of the Inter-American system have interpreted the principle of judicial independence as incorporating the following guarantees: an appropriate selection process, guaranteed tenure and the guarantee against external pressures.62 Specifically insofar as is relevant to this case, with respect to the guarantee of tenure, the Court has established that it “results in the subjective right of judges to be dismissed exclusively for the reasons permitted, either by a proceeding that complies with judicial guarantees or because their mandate has terminated.”63 When a judge’s tenure is arbitrarily impaired, “the right to judicial independence recognized in Article 8(1) of the American Convention is violated.” 64 93. Specifically with regard to impeachment and its use for the removal of persons involved in the administration of justice, the Inter-American Court has stated that it “must observe the guarantees of due process in order to respect the principle of judicial independence with regards to senior magistrates facing such proceedings.”65 The IACHR, for its part, has stated that impeachment: ... may only be used on an exceptional basis as a mechanism for removing judges, since because of its unique nature it may pose certain risks for certain guarantees that must be strictly observed in such circumstances. Accordingly, if the legislative branch is empowered to exercise adjudicatory functions in cases involving the dismissal of judges, that authority must constitute legal control with unreserved compliance with the principles of legality and the guarantees of due process, not political control of judicial activity based on discretionary criteria or political expediency.66 94. The Commission is of the view that “the use of impeachment in the case of justice operators should be gradually eliminated in the region, as impeachment poses a significant threat to judicial independence.”67 95. Bearing in mind the positions of the parties and the established facts, and taking into account the above general considerations, the Commission's legal analysis is conducted in the following order: (i) The right to a competent, independent, and impartial tribunal (Article 8(1) of the Convention); (ii) The right of defense and the right to appeal the judgment to a higher court (Articles 8(2) (c), (f), and (h) of the Convention; (iii) The right to reasoned decisions and the principle of legality (Articles 8(1) and 9 of the Convention); (iv) The right to participate in government (Article 23 of the Convention); and (v) The right to judicial protection (Article 25 of the Convention). [… continuation] 61Thus, for example, the Inter-American Court has held that the obligations of the State with respect to persons subject to judicial proceedings in the courts give rise, in turn, to “rights for judges,” which, according to the Court, include “the guarantee of not being subject to removal at will signifies that, in the case of judges, the disciplinary and punishment procedures must necessarily respect the guarantees of due process, and those subject to such procedures must be provided, among other matters, with an effective remedy.” I/A Court H.R., Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela, Preliminary Objection, Merits, Reparations and Costs. Judgment of August 5, 2008, Series C No. 182, par. 147. 62IACHR, Guarantees for the Independence of Justice Operators: Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, pars. 56, 109 and 184, 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. 191. 63 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. 192. 64 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. 192. 65I/A Court H.R., Case of the Constitutional Court v. Peru, Judgment of January 31, 2001, Series C No. 71, par. 84. 66IACHR, Report No. 43/15, Case 12.632, Merits (Publication), Adriana Beatriz Gallo, Ana María Cariaga and Silvia Maluf de Christin, Argentina, July 28, 2015, par. 135. 67See also, IACHR, Guarantees for the Independence of Justice Operators: Towards Strengthening Access to Justice and the Rule of Law in the Americas, OEA/Ser.L/V/II.Doc.44, December 5, 2013, par. 205.