66 212. Lastly, the Commission must determine whether the Supreme Court has displayed a lack of impartiality in processing the court cases related to the seizure of RCTV’s property. Specifically, it must examine whether, as the petitioners allege, the Supreme Court “became an essential player in the State’s plan to terminate RCTV’s concession and then hand over its frequency, property and broadcasting 307 equipment to a government-run channel.” 213. The Commission is reminded that bias or abuse of authority on the part of judges must be proved, especially when they are acting within the authority that the law has vested in them, as 308 happened in the instant case. There must be concrete and direct evidence to establish whether legal procedures were used, not as legitimate means of administering justice but as tools to accomplish 309 unstated purposes. A charge of abuse of authority or bias must be based on duly proven objective factors that demonstrate the abusive intent of the party whose conduct is in question, since in principle 310 the personal impartiality of members of a tribunal is to be presumed until there is proof to the contrary. Here, the Court has set a very high standard of proof to establish abuse of authority on the part of a 311 court. 214. Before applying this high standard of proof to the Supreme Court’s conduct in the seizure 312 of RCTV’s property, the Commission believes that some context might be informative. . In its special report on Democracy and Human Rights in Venezuela, published in 2009, the IACHR states that the “lack of judicial independence and autonomy vis-à-vis the political power is, in the IACHR’s opinion, one of the weakest points in Venezuelan democracy” and noted “with concern that in some cases, judges were removed almost immediately after adopting judicial decisions in cases with a major political 313 impact.” The Commission made specific reference to the Supreme Court, and observed that “the provisions for the appointment, removal, and suspension of justices set out in the Organic Law of the Supreme Court of Justice lacked appropriate mechanisms to keep other branches of government from 314 undermining the court’s independence.” Under the provisions of that law, “in December 2004, a simple majority of the National Assembly, supportive of the government’s interests, appointed 49 new justices 315 […] the 49 newly-elected justices were reported to be politically sympathetic to the government.” 215. The Commission recalls that in the instant case, the highest ranking authorities in the executive branch of the Venezuelan government stated repeatedly, and in no uncertain terms, their opinions toward RCTV and their opposition to renewal of its concession. Among other statements, alluded to earlier, President Chávez said that “There’ll be no new concession for that coup-supporting television channel that calls itself Radio Caracas Televisión. […] The order is already drafted. So go ahead […] start packing the bags. No media outlet that supports government overthrow, that is against 307 Annex 1, Communication from the petitioners received on February 18, 2010, p. 189. 308 IACHR, Application filed by the IACHR with the I/A Court H.R.. Case of Ana María Ruggeri Cova, Perkins Rocha Contreras and Juan Carlos Apitz (“First Court of Administrative Disputes”) against the Bolivarian Republic of Venezuela, Case 12.489. November 29, 2006. Paragraph 124. 309 Cf. IACHR, Application filed by the IACHR with the I/A Court H.R.. Case of Ana María Ruggeri Cova, Perkins Rocha Contreras and Juan Carlos Apitz (“First Court of Administrative Disputes”) against the Bolivarian Republic of Venezuela, Case 12.489. November 29, 2006. Paragraph 124. On the matter of abuse of power by court authorities, see also European Court of Human Rights, Case of Gusinskiy v. Russia, Judgment of May 19, 2004, paragraphs 71-78. 310 Cf. IACHR, Application filed by the IACHR with the I/A Court H.R.. Case of Ana María Ruggeri Cova, Perkins Rocha Contreras and Juan Carlos Apitz (“First Court of Administrative Disputes”) against the Bolivarian Republic of Venezuela, Case 12.489. November 29, 2006. Paragraphs.124-125. 311 Cf. 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 114. 312 Cf. I/A Court H.R.. Case of the Rochela Massacre v. Colombia. Merits, Reparations and Costs. Judgment of May 11, 2007. Series C No. 163, paragraph 76. 313 IACHR. Democracy and Human Rights in Venezuela. OEA/Ser.L/V/II.Doc.54, December 30, 2009, paragraph 15. 314 IACHR. Democracy and Human Rights in Venezuela. OEA/Ser.L/V/II.Doc.54, December 30, 2009, paragraph 198. 315 IACHR. Democracy and Human Rights in Venezuela. OEA/Ser.L/V/II.Doc.54, December 30, 2009, paragraph 199.