rulings they adopt or by virtue of arbitrary decisions by administrative or judicial entities. The appointment of temporary judicial officers with no defined term or condition in their appointment should be considered incompatible with the international obligations of a state as regards judicial independence and cannot be argued as an excuse for not granting due process guarantees in a decision on removal. 35 The IACHR has indicated that the independence of the judicial system is undermined when provisional judges can be dismissed without any statement regarding the cause. 36 56. In sum, even when the “needs of the service” may justify an appointment of a judicial officer on a temporary basis or to fulfill a specific function, that period or condition should be clearly established in the act of the appointment and should also be part of the explanation of the eventual act of separation. Only in this way can one protect the independence of the judicial function and avoid the provisional nature of judicial officers from being used arbitrarily to undermine such independence. 2.2 General considerations about the reinforced stability of prosecutors 57. The Commission considers that the principle of reinforced stability of judges also applies to prosecutors insofar as they play a complementary role to that of judges in the administration of justice, on bringing criminal proceedings, investigating crimes, as well as performing other functions of public interest, which in the absence of sufficient guarantees may contribute to them becoming subject to internal and external pressures in relation to the decisions they make. 37 58. In this respect the United Nations Guidelines on the Role of Prosecutors establish 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.” 38 59. establishes: In addition, the Bordeaux Declaration on judges and prosecutors in a democratic society The independence of the public prosecution service 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 (which shall be effected only according to the law or by their consent), remuneration, termination of functions and freedom to create professional associations. 39 60. In addition, the Consultative Council of European Prosecutors of the Council of Europe indicated in its Opinion No. 9: 35 IACHR, Application before the Inter-American Court of Human Rights in the case of Mercedes Chocrón Chocrón, Case 12,556, para. 78. 36 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, para. 15. 37 See, for example, IACHR, Integral Protection Policies for Human Rights Defenders, OEA/Ser.L/V/II.Doc.207/17, December 29, 2017, para. 47. 38 United Nations Guidelines on the Role of Prosecutors, adopted by the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, 27 August to 7 September 1990. 39 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, paras. 10, 27, and 37. 10