150. Furthermore, regarding the protection afforded by Article 23(1) (c) of the American Convention 195 in the cases of Apitz Barbera et al., and Reverón Trujillo, this Court specified that Article 23(1) (c) does not establish the right to participate in government, but to do so “under general conditions of equality.” This means that respect for and guarantee of this right are fulfilled when there are “clear procedures and objective criteria for appointment, promotion, suspension and dismissal” and that “persons are not subject to discrimination” in the exercise of this right. 196 In this respect, the Court has pointed out that equality of opportunities in access to and tenure in office guarantee freedom from all interference or political pressure. 197 151. Likewise, the Court has stated that a judge’s guarantee of tenure is related to the right to remain in public office, under general conditions of equality. 198 Indeed, in the case of Reverón Trujillo it established that “access in equal conditions would constitute an insufficient guarantee if it were not accompanied by the effective protection of the continuance in what is accessed.” 199 152. For its part, in cases of arbitrary dismissal of Judges 200 the Human Rights Committee has considered that failure to observe the basic requirements of due process violates the right to due process enshrined in Article 14 201 of the International Covenant on Civil and 195 Article 23(1) states the following: “Every citizen shall enjoy the following rights and opportunities: […] c) to have access, under general conditions of equality, to the public service of his country.” 196 Cf. Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela, para. 206, and Case of Reverón Trujillo v. Venezuela, para. 138. See also Human Rights Committee, General Comment No. 25, Article 25: Participation in Public Affairs and the Right to Vote, CCPR/C/21/Rev. 1/Add. 7, July 12, 1996, para. 23. 197 Cf. Case Chocrón Chocrón v. Venezuela, para. 135. See also Human Rights Committee, General Comment No. 32, Article 14: Right to Equality before Tribunals and Courts and to a Fair Trial, CCPR/C/GC/32, of August 23, 2007, para. 19. 198 Cf. Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela, para. 43, and Case of Chocrón Chocrón v. Venezuela, para. 135. See also Human Rights Committee, Communication No. 814/1998, Mikhail Ivanovich Pastukhov v. Belarus, CCPR/C/78/D/814/1998, para. 7.3; Communication No. 933/2000, Adrien Mundyo Busyo, Thomas Osthudi Wongodi, René Sibu Matubuka et al. v. Democratic Republic of Congo, CCPR/C/78/D/933/2000, para. 5.2. 199 Case of Reverón Trujillo v. Venezuela, para. 138, and Case Chocrón Chocrón v. Venezuela, para. 135. Similarly, the Human Rights Committee, in the case Mikhail Ivanovich Pastukhov v. Belarus, declared that “the author's dismissal from his position as a judge of the Constitutional Court, several years before the expiry of the term for which he had been appointed, constituted an attack on the independence of the judiciary and failed to respect the author's right to have access, on general terms of equality, to public service in his country.” Cf. Human Rights Committee, Communication No. 814/1998, Mikhail Ivanovich Pastukhov v. Belarus, CCPR/C/78/D/814/1998, paras. 7.3. Thus, there has been a violation of Article 25 (c) of the Covenant, read in conjunction with Article 14, paragraph 1, providing for the independence of the judiciary”). 200 In the case Soratha Bandaranayake v. Sri Lanka, where the Committee concluded that the arbitrary dismissal of a judge could be construed as the violation of the right to have access, under general conditions of equality, to the public service of his country in conjunction with the right to due process and, in particular, in conjunction with the independence of the judiciary. Human Rights Committee, Communication No. 1376/2005, Soratha Bandaranayake v. Sri Lanka, CCPR/C/93/D/1376/2005, para. 7.3. (“Dismissal of a judge in violation of Article 25 (c) of the Covenant, may amount to a violation of this guarantee, read in conjunction with Article 14, paragraph 1 providing for the independence of the judiciary”). 201 Article 14(1) of the International Covenant on Civil and Political Rights establishes: “All persons shall be equal before the courts and tribunals. In the determination of any criminal charge against him, or of his rights and obligations in a suit at law, everyone shall be entitled to a fair and public hearing by a competent, independent and impartial tribunal established by law. The Press and the public may be excluded from all or part of a trial for reasons of morals, public order or national security in a democratic society, or when the interest of the private lives of the parties so requires, or to the extent strictly necessary in the opinion of the court, in special circumstances where publicity would prejudice the interests of justice; but any judgment rendered in a criminal case or in a suit at law shall be made public, except where the interest of juvenile persons otherwise requires or the proceedings concern matrimonial disputes or the guardianship of children.” 46