Are you sure about that? This is Voyager's bottom 12 according to IMDb voters:
Elogium
Tattoo
Threshold
Sacred Ground
Darkling
Favorite Son
Unforgettable
Once Upon a Time
The Fight
Fair Haven
Spirit Folk
Fury
Can anyone honestly say that The Fight is better than Section 31? Or Unforgettable? (Personally I'm rating Spirit Folk and Once Upon a Time above it.)
The following episodes, I feel, are better than SECTION 31.
"TATTOO" - we get a look at Chakotay's childhood, and The Doctor giving himself a flu to prove a point was funny.
"THRESHOLD" - this is a GOOD episode, doesn't belong in the bottom end of VOY. It's got great character work for Tom, and some fantastic horror elements. The last few minutes are the only parts that ding the episode.
"SACRED GROUND" - it was a decent character episode for Janeway.
"DARKLING" - while this is definitely lower tier VOY, Robert Picardo's acting at least makes it palatable.
"UNFORGETTABLE" - this was more boring than outright bad.
"ONCE UPON A TIME" - I don't see this as a bad episode, honestly. Maybe lower tier VOY, but definitely not among the worst. It's a nice Neelix story.
"FAIR HAVEN" - this is a bad one, but still not as bad as SECTION 31.
The following episodes, I feel, are probably worse than SECTION 31.
"ELOGIUM" - at least the space dwelling lifeform situation was interesting and the episode was
trying to have a message.
"FAVORITE SON" - among the worst of VOY, but I'd still rather watch this again than SECTION 31.
"THE FIGHT" - a very interesting premise (Chaotic Space) that was very poorly executed. I'd still watch this again before SECTION 31.
"SPIRIT FOLK" - a terrible episode, but I'd still rewatch this before SECTION 31.
"FURY" - this IS among the worst in the franchise, but I would still watch this again before SECTION 31.
Yes, some of them are worse than SECTION 31, but honestly not so much worse that I would not rewatch them again.