Quorum Requirements
The most common failure of the participation criterion is not in the use of particular voting systems, but in simple yes or no measures that place quorum requirements. A public referendum, for example, if it required majority approval and a certain number of voters to participate in order to pass, would fail the participation criterion, as a minority of voters preferring the "no" option could cause the measure to fail by simply not voting rather than voting no. In other words, the addition of a "no" vote may make the measure more likely to pass. A referendum that required a minimum number of yes votes (not counting no votes), by contrast, would pass the participation criterion.
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