19 officials to maintain their independence.”64 70. According to the jurisprudence of this Court and the European Court, as well as pursuant with the Basic Principles of the United Nations on the Independence of the Judiciary (hereinafter, “Basic Principles”), the following guarantees are derived from the judicial independence: an adequate appointment process, 65 the tenure in the position,66 and the guarantee against external pressures.67 i) adequate appointment process 71. The Basic Principles highlight as preponderant elements in the appointment of judges their integrity, ability with appropriate training or qualifications in law. 68 Likewise, the Recommendations of the Council of Europe evoke a framework criterion of usefulness in this analysis when it states that all the decisions regarding the professional career of the judges shall be based on objective criteria, namely the judge’s personal merits, his qualifications, integrity, ability, and efficiency, all of which are the preponderant elements to be considered.69 This Court has previously pointed out that the different political systems have come up with strict procedures both for the appointment of judges as well as for their dismissal.70 72. The Human Rights Committee has stated that if the access to the public administration is based on merits and equal opportunities, and the stability in the position can be ensured, the liberty from all political interference or pressure is guaranteed.71 In a similar sense, the Court points out that all appointment processes shall serve the purpose not only of appointment according to merits and qualifications of those who aspire, but to assurance of equal opportunities in the 64 Cf. judgment issued by the SPA on October 13, 2004, supra note 45, folio 180. 65 Cf. Case of the Constitutional Court v. Peru, supra note 58, para. 75; Case of Palamara Iribarne v. Chile, supra note 57, para. 156, and Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela, supra note 58, para. 138. See also ECHR, Case of Campbell and Fell v. the United Kingdom, judgment of 28 June 1984, Series A No. 80, para. 78; ECHR, Case of Langborger v. Sweden, Judgment of 22 January 1989, Series A no. 155, para. 32; and Principle 10 of the Basic Principles of the United Nations on the Independence of the Judiciary adopted by the Seventh Congress of the United Nations for the Prevention of Crime and the Treatment of Offenders, held in Milan, Italy, from August 26th through September 6, 1985, and confirmed by the General Assembly in its resolutions 40/32 of November 29, 1985 and 40/146 of December 13, 1985. 66 Cf. Case of the Constitutional Court v. Peru, supra note 58, para. 75; Case of Palamara Iribarne v. Chile, supra note 57, para. 156, and Case of Apitz Barbera et al (“First Court of Administrative Disputes”) v. Venezuela, supra note 58, para. 138. See also Principle 12 of the Basic Principles of the United Nations, supra note 65. 67 Cf. Case of the Constitutional Court v. Peru, supra note 58, para. 75, and Case of Palamara Iribarne v. Chile, supra note 57, para. 156. See also ECHR, Case of Campbell and Fell v. the United Kingdom, supra note 65, para. 78, and Case of Langborger Vs. Sweden, supra note 65, para. 32. See also Principles 2, 3, and 4 of the Basic Principles of the United Nations, supra note 65. Judgment of 27 January 1989, Series A no. 155, para. 32; Basic Principle 12. 68 Cf. Principle 10 of the Basic Principles of the United Nations, supra note 65. 69 Cf. Principle I(2)(c) of Recommendation No. R (94) 12 of the Committee of Ministers of the State Members on the Independence, Efficiency, and Duty of the Judges adopted by the Committee of Ministers on October 13, 1994 in the 5i8th meeting of Vice-ministers. 70 Cf. Case of the Constitutional Court v. Peru, supra note 58, para. 73 and Case of Apitz Barbera et al. (First Court of Administrative Disputes) v. Venezuela, supra note 58, para. 44. 71 Cf. United Nations, Human Rights Committee, General Observation No. 32, Article 14: Right to a Fair Trial and Equality Before Tribunals and Courts of Justice, CCPR/C/GC/32, August 23, 2007, para. 19.