39 and that of the system, as well as the appearance of independence with regard to the parties and society.210 117. The Commission is of the view that under the applicable international law on the subject of the irremovability of judges, the latter may only be removed under two different types of circumstances: i) circumstances that are commensurate with the guarantee of irremovability and are dictated by the term of office, period of appointment, or mandatory retirement age; 211 and ii) circumstances related to the judge’s fitness for office, i.e., through the disciplinary system.212 118. The dispute between the parties in the present case concerns the disciplinary proceedings conducted against the alleged victims for certain acts they supposedly performed in their capacity as judges, against the backdrop of the coup d’état in Honduras. The Commission will now turn its attention to its analysis, with a view to ascertaining the following: i) whether the alleged victims had the necessary guarantees of due process in the disciplinary proceedings conducted in their cases and ii) whether those proceedings, that took into account deeds or remarks by the alleged victims, affected other rights protected by the American Convention. B. Right to a fair trial an judicial protection (Articles 8 and 25 of the American Convention, read in conjunction with articles 1(1) and 2 thereof) 119. Article 8 of the American Convention provides that: 1. Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. 2. Every person accused of a criminal offense has the right to be presumed innocent so long as his guilt has not been proven according to law. During the proceedings, every person is entitled, with full equality, to the following minimum guarantees: (…) b. prior notification in detail to the accused of the charges against him; c. adequate time and means for the preparation of his defense; (…) h. the right to appeal the judgment to a higher court. 120. Article 25 of the American Convention establishes: 210 I/A Court H.R. Case of Reverón Trujillo v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of June 30, 2009. Series C No. 197, paragraph 81. 211 Principle 12 of the Basic Principles on the Independence of the Judiciary, principle I.3 of the Recommendation N. R (94) 12 and principle A 4 (l) of the Principles and Guidelines on the Right to a Fair Trial and Legal Assistance in Africa require guaranteed tenures of judges until mandatory retirement age or the expiry of their term of office, where such exist. See, United Nations. General Assembly. Human Rights Council. Report of the Special Rapporteur on the Independence of judges and lawyers, Leandro Despouy, A/HRC/11/41, March 24, 2009, paragraph 53. 212 IACHR, Final written observations, Case 12,600 Quintana Coello et al. (Justices of the Supreme Court) v. Ecuador, March 4, 2013. See also the expert paper by Param Cumaraswamy in Case 12,600 Hugo Quintana Coello et al. with respect to Ecuador, January 29, 2013.