29 understood by the Commission as a means to ensure the most basic human rights, such as the rights to 120 life, liberty, and personal integrity. 131. The specific terms of instruments on the protection of refugees are supplemented and, in certain respects, broadened by international human rights law. Thus, in the inter-American framework, the American Convention has served to strengthen the protection offered by international refugee law. As the IACHR has held, “Pursuant to this network of protections, States are obliged to refrain from taking measures contrary to the principle of asylum, such as returning or expelling asylum seekers or refugees 121 contrary to international human rights, humanitarian and refugee law.” 3. General considerations on the right to seek and be granted asylum, the principle of non-return, the right to a fair trial, and the right to judicial protection 132. In cases concerning the determination of refugee status and the expulsion or deportation of a refugee or someone seeking the recognition of refugee status, the analysis of compliance of the state's obligations under the American Convention entails a combined assessment of the rights recognized by articles 8, 22(7), 22(8), and 25 of that instrument. In circumstances such as in the instant case, these three articles of the American Convention are interrelated from two perspectives. 133. On one hand, as is explained in the section on fair trial guarantees in the area of immigration, according to the consistent case-law of the organs of the inter-American system, fair trial guarantees are not limited to judicial remedies, but apply to all procedural instances, including immigration proceedings, which can end in the expulsion or deportation of a person, as well as proceedings for the determination of refugee status and any proceeding that might culminate with an 122 individual's expulsion or deportation. From this perspective, the object and purpose of the protections recognized in articles 22(7) and 22(8) of the American Convention, introduce certain specific aspects in satisfying the right to fair trial guarantees in the framework of proceedings to do with the scope of these provisions. 134. On the other hand, it is up to states to make determinations regarding the rights recognized in articles 22(7) and 22(8) of the American Convention through the procedures and authorities established internally for those ends. And In that sense, these provisions include not only substantive, but also procedural, obligations, in order to ensure the effectiveness of such procedures and authorities in satisfying the ultimate purpose of these provisions; that is, the protection of these individuals from dangers to their life, integrity, or liberty in other countries. Consequently, determinations on asylum claims and on the admissibility of grounds for invoking the principle of non-return must meet the applicable basic guarantees contained in article 8 of the Convention in the below-described terms. 135. Indeed, based on these interconnections, following, the Commission summarizes the specific due process standards for upholding the right to seek and be granted asylum, as well as the principle of non-return. 120 IACHR, Report on the Situation of Human Rights of Asylum Seekers within the Canadian Refugee Determination System. OEA/Ser.L/V/II.106. Doc. 40. Rev. 1. February 28, 2000. par. 32. 121 IACHR, Report on the Situation of Human Rights of Asylum Seekers within the Canadian Refugee Determination System. OEA/Ser.L/V/II.106. Doc. 40. Rev. 1. February 28, 2000. par. 26. See generally, UN General Assembly Resolution 52/103, 12 December 1997, "Office of the UN High Commissioner for Refugees," para. 5. 122 Further to what is mentioned above in the sphere of the inter-American system, the African Commission on Human and People's Rights has also consistently held that fair trial guarantees must be applied in the framework of proceedings on expulsion of immigrants and refugees. For more information see, inter alia, African Commission on Human and Peoples' Rights: Communication 313/05 – Kenneth Good v. Republic of Botswana, 47th ordinary session, 12-26 May 2010, paras. 160-180; and Communications 27/89, 46/91, 49/91, 99/93 - Organisation Mondiale Contre La Torture and Association Internationale des juristes Democrates, Commission Internationale des Juristes (C.I.J), Union Interafricaine des Droits de l'Homme v. Rwanda, 20th ordinary session, October 1996, p. 4.

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