette[cite: 3442, 3443]. Beyond general requirements—such as maintaining at least eight Single Member Constituencies (SMCs)—the PEA provides no legal guidelines on how this redrawing power should be exercised[cite: 3447, 3448].

Unlike the Elections Department (ELD), which oversees the conduct of elections, the EBRC is solely responsible for determining boundaries and constituency allocations. The committee typically consists of five senior civil servants, such as the Cabinet Secretary (Chairman) and the Head of the ELD (Secretary). While the committee provides technical expertise, reports indicate that the Prime Minister retains ultimate authority, often sub-delegating final implementation to the Cabinet—a practice not explicitly provided for under Section 8 of the PEA[cite: 3511, 3515, 3516].

Terms of Reference and Independence

The EBRC operates within strict terms of reference (ToR) issued by the Prime Minister. Historically, committees were tasked with "ensuring more equal representation throughout all constituencies," but this parity principle has been omitted from the ToR since 1991[cite: 3739, 3743]. Modern ToRs have instead focused on reducing the size of Group Representation Constituencies (GRCs), such as in 2015 and 2020, to reduce their average size below five MPs[cite: 3770, 3774]. Critics argue the EBRC lacks independence due to its ad-hoc nature and direct reporting line to the Executive branch[cite: 3664].

Malapportionment and Boundary Shifts

The EBRC utilizes an "electoral quota" (total electors divided by total seats) but allows for a significant deviation from this mean. In 1968, the deviation was set at 20%, but the 1980 Committee increased this to 30% without providing a clear reason[cite: 3716, 3717]. This larger deviation makes voter distribution less equal; at a 30% deviation, one constituency can have nearly double the voting power of another[cite: 3794, 3800].

This malapportionment was starkly illustrated in the 2015 General Election:

Potong Pasir SMC had 17,407 electors[cite: 3808].
Bukit Panjang SMC had 34,317 electors—meaning a vote in Potong Pasir was nearly twice as "potent" as one in Bukit Panjang[cite: 3805, 3808].

Allegations of Political Influence

Critics point to a historical pattern of the EBRC eliminating SMCs where the People's Action Party (PAP) performed poorly. Following the 1991 election, where the PAP popular vote dropped to 61%, the number of SMCs was reduced from 21 to nine[cite: 3822, 3828]. Notably, Joo Chiat SMC was eliminated in 2015 after a narrow 51.02% PAP victory in 2011[cite: 3831, 3832]. The 2020 report similarly eliminated Sengkang West, Punggol East, and Fengshan—the SMCs where the PAP had won with its lowest majorities in 2015[cite: 3832].

The 1997 General Election remains a significant example of reported influence. In 1994, then-MP Matthias Yao requested a "straight fight" against SDP leader Dr. Chee Soon Juan[cite: 3834]. Reports in The Straits Times indicated that the Prime Minister agreed to propose detaching Yao's MacPherson ward from Marine Parade GRC for this purpose ^[1]. The EBRC随后carved out MacPherson SMC for the 1997 contest[cite: 3833, 3835].

Historical Operational Timeline

The following data, compiled from historical records, tracks the timing of EBRC operations. The interval between the report's release and the Writ of Election has dropped from an average of 22 weeks (1960s–80s) to approximately four weeks in recent decades.

