23 111. The Commission has taken as established a number of facts that occurred between February 19 and 24, 2001. The Commission observes that the Pacheco Tineo family entered Bolivia irregularly on February 19, 2001. When they visited the offices of the SENAMIG the following day, the immigration authorities became aware of their situation and, consequently, ordered steps to be taken with a view to their summary expulsion to Peru. During that same interval, Rumaldo Juan Pacheco Osco applied to the State of Bolivia for recognition of refugee status for himself and his family. Consequently, from February 21, 2001, until their expulsion on February 24, 2001, their status was both that of undocumented migrants and of applicants for refugee status. Therefore, on one hand, the immigration authorities moved forward with the arrangements for the expulsion of the Pacheco Tineo family, and on the other, meanwhile, in a matter of hours the CONARE made decisions on the propriety of the new asylum claim. Bearing in mind the different purpose and scope of these procedures—one having to do with irregular entry and resulting expulsion, the other concerning recognition of refugee status—, the Commission finds it appropriate to refer separately to the standards applicable to each; that is, on one hand, the guarantees in the framework of an immigration proceeding, which may result in the expulsion or deportation of an individual, and, on the other, the guarantees necessary for effective exercise of the right to seek and be granted asylum and the principle of non-return under the terms of articles 22(7) and 22(8) of the American Convention. 112. In order for this analysis to incorporate both aspects, the Commission considers it appropriate to set out its considerations in the following order: i) General considerations on the right to a fair trial in immigration matters; ii) The right to seek and be granted asylum and the principle of non-return; iii) The relationship between the right to seek and be granted asylum, the principle of non-return, the right to a fair trial, and the right to judicial protection; iv) Analysis of the events that occurred between February 20 and 24, 2001. 1. General considerations on the rights to a fair trial in immigration matters 113. The consistent jurisprudence of the organs of the inter-American system indicates that 90 fair trial guarantees are not limited to judicial remedies but apply to all procedural instances, including, 91 of course, any proceeding that could culminate in a person’s expulsion or deportation. In this last case, the Inter-American Commission and the Court have underscored that in addition to the guarantees envisaged in article 8(1), also applicable are the guarantees set forth in article 8(2) of the American 92 Convention, where pertinent. This has to do with the punitive nature of proceedings of this type. The Commission has also found that proceedings that can result in a person's expulsion or deportation involve determinations on fundamental rights, which demands as broad an interpretation as possible of 93 the right to a fair trial. 90 I/A Court H.R. Constitutional Court Case. Judgment of January 31, 2001. Series C, No. 71, par. 69; and Judicial Guarantees in States of Emergency (Arts. 27(2), 25 and 8 American Convention on Human Rights), Advisory Opinion OC-9/87 of October 6, 1987. Series A, No. 9. par. 27. Through its case-law, the inter-American court has been developing the scope of fair trial guarantees and their extent of application. The Court has interpreted that these guarantees are not limited to judicial remedies in the strict sense “but [to] all the requirement that must be observed in the procedural stages in order for an individual to be able to defend his rights adequately vis-à-vis any [...] act of the State that could affect them.” This is because, as the Court has noted, the State also empowers administrative, collegiate, and uni-personal authorities to adopt decisions that determine rights. On the last point, see I/A Court H.R., Case of Claude-Reyes et al. Judgment of September 19, 2006. Series C, No. 151, par. 118. 91 IACHR, Report No. 64/08. Case 11.691. Admissibility. Raghda Habbal and son. Argentina. July 25, 2008. par. 54; IACHR. Report No. 49/99. Case 11.610. Loren Laroye Riebe Star, Jorge Barón Guttlein, and Rodolfo Izal Elorz. Mexico. April 13, 1999. pars. 56, 58; IACHR. Report No. 81/10. Case 12.562. Publication. Wayne Smith, Hugo Armendariz et al. July 12, 2010. pars. 5 and 63; IACHR. Report No. 84/09. Case 12.525. Merits. Nelson Iván Serrano Sáenz. Ecuador. August 6, 2009. par. 61; IACHR. Report No. 63/08. Case 12.534. Admissibility and merits. Andrea Mortlock. United States. July 25, 2008. pars. 78 and 83; IACHR, Report on Terrorism y Human Rights, OEA/Ser.L/V/II.116 Doc 5 rev. 1 corr. (2002). par. 401. See also I/A Court H.R., Case of Vélez Loor v. Panama. Preliminary Objections, Merits, Reparations and Costs Judgment of November 23, 2010. Series C, No. 218. par. 141 and 142. 92 IACHR, Application to the Inter-American Court of Human Rights. Case of Jesús Tranquilino Vélez Loor. 12.581. Panama. October 8, 2009. par. 73; and I/A Court H.R., Ivcher Bronstein Case v. Peru. Judgment of February 6, 2001. Series C, No. 74, par. 103. 93 IACHR, Report No. 49/99. Case 11.610. Loren Laroye Riebe Star, Jorge Barón Guttlein, and Rodolfo Izal Elorz. Mexico. April 13, 1999. par. 70.