Independent campaign groups.  The resolution ignores the possibility that negative campaigns may occur outside of a partisan context. In India [i] and Korea [ii] , grass roots campaigns without specific party or ideological ties have been used to highlight corruption among electoral candidates and legislative incumbents. These campaigns are arguably an expression of democratic political freedom, with individual citizens banding together to enforce core democratic norms. However, as the example of the Citizen’s Solidarity movement in South Korea shows, because such actions inevitably involve questioning the character and conduct of politicians running for election, they frequently fall foul of laws designed to restrict negative campaigning.  Similar problems are encountered by the professional press. Even in countries with liberal electoral and libel law regimes, the press frequently find themselves accused of political bias if they attempt to highlight mendacity or wrongdoing by a particular candidate. Unless the wrongdoing in question is particularly severe, western journalists may find themselves in the position of their Singaporean counterparts – held accountable for “electoral crimes”, libel or contempt of court by a body of law that treat political institutions as sacrosanct and denies that scrutiny of those institutions’ officer holders is necessary.  [i] “No modern-day Mahatma”. The Economist, 27 April 2011.   [ii] “Korea’s art of negative campaigning.” The Economist, 6 April 2000.