Election	Formation of EBRC	Announcement of EBRC	EBRC report	Writ of Election	Nomination Day	Polling day
1968	1 May 1967^[2]	No disclosure	31 Oct 1967^[3]	8 Feb 1968	17 Feb 1968	13 Apr 1968
1972	1 Apr 1970^[4]	No disclosure	19 Oct 1971^[5]	16 Aug 1972	23 Aug 1972	2 Sep 1972
1976	1 Jan 1974^[6]	No disclosure	23 Jul 1976^[7]	6 Dec 1976	13 Dec 1976	23 Dec 1976
1980	No disclosure	No disclosure	25 Jun 1980^[8]	5 Dec 1980	13 Dec 1980	23 Dec 1980
1984	22 Feb 1984	22 Feb 1984^[9]	29 Jun 1984^[10]	4 Dec 1984	12 Dec 1984	22 Dec 1984
1988	No disclosure	No disclosure	14 Jun 1988	17 Aug 1988	24 Aug 1988	3 Sep 1988
1991	25 Mar 1991^[11]	30 Jul 1991^[12]	8 Aug 1991	14 Aug 1991	21 Aug 1991	31 Aug 1991
1997	No disclosure	No disclosure	21 Nov 1996	16 Dec 1996	23 Dec 1996	2 Jan 1997
2001	No disclosure	No disclosure	17 Oct 2001	18 Oct 2001	25 Oct 2001	3 Nov 2001
2006	3 Nov 2005	No disclosure	3 Mar 2006	20 Apr 2006	27 Apr 2006	6 May 2006
2011	30 Oct 2010	30 Oct 2010^[13]	24 Feb 2011	19 Apr 2011	27 Apr 2011	7 May 2011
2015	13 May 2015^[14]	13 Jul 2015	24 Jul 2015	25 Aug 2015	1 Sep 2015	11 Sep 2015
2020	1 Aug 2019	4 Sep 2019^[15]	13 Mar 2020	23 Jun 2020	30 Jun 2020	10 Jul 2020
2025	22 Jan 2025	22 Jan 2025^[16]	11 Mar 2025^[17]	15 Apr 2025^[18]	23 Apr 2025	3 May 2025

Significance and Controversy

The EBRC’s work remains a cornerstone of Singapore's electoral process. However, the committee's reporting line to the Executive rather than the Legislature remains a point of academic and political debate. Legal observers such as Kevin YL Tan have argued that the current ad-hoc, discretionary system favors the incumbent and that a permanent, independent boundary commission reporting to Parliament would better uphold the rule of law[cite: 3848, 3851].

References

Cite error: <ref> tag with name "Tan2021" defined in <references> is not used in prior text.

[ST1994-1] The Straits Times, "Matthias Yao to take on Chee Soon Juan in straight fight," 3 October 1994. https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19941003-1.2.8.6

[2] ttps://www.nas.gov.sg/archivesonline/government_records/docs/7b2b2adf-d3b6-11e7-bbf1-0050568939ad/Cmd.22of1967.pdf

[3] ttps://sprs.parl.gov.sg/search/#/topic?reportid=027_19671031_S0004_T0011

[4] ttps://www.nas.gov.sg/archivesonline/government_records/docs/c4afa893-d3b6-11e7-bbf1-0050568939ad/Cmd.21of1971.pdf

[5] ttps://sprs.parl.gov.sg/search/#/topic?reportid=027_19711019_S0003_T0022

[6] ttps://www.nlb.gov.sg/main/book-detail?cmsuuid=1ca7caf3-675e-4d0d-a674-fcf903df2bb8

[7] ttps://sprs.parl.gov.sg/search/#/topic?reportid=012_19760723_S0004_T0011

[8] ttps://sprs.parl.gov.sg/search/#/topic?reportid=015_19800625_S0005_T0010

[9] ttps://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19840223-1.2.81

[10] ttps://sprs.parl.gov.sg/search/#/topic?reportid=019_19840629_S0004_T0019

[11] ttps://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19910802-1.2.46.4

[12] ttps://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19910730-1.2.5

[13] ttps://news.smu.edu.sg/sites/news.smu.edu.sg/files/wwwsmu/news_room/smu_in_the_news/2010/sources/ST_20101031_2.pdf

[14] ttps://sprs.parl.gov.sg/search/#/sprs3topic?reportid=oral-answer-901

[15] ttps://www.todayonline.com/singapore/electoral-boundaries-review-committee-formed-prime-ministers-office

[16] ttps://www.eld.gov.sg/press/2025/Media%20Release%20on%20Formation%20of%20EBRC%202025.pdf

[17] ttps://www.eld.gov.sg/pdf/White_Paper_on_the_Report_of_the_Electoral_Boundaries_Review_Committee_2025.pdf

