offenses committed in the context of anti-government activities” and was “the beneficiary of precautionary measures […] ordered by the Inter-American Commission, based on which there was an order for his release that had not been complied with.” They added that “Mercedes Chocrón [Chocrón] was removed on February 3, 2003; [that is], a few days after having conducted the said judicial procedure.” According to the representatives, this situation had “upset the Venezuelan government.” In that regard, the representatives indicated that the provisional judges “began to be removed by the Judicial Commission in a discretionary manner and without any kind of disciplinary procedure” and that, “in many case, the political nature of these removals and appointments was evident.” In addition, they referred to several cases involving judges who had been removed or whose appointment was “annulled” on grounds related to the alleged context of political polarization, especially “in the case of those who, through their rulings, had benefited individuals or institutions opposed to the Government,” or that “occurred because those judges issued judicial rulings that were inconvenient or contrary to the Government’s interests.” 40. Responding to a question from the Court on whether the foregoing constituted a fact included in the application (supra para. 13), the Commission indicated that, during the proceedings on admissibility and merits before the Commission, “the petitioners alleged that the grounds for the removal of the [alleged victim] was a judicial action related to precautionary measures granted by the Commission in favor of Carlos Alfonso Martínez.” However, it added that “[w]hen ruling on the merits, the Inter-American Commission considered that it was not necessary to analyze the reasons for the removal, because the procedure was sufficiently flawed to conclude that it constituted a violation of the American Convention.” Thus, it indicated that, “[s]ince the reasons that led to the [alleged] victim’s removal were not specified, the Commission [assumed] as a fact of the case that there was reasonable doubt about the real grounds for the decision.” 41. For its part, the State indicated that, “[t]he statements made by the alleged victim on the reasons for her removal from her post are completely false, since she alleges that it was due to a judicial procedure at the residence of General Carlos Martínez Alfonso.” The State indicated that “the facts alleged by the alleged victim are not the reason that she was removed from her post; but rather, it was the Judicial Commission’s exercise of its discretionary powers to annul appointments of temporary judges.” 42. In this regard, the Court notes that, according to its consistent case law, the alleged victims, their next of kin or their representatives may, under the proceedings before this Court, invoke the violation of rights other than those included in the application, provided that they do not allege facts that are not included therein,28 since the application constitutes the factual framework of the proceedings.29 For its part, given that a disputed case is substantially a litigation between a State and a petitioner or alleged victim,30 the latter may refer to facts that help explain, contextualize, clarify or, as appropriate, refute facts that have 28 Cf. Case of the "Five Pensioners" v. Peru. Merits, reparations and costs. Judgment of February 28, 2003. Series C No. 98, para. 155; Case of Fernández Ortega et al. v. Mexico, Preliminary objection, merits, reparations and costs. Judgment of August 30, 2010. Series C No. 215, para. 218, and Case of Ibsen Cárdenas and Ibsen Peña v. Bolivia. Merits, reparations and costs. Judgment of September 1, 2010. Series C No. 217, para. 228. 29 Cf. Case of the “Mapiripán Massacre” v. Colombia. Preliminary objections Judgment of March 7, 2005. Series C No. 122, para. 59; Case of Fernández Ortega et al. v. Mexico, supra note 28, para. 69, and Case of Ibsen Cárdenas and Ibsen Peña v. Bolivia, supra note 28, para. 134. 30 Case of Manuel Cepeda Vargas v. Colombia, Preliminary objections, merits, reparations and costs. Judgment of May 26, 2010. Series C No. 213, para. 49, and Case of Cabrera García and Montiel Flores v. Mexico, supra note 13, para. 56. 13