51 independence, since it would promote that the judges follow instructions or abstain from contesting both the nominating and punishing entity.259 163. Even so, the Court has acknowledged that there may be special reasons for not reinstating a judge to his or her seat on the bench, reasons that have to be suitable to achieve a conventionally accepted end and necessary in the sense that there is no other less onerous or more proportional means.260 164. In the present case, the Commission notes that the “advisability” criterion is impermissible when one considers the importance and fundamental relevance of the principle of judicial independence. Lacking a permissible justification, what the Council did in practice was to impose yet another sanction on Judge Chévez, this time without the pretense of a trial and without allowing him to exercise his right to defend himself against the very same set of facts that the Council had previously discounted as grounds for disciplinary action. 165. As for the supposed “impossibility” of ordering reinstatement, the Commission notes that while the only reason given by the State was that the post was already occupied by the replacement appointed by the Supreme Court, the State failed to show that there were no other less onerous alternatives by which it could have offered the judge the option of being reinstated, for example, to a similar post with another tribunal or court. 166. In the case of Judge Barrios, the Council upheld his arguments as to the merits and decided that he would remain a member of the Judicial Branch. However, it also decided to declare his claim seeking reinstatement and back pay to be “unfounded” since Judge Barrios had continued working because no replacement had ever been named. After the SCJ’s decision ordering his dismissal, Judge Barrios remained in his post from June 16, 2010 to August 24, 2011, awaiting his replacement. During that time, the decision ordering his dismissal had not yet become final, which meant that he lived in a constant state of uncertainty as to his future in the Judicial Branch, and that uncertainty lasted for more than a year, thereby affecting his guarantee of job stability and exposing him to the threat of discretionary removal and pressure about his performance as a judge. The Commission observes that the Council’s ruling did not acknowledge the violations committed during the disciplinary process and did not order that Judge Barrios be compensated for those violations. 167. The Commission therefore considers that the State violated the right to challenge a punitive disciplinary ruling in violation of Article 8(2)(h) of the American Convention, read in conjunction with articles 1(1) and 2 thereof, to the detriment of Guillermo López Lone, Ramón Barrios, Luis Alonso Chévez de la Rocha and Tirza Flores Lanza. The Commission notes that the appeal was not an effective means to safeguard the Convention-protected rights that the Commission, in this report, declared were violated. That failure to provide an effective remedy was itself a violation of Article 25 of the Convention, to the detriment of Guillermo López Lone, Ramón Barrios, Luis Alonso Chévez de la Rocha and Tirza Flores Lanza. 259 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, paragraph 81. 260 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, paragraph 124.