from office. 28 The IACHR has held that the independence of the judicial system is undermined when provisional judges are subject to dismissal without cause.29 44. In short, even when “needs of service” may justify an appointment of a justice operator on a temporary basis or in order to perform a specific function, said period or condition must be clearly set forth in the appointment document and must also be one of the grounds for eventual removal. This is the only way for the independence of the judicial function to be protected and to prevent provisional appointments of operators from being used arbitrarily to undermine said independence. 2.2 General considerations on prosecutors’ reinforced stability 45. The Commission finds that the principle of reinforced stability of judges is also applicable to prosecutors, inasmuch as they play a complementary role to that of a judge in the administration of justice, in bringing criminal cases, investigating crime, as well as the performance of other duties of public interest, which in the absence of sufficient guarantees, could make conditions ripe for them to be the target of internal and external pressure on the decisions they make.30 46. In this regard, the United Nations Guidelines on the Role of Prosecutors establishes that “States shall ensure that prosecutors are able to perform their professional functions without intimidation, hindrance, harassment, improper interference or unjustified exposure to civil, penal or other liability.”31 47. Likewise, the Bordeaux Declaration on Judges and Prosecutors in a Democratic Society establishes that: The independence of public prosecution constitutes an indispensable corollary to the independence of the judiciary (…) The independence of public prosecutors is indispensable for enabling them to carry out their mission (…) Thus, akin to the independence secured to judges, the independence of public prosecutors is not a prerogative or privilege conferred in the interest of the prosecutors, but a guarantee in the interest of a fair, impartial and effective justice that protects both public and private interests of the persons concerned. (…) the proximity and complementary nature of the missions of judges and prosecutors create similar requirements and guarantees in terms of their status and conditions of service, namely regarding recruitment, training, career development, discipline, transfer, remuneration, termination of functions and freedom to create professional associations.32 48. Moreover, the Consultative Council of European Prosecutors of the Council of Europe wrote in its Opinion No. 9 that: The independence and autonomy of the prosecution services constitute an indispensable corollary to the independence of the judiciary. Therefore, the general tendency to enhance the independence and effective autonomy of the prosecution services should be encouraged (…) IACHR, Application to the Inter-American Court of Human Rights in the case of Mercedes Chocrón Chocrón, Case 12.556, par.78. 29 IACHR, Second Report on the Situation of Human Rights in Peru, Chapter II, Administration of Justice and Rule of Law, OEA/Ser.L/V/II.106 Doc. 59 rev, June 2, 2000, par.15. 30 See for example IACHR, Toward a Comprehensive Policy to Protect Human Rights Defenders, OEA/Ser.L/V/II.Doc.207/17, December 29, 2017, par. 47. 31 United Nations. Guidelines on the Role of Prosecutors. Approved by the Eighth United Nations Congress on the Prevention of Crime and Treatment of Offenders, held in Havana, Cuba, from August 27 to September 7, 1990. 32 Consultative Council of European Judges and Consultative Council of European Prosecutors. Bordeaux Declaration, on Judges and Prosecutors in a Democratic Society, Strasbourg, December 8, 2009, pars. 27 and 37. 28 9