This article provides a review of the concept of student voice as it has been represented in "Educational Action Research" from the 1990s to the present day. Contextualised within an exploration of the challenges posed by educational action research that incorporates student voice in the current age of accountability as reflected and understood in academia, we explore issues of power and authority, issues of process and issues of ownership as they emerge in the literature. We note ways in which these challenges are manifest in primary and secondary schooling and in tertiary education. Finally, we survey some recent representations of student voice in "Educational Action Research," observing something of a shift from earlier conceptualisations of students as a "data source" to a more active involvement as co-researchers and joint constructors of knowledge, progressing toward more active student-teacher partnerships.