41 procedures. This is a way to ensure that a State does not invent authorities that will not adhere to the pre-established rules of procedure and that serve in place of the authority in which that competence is normally vested.215 125. The Commission notes that the SCJ’s disciplinary authority can be traced to Article 313 of the Honduran Constitution, which makes it the competent authority to remove judges “upon the recommendation of the Judicial Career Council.” The Commission notes that the removal of the alleged victims was done by a decision of the SCJ issued subsequent to a recommendation by the Office of the Director of Personnel Management. Likewise, the Judicial Career Council’s role in the disciplinary proceedings came on the heels of the Supreme Court’s decisions to dismiss, where it functioned as an appellate body. 126. Here, the Commission observes that the manner in which the disciplinary proceedings were conducted was not the one prescribed in the Constitution. Because the Supreme Court intervened in the disciplinary process without the requirement prescribed by the Constitution being met, it did not have jurisdiction to decide the matter of the alleged victims’ dismissal. The Commission notes further that the Judicial Career Council did not follow the model prescribed in Article 313 of the Constitution and functioned instead as a body to which the alleged victims could turn to appeal the SCJ’s decision to order their dismissal. According to the information available, this was not just at variance with the procedure prescribed in the Constitution; it was also a situation in which the Council exercised an authority it did not have since, under Article 9 of the Judicial Career Service Act, the Council is only authorized to take up and decide those “remedies that are duly filed against decisions of the Office of the Director of Personnel Management.” It is not authorized to hear appeals challenging decisions of the SCJ. Therefore, the Commission finds that the Judicial Career Council was not competent to serve as an appellate body of the SCJ. 127. As for the guarantee of independence, the Inter-American Court has held that an adequate appointment process, tenure and protection against external pressures are essential to the independence of the authority charged with applying sanctions.216 That guarantee must materialize in the form of a disciplinary system in which the authorities charged with reviewing the situation and determining whether sanctions are in order are not subject to “possible undue limitations in the exercise of their functions” by other authorities and inspire confidence in the judge facing disciplinary proceedings.217 128. The Commission has sufficient information to conclude that the SCJ did not offer the guarantees of independence necessary to intervene in the present case. However, since the Judicial Career Council functioned as a body for review of the SCJ’s decisions, with the ultimate authority to confirm its decisions or overturn them, the Commission will now consider whether the Council had the necessary guarantees of independence vis-à-vis the Supreme Court, whose decisions reviewed. 215 I/A Court H.R. Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of August 5, 2008. Series C No 182, paragraph 50. 216 Cf. I/A Court H.R. Case of Reverón Trujillo v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of June 30, 2009, paragraph 70; and Case of Chocrón Chocrón v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2011, paragraph 98. 217 I/A Court H.R. Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of August 5, 2008, paragraph 55.