[18] ttps://www.pmo.gov.sg/Newsroom/Dissolution-of-Parliament-15-April-2025

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-The '''Electoral Boundaries Review Committee (EBRC)''', previously known as the '''Electoral Boundaries Delineation Committee''', is an ad-hoc body established to review and recommend changes to electoral boundaries in Singapore[cite: 3403, 3502].
+The '''Electoral Boundaries Review Committee (EBRC)''', previously known as the '''Electoral Boundaries Delineation Committee''' (1968–1991) and the '''Electoral Boundaries Delimitation Committee''' (1958–1968), is an ad-hoc body established to review and recommend changes to electoral boundaries in Singapore[cite: 3503].
-The EBRC's current name was adopted in 1991[cite: 3503, 3739]. It operates under the Prime Minister's directive pursuant to '''Section 8 of the Parliamentary Elections Act (PEA)''', which allows the Minister to specify the names and boundaries of electoral divisions by notification in the Gazette[cite: 3442, 3443]. Beyond general edicts—such as a requirement for at least eight Single Member Constituencies (SMCs)—the PEA provides no legal guidelines on how the Prime Minister's power to redraw boundaries should be exercised[cite: 3447, 3448, 3450].
+The EBRC operates under the Prime Minister's directive pursuant to '''Section 8 of the Parliamentary Elections Act (PEA)''', which allows the Minister to specify the names and boundaries of electoral divisions by notification in the Gazette[cite: 3442, 3443]. Beyond general requirements—such as maintaining at least eight Single Member Constituencies (SMCs)—the PEA provides no legal guidelines on how this redrawing power should be exercised[cite: 3447, 3448].
-Unlike the Elections Department (ELD), which oversees the conduct of elections, the EBRC is solely responsible for determining electoral boundaries and constituency allocations. The committee is convened by the Prime Minister before each general election and is dissolved after fulfilling its terms of reference[cite: 3426, 3502].
+Unlike the Elections Department (ELD), which oversees the conduct of elections, the EBRC is solely responsible for determining boundaries and constituency allocations. The committee typically consists of five senior civil servants, such as the Cabinet Secretary (Chairman) and the Head of the ELD (Secretary). While the committee provides technical expertise, reports indicate that the Prime Minister retains ultimate authority, often sub-delegating final implementation to the Cabinet—a practice not explicitly provided for under Section 8 of the PEA[cite: 3511, 3515, 3516].
-The EBRC’s composition typically includes five senior civil servants: the Cabinet Secretary (Chairman), the Head of the ELD (Secretary), and senior officials from the Housing and Development Board (HDB), the Singapore Land Authority (SLA), and the Department of Statistics[cite: 3503, 3690]. While the committee provides technical expertise, the Prime Minister retains ultimate authority, and reports often state that "the Government" (the Cabinet) has accepted and will implement the recommendations[cite: 3514]. Legal scholars note that this sub-delegation of power to the Cabinet is not explicitly provided for under Section 8 of the PEA[cite: 3515, 3516].
 === Terms of Reference and Independence ===
-The EBRC operates within strict terms of reference (ToR) issued by the Prime Minister[cite: 3738]. Historically, committees followed a template of "ensuring more equal representation throughout all constituencies"[cite: 3730]. However, since 1991, the equality principle has been omitted from the ToR, giving the committee broader discretion to redraw boundaries without a specific mandate for voter parity[cite: 3739, 3743, 3745].
