38 the inter-American system have made reference to the following guarantees: a) establishment of an adequate procedure for the appointment and removal of judges; 201 b) the guarantee against external pressures;202 and c) the irremovability in the post for the duration of one’s term.203 Those guarantees are a corollary of the right of access to justice that every person enjoys and, in the case of judges, are “reinforced guarantees” of tenure so as to thereby ensure the necessary independence of the Judicial Branch.204 116. With specific reference to the guarantee of tenure, the UN Basic Principles provide that “[t]he term of office of judges, their independence, security, adequate remuneration, conditions of service, pensions and the age of retirement shall be adequately secured by law”;205 they also provide that “[j]udges, whether appointed or elected, shall have guaranteed tenure until a mandatory retirement age or the expiry of their term of office, where such exists.”206 The UN Basic Principles state that “[j]udges shall be subject to suspension or removal only for reasons of incapacity or behaviour that renders them unfit to discharge their duties.”207 Likewise, the European Court has written that the irremovability of judges by the executive during their term of office must in general be considered as a corollary of their independence and thus included in the guarantees of Article 6 (1) of the European Convention on Human Rights and Fundamental Freedoms. 208 Similarly, the UN Human Rights Committee has written that judges may be dismissed only on serious grounds of misconduct or incompetence, in accordance with fair procedures ensuring objectivity and impartiality set out in the constitution or the law.209 For its part, the Inter-American Court and the Commission has held that these guarantees “reinforce” judges’ stability in their position as a way to ensure their independence 201 73-75. I/A Court H.R., Case of the Constitutional Court v. Peru. Judgment of January 31, 2001. Series C No. 71, paragraphs IACHR, Democracy and Human Rights in Venezuela, December 30, 2009. Available at: http://www.cidh.org/countryrep/Venezuela2009eng/VE09.TOC.eng.htm; CIDH, Second Report on the Situation on Human Rights Defenders, December 31, 2011. Available at: http://www.oas.org/en/iachr/defenders/docs/pdf/defenders2011.pdf 202 75; I/A Court H.R., Case of the Constitutional Court v. Peru. Judgment of January 31, 2001. Series C No. 71, paragraph IACHR, Democracy and Human Rights in Venezuela, December 30, 2009. Available at: http://www.cidh.org/countryrep/Venezuela2009eng/VE09.TOC.eng.htm; CIDH, Second Report on the Situation on Human Rights Defenders, December 31, 2011. Available at: http://www.oas.org/en/iachr/defenders/docs/pdf/defenders2011.pdf. 203 I/A Court H.R., Case of the Constitutional Court v. Peru. Judgment of January 31, 2001. Series C No. 71, paragraph 75.; Case of Apitz Barbera et al. (First Court of Administrative Disputes) v. Venezuela, Judgment of August 5, 2008. Series C No. 182, paragraph 138. IACHR, Democracy and Human Rights in Venezuela, December 30, 2009. Available at: http://www.cidh.org/countryrep/Venezuela2009eng/VE09.TOC.eng.htm; CIDH, Second Report on the Situation on Human Rights Defenders, December 31, 2011. Available at: http://www.oas.org/en/iachr/defenders/docs/pdf/defenders2011.pdf. 204 /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, paragraph 67. 205 Principle 11 of the UN Basic Principles on the Independence of the Judiciary (1985). 206 Principle 12 of the UN Basic Principles on the Independence of the Judiciary (1985). 207 Principle 18 of the UN Basic Principles on the independence of the judiciary (1985). Eur. Court H.R., Campbell and Fell judgment of 28 June 1984, Series A no. 80, para. 80; Eur. Court HR., Engel and Others judgment, Series A no. 22, pp. 27-28, para. 68. 208 209 Cf. United Nations, Human Rights Committee, General Comment No. 32, Article 14, supra nota 71, paragraph 20.