the procedural rules that apply. 61 In disciplinary matters, the principle of legality requires that the law give detailed guidance on the infractions that may trigger disciplinary measures, including the seriousness of the infraction and the type of disciplinary measure that may be applied in different cases. The principle of legality requires not only that the impugned measure should have some basis in domestic law, but also that the law containing the measure should be accessible to the persons concerned and formulated with sufficient precision to enable them to foresee, to a degree that is reasonable in the circumstances, the consequences which a given action may entail. 62 60. Both the Court and the Commission have indicated that the greater the restriction on a human right, the more precise the provisions establishing that restriction must be. 63 In terms of judges, the IACHR has indicated that the penalties of suspension or dismissal must be applied only in the case of the most serious misconduct. As the Council of Europe recommended with respect to disciplinary offenses, disciplinary measures should become stricter as the seriousness of the offense increases, and can include removal of cases from a judge, assigning the judge other tasks, economic sanctions, and suspension. 64 61. Along these same lines, the Court has indicated that an overly broad regulatory framework affects the predictability of the sanctions because it permits the dismissal of a judge based on open-ended grounds that grant excessive discretionary power to the body responsible for applying the sanction. 65 The Court has indicated that some degree of imprecision does not result, per se, in a violation of the Convention; in other words, the fact that a law grants some discretionary power is not incompatible with the degree of predictability required, provided that the scope of the discretion and the way in which it should be exercised are indicated with sufficient clarity so as to provide adequate protection against arbitrary interference. 66 62. In the case at hand, the Commission observes that Article 205, paragraph 20, of the Constitution states that the Congress has the power to “approve or disapprove the administrative conduct…of the judicial branch.” First of all, as established earlier in the context of the guarantee of competence, this provision may not serve as the justification or basis for the summary decisions made by the National Congress to remove the justices from office. 63. Second of all, the Commission notes that the aforementioned constitutional provision is very broad, as it does not determine or specify particular conduct that would be reproachable from a disciplinary standpoint. The Commission further notes that, contrary to the standards that have been cited, the legal framework does not even establish the grounds or the sanctions that would apply if such administrative conduct were to be proved. Finally, the Commission considers that this lack of predictability allowed the National Congress to have excessive discretion when it came to applying the most severe sanction, as occurred in this case. 64. Consequently, the Commission considers that basing the dismissal of the four justices from the Constitutional Chamber of the Supreme Court on that article is clearly contrary to the principle of legality in disciplinary matters. 65. In view of the above considerations, the IACHR concludes that the Honduran State violated Article 9 of the American Convention in connection with Articles 1(1) and 2 thereof, to the detriment of José Antonio Gutiérrez Navas, Rosalinda Cruz Sequeira, José Francisco Ruiz Gaekel, and Gustavo Enrique Bustillo Palma. 61 IACHR, Guarantees for the Independence of Justice Operators. Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, par. 187. 62 IACHR, Guarantees for the Independence of Justice Operators. Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, par. 208. 63 I/A Court H.R., Case of Kimel v. Argentina, Judgment of May 2, 2008, Series C No. 177, paras. 59 and following. 64 IACHR, Guarantees for the Independence of Justice Operators. Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, par. 217. 65 I/A Court H.R., Case of López Lone et al. v. Honduras, Preliminary Objection, Merits, Reparations, and Costs, Judgment of October 5, 2015, Series C No. 302, par. 264. 66 I/A Court H.R., Case of López Mendoza v. Venezuela, Merits, Reparations, and Costs, Judgment of September 1, 2011, Series C No. 233, par. 202. 14