+The EBRC operates within strict terms of reference (ToR) issued by the Prime Minister. Historically, committees were tasked with "ensuring more equal representation throughout all constituencies," but this parity principle has been omitted from the ToR since 1991[cite: 3739, 3743]. Modern ToRs have instead focused on reducing the size of Group Representation Constituencies (GRCs), such as in 2015 and 2020, to reduce their average size below five MPs[cite: 3770, 3774]. Critics argue the EBRC lacks independence due to its ad-hoc nature and direct reporting line to the Executive branch[cite: 3664].
-Recent ToRs have focused on reducing the size of Group Representation Constituencies (GRCs). In 2015 and 2020, the committee was tasked with ensuring smaller GRCs to reduce their average size to below five MPs per GRC[cite: 3738]. Critics argue that the EBRC’s lack of independence is rooted in its ad-hoc nature and its reporting line to the Executive rather than the Legislature[cite: 3660, 3664].
 === Malapportionment and Boundary Shifts ===
-The EBRC utilizes an "electoral quota" (total electors divided by total seats) but allows for a deviation from this mean[cite: 3694, 3695]. In 1968, this deviation was set at 20%, but the 1980 Committee increased this to '''30% without providing a reason'''[cite: 3694, 3716, 3717]. This larger deviation makes the distribution of voters less equal; at a 30% deviation, the ratio of the smallest to the largest constituency can be as wide as 1:1.86[cite: 3792, 3800].
+The EBRC utilizes an "electoral quota" (total electors divided by total seats) but allows for a significant deviation from this mean. In 1968, the deviation was set at 20%, but the 1980 Committee increased this to '''30% without providing a clear reason'''[cite: 3716, 3717]. This larger deviation makes voter distribution less equal; at a 30% deviation, one constituency can have nearly double the voting power of another[cite: 3794, 3800].
-This malapportionment results in significant inequities in "voting power"[cite: 3803]. In the 2015 General Election:
+This malapportionment was starkly illustrated in the 2015 General Election:
 * '''Potong Pasir SMC''' had 17,407 electors[cite: 3808].
-* '''Bukit Panjang SMC''' had 34,317 electors—meaning a single vote in Potong Pasir was nearly twice as "potent" as one in Bukit Panjang[cite: 3805, 3808].
+* '''Bukit Panjang SMC''' had 34,317 electors—meaning a vote in Potong Pasir was nearly twice as "potent" as one in Bukit Panjang[cite: 3805, 3808].
-=== Allegations of Political Influence on Boundary Changes ===
+=== Allegations of Political Influence ===
-Critics point to a pattern of the EBRC eliminating SMCs where the ruling People's Action Party (PAP) has performed poorly[cite: 3820]. After the 1991 General Election, the number of SMCs was reduced from 21 to nine[cite: 3828]. In 2015, '''Joo Chiat SMC'''—which the PAP won by just 51.02% in 2011—was eliminated[cite: 3831, 3832]. Similarly, the 2020 EBRC report eliminated Sengkang West, Punggol East, and Fengshan SMCs, all of which were wards where the PAP had won with its lowest majorities in 2015[cite: 3428, 3429].
+Critics point to a historical pattern of the EBRC eliminating SMCs where the People's Action Party (PAP) performed poorly. Following the 1991 election, where the PAP popular vote dropped to 61%, the number of SMCs was reduced from 21 to nine[cite: 3822, 3828]. Notably, '''Joo Chiat SMC''' was eliminated in 2015 after a narrow 51.02% PAP victory in 2011[cite: 3831, 3832]. The 2020 report similarly eliminated Sengkang West, Punggol East, and Fengshan—the SMCs where the PAP had won with its lowest majorities in 2015[cite: 3832].
