74. Prosecutor Nissen Pessolani filed a recusal motion against four members of the JEM, including its president.97 However, the Jury rejected it "for lacking grounds and for having violated the modifying rule of article 10 of the Law that governs the Jury."98 In fact, this rule limited the number of jurors who could be challenged to three. 75. Moreover, within the framework of the proceedings before the Inter-American Commission, the Director of Human Rights of the Public Prosecutor's Office submitted a note to the Ministry of Foreign Affairs, referring to the petition filed by Mr. Nissen Pessolani before the Commission. It was indicated that, after an examination of the file, "it can be easily deduced that Society's Representative, Attorney Alejandro Nissen Pessolani has been subject to persecution and political pressure by the Jury for the Impeachment of Magistrates during the entire process against him, with the intention of being removed from all the investigation cases under his charge, leading to his dismissal."99 76. The joint analysis of the elements described above allows us to conclude that there were conflicts of interest capable of affecting the impartiality of at least two members of the Jury for the Impeachment of Magistrates and the existence of political pressures in the trial of Prosecutor Nissen Pessolani. Therefore, the Court considers that, based on the evidence in the file, the presumption of subjective impartiality is undermined. Likewise, these elements had an impact on the functioning of the Jury as a whole, thus affecting its functional impartiality. Consequently, this Court considers that, in the instant case, the right to an impartial tribunal, guaranteed by Article 8(1) of the American Convention, to the detriment of Alejandro Nissen Pessolani, was violated. 77. This violation of the guarantee of impartiality, due to its seriousness, implies that the entire proceedings carried out by the JEM against Mr. Nissen Pessolani are flawed and implied the arbitrariness of his dismissal. Therefore, this Court does not consider it necessary to analyze the other violations of due process and other related rights alleged by the representative and the Commission. VI-2 RIGHT TO JUDICIAL PROTECTION100 A. Motions by the parties and the Commission 78. The Commission recalled that Article 21 of Law no. 1084 established that the final rulings of the JEM are "not subject to appeal before another body. However, an appeal for clarification and reversal may be filed before the JEM itself. The Commission observed that, due to its nature and legal configuration, the appeal for clarification and reversal does not allow for a comprehensive review of the JEM's resolutions, and therefore does not constitute a suitable appeal to ensure the double compliance of a sanctioning judgment. 97 Cf. Challenge letter submitted by Alejandro Nissen Pessolani to the president of the Impeachment Jury on May 31, 2002 (case file of evidence, folios 3297 to 3311). Interloculatory Order No. 10/02 of July 30, 2022 issued by the Jury for the Impeachment of Magistrates on the recusal motion filed by Attorney Alejandro Nissen Pessolani (case file of evidence, folio 3746). 98 99 Note No. 116 issued by the Director of Human Rights of the Public Prosecutor's Office, addressed to the Ministry of Foreign Affairs on September 18, 2006 (case file of evidence, folios 2766 to 2768). 100 Article 25(1) of the American Convention. 25