Constitutional Chamber of the Supreme Court, the guarantees of due process and the principle of legality are applicable, in accordance with Articles 8(1), 8(2), and 9 of the American Convention. 51. In addition, the IACHR notes that disciplinary proceedings against justice operators must be exercised in a way that is compatible with the principle of judicial independence. This principle is an inherent requirement of a democratic system and a fundamental prerequisite for the protection of human rights. 48 The principle of judicial independence is enshrined as one of the guarantees of due process of law protected by Article 8(1) of the American Convention and, moreover, this principle gives rise to “reinforced” 49 guarantees that States must provide judges in order to ensure their independence. 50 The bodies of the inter-American system have interpreted the principle of judicial independence in the sense of incorporating the following guarantees: an appropriate appointment process, tenure in the position, and the guarantee against external pressures. 51 Specifically, as pertains to the instant case, the Court has indicated with respect to guaranteed tenure that “the scope of judicial independence results in the subjective right of judges to be dismissed exclusively for the reasons permitted, either by a proceeding that complies with judicial guarantees or because their mandate has terminated.” 52 When judges’ tenure is arbitrarily impaired, “the right to judicial independence recognized in Article 8(1) of the American Convention is violated.” 53 2. Guarantee of competence 52. Under Article 8(1) of the Convention, decisions affecting the rights of persons must be adopted by a competent authority, in accordance with domestic law. 54 Thus, “everyone shall have the right to be tried by ordinary courts or tribunals using established legal procedures. Tribunals that do not use the duly established procedures of the legal process shall not be created to displace the jurisdiction belonging to the ordinary courts or judicial tribunals.” 55 The purpose of this is to prevent individuals from being tried by special or ad hoc tribunals. 56 53. In the case at hand, the Commission observes that when the National Congress decided to dismiss the four justices of the Constitutional Chamber, Honduras did not have any legal or constitutional provisions in place to regulate disciplinary proceedings against justices of the Supreme Court. Nor is it evident from the constitutional framework that the Congress had jurisdiction to remove the members of the highest court through any type of summary proceeding. 48 IACHR, Report on Merits 12.816, Report No. 103/13, November 5, 2013, par. 112, citing United Nations, Human Rights Committee, General Comment No. 32, CCPR/C/GC/32, August 23, 2007, par. 19. In that same connection, see I/A Court H.R., Habeas Corpus in Emergency Situations (Arts. 27(2), 25(1) and 7(6) American Convention on Human Rights), Advisory Opinion OC-8/87 of January 30, 1987, Series A No. 8, par. 30. See also IACHR, Democracy and Human Rights in Venezuela, Ch. III, Independence and Separation of Public Powers, December 30, 2009, par. 80. 49 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, par. 67; IACHR, Democracy and Human Rights, December 30, 2009, par. 185; IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, December 31, 2011, par. 359. 50 Thus, for example, the Inter-American Court has indicated that the State’s obligations toward parties before the courts result, at the same time, in “rights for the judges.” The Court has indicated, among other things, that “the guarantee that they will not be subject to a discretional removal implies that the disciplinary and punishing processes of judges must necessarily respect the guarantees of the due process and shall offer those affected an effective remedy.” 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, par. 147. 51IACHR, Guarantees for the Independence of Justice Operators. Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, paras. 56, 109, and 184; I/A Court H.R., Case of López Lone et al. v. Honduras, Preliminary Objection, Merits, Reparations, and Costs, Judgment of October 5, 2015, Series C No. 302, par. 196. 52 I/A Court H.R., Case of López Lone et al. v. Honduras, Preliminary Objection, Merits, Reparations, and Costs, Judgment of October 5, 2015, Series C No. 302, par. 192. 53 I/A Court H.R., Case of López Lone et al. v. Honduras, Preliminary Objection, Merits, Reparations, and Costs, Judgment of October 5, 2015, Series C No. 302, par. 192. 54 I/A Court H.R., Case of the Supreme Court of Justice (Quintana Coello et al.) v. Ecuador, Preliminary Objection, Merits, Reparations, and Costs, Judgment of August 23, 2013, Series C No. 266, par. 158. 55 I/A Court H.R., Case of Barreto Leiva v. Venezuela, Merits, Reparations and Costs, Judgment of November 17, 2009, Series C No. 206, par. 75. 56 I/A Court H.R., Case of Barreto Leiva v. Venezuela, Merits, Reparations and Costs, Judgment of November 17, 2009, Series C No. 206, par. 75. 12