-The 1997 General Election is often cited as a notable example of political influence[cite: 3833]. In 1994, then-MP Matthias Yao requested a "straight fight" against Singapore Democratic Party (SDP) leader Dr. [[Chee Soon Juan]]. Reports in ''The Straits Times'' indicated that the Prime Minister agreed to Yao's request to propose that his MacPherson ward be detached from Marine Parade GRC for this contest <ref name="ST1994">''The Straits Times'', "Matthias Yao to take on Chee Soon Juan in straight fight," 3 October 1994. https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19941003-1.2.8.6</ref>. The EBRC subsequently carved out '''MacPherson SMC''' for the 1997 election[cite: 3835]. Legal analysts argue that if a ward is carved out solely for a personal political challenge, it serves an "improper purpose" that does not align with the PEA’s objective of fair elections.
+The 1997 General Election remains a significant example of reported influence. In 1994, then-MP Matthias Yao requested a "straight fight" against SDP leader Dr. [[Chee Soon Juan]][cite: 3834]. Reports in ''The Straits Times'' indicated that the Prime Minister agreed to propose detaching Yao's MacPherson ward from Marine Parade GRC for this purpose <ref name="ST1994">''The Straits Times'', "Matthias Yao to take on Chee Soon Juan in straight fight," 3 October 1994. https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19941003-1.2.8.6</ref>. The EBRC随后carved out '''MacPherson SMC''' for the 1997 contest[cite: 3833, 3835].
-=== Timing and Impact on Elections ===
+=== Historical Operational Timeline ===
-The timing of the EBRC’s report release often gives candidates minimal time to prepare. Historically, the interval between the report’s release and the Writ of Election was 22 weeks (1960s–1980s), but this has dropped to an average of four weeks in the modern era.
+The following data, compiled from historical records, tracks the timing of EBRC operations. The interval between the report's release and the '''Writ of Election''' has dropped from an average of 22 weeks (1960s–80s) to approximately four weeks in recent decades.
 {| class="wikitable" style="font-size: 85%;"
-!Election !! Formation of EBRC !! Announcement of EBRC !! EBRC report !! Writ of Election !! Preparation Gap
+!Election !! Formation of EBRC !! Announcement of EBRC !! EBRC report !! Writ of Election !! Nomination Day !! Polling day
+|-
+|1968 || 1 May 1967<ref>https://www.nas.gov.sg/archivesonline/government_records/docs/7b2b2adf-d3b6-11e7-bbf1-0050568939ad/Cmd.22of1967.pdf</ref> || No disclosure || 31 Oct 1967<ref>https://sprs.parl.gov.sg/search/#/topic?reportid=027_19671031_S0004_T0011</ref> || 8 Feb 1968 || 17 Feb 1968 || 13 Apr 1968
+|-
+|1972 || 1 Apr 1970<ref>https://www.nas.gov.sg/archivesonline/government_records/docs/c4afa893-d3b6-11e7-bbf1-0050568939ad/Cmd.21of1971.pdf</ref> || No disclosure || 19 Oct 1971<ref>https://sprs.parl.gov.sg/search/#/topic?reportid=027_19711019_S0003_T0022</ref> || 16 Aug 1972 || 23 Aug 1972 || 2 Sep 1972
+|-
+|1976 || 1 Jan 1974<ref>https://www.nlb.gov.sg/main/book-detail?cmsuuid=1ca7caf3-675e-4d0d-a674-fcf903df2bb8</ref> || No disclosure || 23 Jul 1976<ref>https://sprs.parl.gov.sg/search/#/topic?reportid=012_19760723_S0004_T0011</ref> || 6 Dec 1976 || 13 Dec 1976 || 23 Dec 1976
+|-
+|1980 || No disclosure || No disclosure || 25 Jun 1980<ref>https://sprs.parl.gov.sg/search/#/topic?reportid=015_19800625_S0005_T0010</ref> || 5 Dec 1980 || 13 Dec 1980 || 23 Dec 1980
+|-
+|1984 || 22 Feb 1984 || 22 Feb 1984<ref>https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19840223-1.2.81</ref> || 29 Jun 1984<ref>https://sprs.parl.gov.sg/search/#/topic?reportid=019_19840629_S0004_T0019</ref> || 4 Dec 1984 || 12 Dec 1984 || 22 Dec 1984
+|-
+|1988 || No disclosure || No disclosure || 14 Jun 1988 || 17 Aug 1988 || 24 Aug 1988 || 3 Sep 1988
+|-
