also has the overall right to due process applicable in criminal matters.” 71 This indicates that the guarantees of Article 8(2) of the Convention are not exclusive to criminal proceedings, but can be applied to proceedings of a punitive nature. Therefore, in each case it is necessary to determine the minimum guarantees that apply to a given non-criminal punitive process, according to its nature and scope. 72 67. In the case sub judice, after the strike was declared illegal, the First Chamber of the Labor and Social Welfare Appeals Court, in a ruling of May 13, 1996, set a term of twenty days for the Judiciary to apply Article 244 of the Labor Code. This article states that when a strike is declared illegal and the workers carry it out, the court must grant the employer a period of twenty days during which, without any liability on its part, it may terminate the employment contracts of workers who strike. The Chamber expressly warned, with respect to the list of employees who participated in the strike, that this “must be established administratively in a precise manner, after a review of the lists that were provided as evidence, since an examination of these reveals certain inaccuracies that could negatively affect the rights of workers who did not suspend work and are included in the list.” 73 68. The Supreme Court of Justice, as the employer of the Judiciary workers, issued an order on September 1, 1999, in which it decided to immediately dismiss 404 employees, including the alleged victims in this case. 74 Among the reasons given to justify this decision, the Supreme Court took into account that: “a) the attitude adopted by the employees who went on strike prevented the population from exercising the right and access to justice […]; b) the harm caused to justice because of the above-mentioned unlawful strike was a blow to the rule of law; and c) the employees who participated in the unlawful strike put private interests above public ones, with the main party affected being the people of Guatemala […].” 75 Owing to certain inconsistencies in the list of dismissed employees, the Supreme Court had to issue a second ruling on September 6, 1999. 76 69. Thus, the alleged victims were dismissed without any prior procedure, solely in application of an order that attributed unlawful conduct to them and established dismissal as a consequence. Thus, the dismissal was the sanction for having participated in a strike declared illegal, and therefore the individuals who were subject to this sanction of dismissal were entitled to due process guarantees in the disciplinary processes, although their scope, content or intensity might vary. The Court therefore considers that the violations alleged in this case should also be analyzed in light of the guarantees established in Article 8(1) and 8(2)(b) and (c), namely, the right to be heard, the right to be notified in advance and in detail of the accusation made and the right to have adequate time and means to prepare a defense. In the Court’s opinion, these guarantees are applicable to the specific case. objection, merits, reparations and costs. Judgment of May 3, 2016. Series C No. 311, Case of Moya Solís v. Peru, supra and Case of Cuya Lavy et al. v. Peru, supra. 71 152. Case of the Constitutional Court v. Peru, supra, para. 70, and Case of Cuya Lavy et al. v. Peru, supra, para. 72 Cf. Case of Maldonado Ordóñez v. Guatemala, supra, para. 75, and Case of Cuya Lavy et al. v. Peru, supra, para. 152. 73 Ruling of the First Chamber of the Labor and Social Welfare Appeals Court in the context of Collective Dispute No. 730-94 of May 13, 1996 (evidence file, folios 60 and 61). 74 Cf. Ruling of the Supreme Court of Justice of September 1, 1999 (evidence file, folios 3583 to 3604). 75 Ruling of the Supreme Court of Justice of September 1, 1999 (evidence file, folio 3585). 76 Cf. Ruling of the Supreme Court of Justice of September 6, 1999 (evidence file, folios 358 to 360). 22