74. Also, the United Nations Special Rapporteurship on the independence of judges and lawyers has stressed that prosecutors “have a central role in the functioning of the rule of law” and that their independence “falls within the general scope of judicial independence,” and the guarantee of this constitutes a State obligation.50 Similarly, the Special Rapporteurship has indicated the following: 66. The United Nations Guidelines stipulate that prosecutors should enjoy reasonable conditions of service, including tenure, when appropriate, remuneration and pension commensurate with the crucial role they play in the administration of justice. […] 68. Another important element that should exist within their conditions of service is the irremovability of prosecutors. […] 70. Given their important role and function, the dismissal of prosecutors should be subject to strict requirements […]. There should be a framework for dealing with internal disciplinary matters and complaints against prosecutors, who should in any case have the right to challenge – including in court – all decisions concerning their career, including those resulting from disciplinary proceedings.51 75. In the European sphere, the Council of Europe has recommended that the governments of the States “take appropriate measures to ensure that public prosecutors are able to perform their professional duties and responsibilities without unjustified interference or unjustified exposure to civil, penal or other liability.”52 Also, the joint report issued by the Consultative Council of European Judges and the Consultative Council of European Prosecutors on “The relations between judges and prosecutors in a democratic society,” known as the “Bordeaux Declaration,” indicates: 8. For an independent status of public prosecutors, some minimal requirements are necessary, in particular: […] that their position and activities are not subject to influence or interference from any source outside the prosecution service itself; […] that their recruitment, career development, security of tenure including transfer, which shall be effected only according to the law or by their consent, as well as remuneration be safeguarded through guarantees provided by the law. 37. Respect for the above principles implies that the status of prosecutors be guaranteed by law at the highest possible level in a manner analogous to that of judges. 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 (which shall be effected only according to the law or by their consent), remuneration, termination of functions and freedom to create professional associations […].53 A/CONF.144/28/Rev.1, p. 189 (1990), Guideline 4. See also: United Nations Commission on Crime Prevention and Criminal Justice, Strengthening the rule of law through improved integrity and capacity of prosecution services (Resolution 17/2), and its annex: Standards of Professional Responsibility and Statement of the Essential Duties and Rights of Prosecutors, adopted by the International Association of Prosecutors (IAP), April 23, 1999. Cf. Report of the Special Rapporteur on the independence of judges and lawyers, Diego García-Sayán, Independence of judges and lawyers, UN Doc. A/HRC/44/47, March 23, 2020, paras. 27 and 34. See also: Report of the Special Rapporteur on the independence of judges and lawyers, Sr. Leandro Despouy, UN Doc. A/HRC/11/41, March 24, 2009, para. 19, and Report of the Special Rapporteur on the independence of judges and lawyers, Gabriela Knaul, UN Doc. A/65/274, August 10, 2010, para. 18, which emphasize the independence that should be ensured to prosecutors in the performance of their functions. Consistent with this, Article 42(1) of the 1998 Rome Statute of the International Criminal Court stipulates: “The Office of the Prosecutor shall act independently as a separate organ of the Court. […].” 50 Cf. Human Rights Council. Report of the Special Rapporteur on the independence of judges and lawyers, UN Doc. A/HRC/20/19, June 7, 2012. 51 Cf. Council of Europe. Recommendation Rec(2000)19 of the Committee of Ministers to Members States on the Role of Public Prosecution in the Criminal Justice System, adopted on October 6, 2000, para. 11. 52 Cf. Report No. 12 (2009) of the Consultative Council of European Judges (CCJE) and Report No. 4 (2009) of the Consultative Council of European Prosecutors (CCPE) to the Committee of Ministers of the Council of Europe on ““The relations between judges and prosecutors in a democratic society.” The European Commission for Democracy through Law (Venice Commission) has indicated that prosecutors should be appointed until retirement, because “appointments for limited periods with the possibility of re-appointment bear the risk that the prosecutor will make 53 21