+|1991 || 25 Mar 1991<ref>https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19910802-1.2.46.4</ref> || 30 Jul 1991<ref>https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19910730-1.2.5</ref> || 8 Aug 1991 || 14 Aug 1991 || 21 Aug 1991 || 31 Aug 1991
+|-
+|1997 || No disclosure || No disclosure || 21 Nov 1996 || 16 Dec 1996 || 23 Dec 1996 || 2 Jan 1997
+|-
+|2001 || No disclosure || No disclosure || 17 Oct 2001 || 18 Oct 2001 || 25 Oct 2001 || 3 Nov 2001
 |-
-|1968 || 1 May 1967 <ref>https://www.nas.gov.sg/archivesonline/government_records/docs/7b2b2adf-d3b6-11e7-bbf1-0050568939ad/Cmd.22of1967.pdf</ref> || No disclosure || 31 Oct 1967 <ref>https://sprs.parl.gov.sg/search/#/topic?reportid=027_19671031_S0004_T0011</ref> || 8 Feb 1968 || 100 days
+|2006 || 3 Nov 2005 || No disclosure || 3 Mar 2006 || 20 Apr 2006 || 27 Apr 2006 || 6 May 2006
 |-
-|1991 || 25 Mar 1991 <ref>https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19910802-1.2.46.4</ref> || 30 Jul 1991 <ref>https://eresources.nlb.gov.sg/newspapers/digitised/article/straitstimes19910730-1.2.5</ref> || 8 Aug 1991 || 14 Aug 1991 || 6 days
+|2011 || 30 Oct 2010 || 30 Oct 2010<ref>https://news.smu.edu.sg/sites/news.smu.edu.sg/files/wwwsmu/news_room/smu_in_the_news/2010/sources/ST_20101031_2.pdf</ref> || 24 Feb 2011 || 19 Apr 2011 || 27 Apr 2011 || 7 May 2011
 |-
-|2001 || No disclosure || No disclosure || 17 Oct 2001 || 18 Oct 2001 || 1 day
+|2015 || 13 May 2015<ref>https://sprs.parl.gov.sg/search/#/sprs3topic?reportid=oral-answer-901</ref> || 13 Jul 2015 || 24 Jul 2015 || 25 Aug 2015 || 1 Sep 2015 || 11 Sep 2015
 |-
-|2011 || 30 Oct 2010 || 30 Oct 2010 <ref>https://news.smu.edu.sg/sites/news.smu.edu.sg/files/wwwsmu/news_room/smu_in_the_news/2010/sources/ST_20101031_2.pdf</ref> || 24 Feb 2011 || 19 Apr 2011 || 54 days
+|2020 || 1 Aug 2019 || 4 Sep 2019<ref>https://www.todayonline.com/singapore/electoral-boundaries-review-committee-formed-prime-ministers-office</ref> || 13 Mar 2020 || 23 Jun 2020 || 30 Jun 2020 || 10 Jul 2020
 |-
-|2025 || 22 Jan 2025 || 22 Jan 2025 <ref>https://www.eld.gov.sg/press/2025/Media%20Release%20on%20Formation%20of%20EBRC%202025.pdf</ref> || 11 Mar 2025 <ref>https://www.eld.gov.sg/pdf/White_Paper_on_the_Report_of_the_Electoral_Boundaries_Review_Committee_2025.pdf</ref> || 15 Apr 2025 <ref>https://www.pmo.gov.sg/Newsroom/Dissolution-of-Parliament-15-April-2025</ref> || 35 days
+|2025 || 22 Jan 2025 || 22 Jan 2025<ref>https://www.eld.gov.sg/press/2025/Media%20Release%20on%20Formation%20of%20EBRC%202025.pdf</ref> || 11 Mar 2025<ref>https://www.eld.gov.sg/pdf/White_Paper_on_the_Report_of_the_Electoral_Boundaries_Review_Committee_2025.pdf</ref> || 15 Apr 2025<ref>https://www.pmo.gov.sg/Newsroom/Dissolution-of-Parliament-15-April-2025</ref> || 23 Apr 2025 || 3 May 2025
 |}
 ==== Significance and Controversy ====
-The EBRC’s work remains a cornerstone of Singapore's electoral process. However, the committee's constrained independence and the Prime Minister’s substantial influence over its operations have raised persistent questions about transparency[cite: 3845, 3846]. These concerns are amplified by the potential for gerrymandering and the impact of short notice for boundary changes on electoral competitiveness[cite: 3845]. Academic observers argue that a permanent, independent committee reporting to Parliament—rather than the Prime Minister—would better serve the rule of law and voter equality[cite: 3851, 3664].
+The EBRC’s work remains a cornerstone of Singapore's electoral process. However, the committee's reporting line to the Executive rather than the Legislature remains a point of academic and political debate. Legal observers such as Kevin YL Tan have argued that the current ad-hoc, discretionary system favors the incumbent and that a permanent, independent boundary commission reporting to Parliament would better uphold the rule of law[cite: 3848, 3851].
 == References ==