63. Apart from the punitive nature, it is relevant to formulate some general considerations on the strengthened safeguards in dismissal proceedings of judges and prosecutors, as well as the safeguards applicable in ratification or re-election proceedings of justice operators. 1. General considerations on applicable safeguards to judicial operators, including prosecutors 1.1 Judicial independence principle and judicial operators’ removal 64. The IACHR indicated that the judicial independence principle is a requirement inherent to a democratic system and an essential pre-requirement for human rights protection.59 It is embodied as one of due process’ safeguards and protected by Article 8.1 of the American Convention. Moreover, the said principle also includes “strengthened” 60 safeguards that the States have to provide for judges so as to insure their independence.61 The Inter-American system’s bodies have interpreted the judicial independence principle so as to include the following safeguards: Adequate appointment procedure, tenure, and safeguard against external pressures.62 65. Particularly, regarding the safeguards to insure tenure, the Court indicated that the proceedings that might culminate in the dismissal of a judicial operator shall be carried out in a way compatible with the judicial independence principle. This implies that the States shall insure that all the people exerting judicial function have the safeguards of strengthened stability, which means that the dismissal or cessation of a judge from their role might be admissible for two essential reasons: i. For presenting “clearly reprehensible” behavior, “truly serious reasons for bad behavior or lack of jurisdiction”63 or ii. due to the termination of the deadline or the fulfillment of the condition established in the appointment. Provisionality does not equal free removal and it shall not imply any alteration in the safeguards’ regime for the judge’s good performance and in the safeguard of the parties themselves.64 66. Regarding the appointment’s established term or condition, the United Nations Basic Principles relative to the judgeship’s independence establish that “the judges’ tenure will be insured for those appointed by administrative decision and those elected, until they reach the age of forced retirement or the term for which they were elected expires, as long as there are regulations in this regard.”65 67. Justice operators’ stability in their roles is closely linked to the safeguard against external and internal pressures because if they do not have permanence assurance during a determined period, they will be IACHR, Report on Merits 12,816, Report No. 103/13, November 5, 2013, para. 112. Citing the United Nations. Human Rights Committee. General Observation No. 32, CCPR/C/GC/32, August 23, 2007, para. 19. See Cf. Habeas Corpus under Suspension of Safeguards (Arts. 27.2, 25.1, and 7.6 of the American Convention on Human Rights.) Advisory Opinion OC-8/87, January 30, 1987. Series A No. 8, para. 30. See also, IACHR, Democracy and Human Rights in Venezuela, III. Separation and independence of the public authorities, December 30, 2009, para. 80. 60 IAHR Court. Case Reverón Trujillo vs. Venezuela. Preliminary Exception, Merits, Reparations, and Indemnities. Judgment of June 30, 2009. Series C No. 197, para. 67; IACHR, Democracy and Human Rights, December 30, 2009, para. 185; IACHR, Second report on the situation of human rights defenders, December 31, 2011, para. 359. 61 As an example of this, the Inter-American Court indicated that “the judges’ rights” are included within the State’s obligations regarding the parties subjected to proceedings before the court. Moreover, the Court has indicated that “the safeguard of not being subjected to free removal entails that the disciplinary and punitive proceedings of judges shall necessarily respect due process safeguards, and that an effective remedy shall be offered to those affected.” IAHR Court. Case Apitz Barbera and others (“First Administrative Law Court”) vs. Venezuela. Preliminary Exception, Merits, Reparations, and Indemnities. Judgment of August 5, 2008. Series C No. 182, para. 147. 62IACHR, Report on Independence remedies for justice operators. The Road toward Strengthening the Access to Justice and the Rule of Law in the Americas, December 5, 2013, para. 56, 109, and 184, IAHR Court. Case López Lone and others vs. Honduras. Preliminary Exception, Merits, Reparations, and Indemnities. Judgment of October 5, 2015. Series C No. 302, para. 191. 63 IAHR Court. Case López Lone and others vs. Honduras. Preliminary Exception, Merits, Reparations, and Indemnities. Judgment of October 5, 2015. Series C No. 302, para. 259. 64 IAHR Court. Case Apitz Barbera and others (“First Administrative Law Court”) vs. Venezuela. Preliminary Exception, Merits, Reparations, and Indemnities. Judgment of August 5, 2008 Series C No. 182, para. 43. 65 See principle 12, United Nations Basic Principles relative to the judgeship’s independence, Adopted by the Seventh Conference of the United Nation on Prevention of Crime and the Treatment of Offenders, held in Milan from August 26 to September 6, 1985, and confirmed by the General Assembly on its resolutions 40/32 of November 29, 1985 and 40/146 of December 13, 1985. 59 12