Electoral Matters, have spoken in favour of compulsory voting. Peter Singer, in Democracy and Disobedience, argues that compulsory voting could negate the obligation of a voter to support the outcome of the election, since voluntary participation in elections is deemed to be one of the sources of the obligation to obey the law in a democracy. In 1996 Albert Langer was jailed for three weeks on contempt charges in relation to a constitutional challenge on a legal way not to vote for either of the major parties. Chong, Davidson and Fry, writing in the journal of the right wing think tank the CIS, argue that Australian compulsory voting is disreputable, paternalistic, disadvantages smaller political parties, and allows major parties to target marginal seats and make some savings in pork-barrelling because of this targeting. Chong et al. also argue that denial is a significant aspect of the debate about compulsory voting. A counter argument to opponents of compulsory voting is that in these systems the individual still has the practical ability to abstain at the polls by voting informally if they so choose, due to the secrecy of the ballot. A spoilt vote does not count towards any political party and effectively is the same as choosing not to vote under a non-compulsory voting system. However, Singer argues that even the appearance of voluntary participation is sufficient to create an obligation to obey the law. In the 2010 Australian election, Mark Latham urged Australians to vote informally by handing in blank ballot papers for the 2010 election. He also stated that he feels it is unfair for the government to force citizens to vote if they have no opinion or threaten them into voting with a fine. An Australian Electoral Commission spokesman stated that the Commonwealth Electoral Act did not contain an explicit provision prohibiting the casting of a blank vote. How the Australian Electoral Commission arrived at this opinion is unknown; it runs contrary to the opinions of Chief Justice Sir Garfield Barwick, who wrote that voters must actually mark the ballot paper and deposit that ballot into a ballot box, and Justice Blackburn who was of the opinion that casting an invalid vote was a violation of the Act. Tim Evans, a Director of Elections Systems and Policy of the AEC, wrote in 2006 that "It is not the case, as some people have claimed, that it is only