types of judge, because provisional and temporary judges are, by definition, elected in a different way and do not have indefinite tenure in their post. In this regard, it recognized that provisional and temporary judges have not demonstrated the qualities and aptitude to exercise their duties with the guarantees of transparency imposed by competitive examinations. However, this does not mean that provisional and temporary judges should not have some kind of appointment procedure because, according to the Basic Principles “[a]ny method of judicial selection shall safeguard against judicial appointments for improper motives.” 39. The Inter-American Court further indicated that just as the State is required to guarantee an appropriate appointment procedure for provisional judges, it must also guarantee them certain tenure in their posts. Thus, in the case of provisional judges, the guarantee of tenure translates into a requirement that they enjoy all the inherent benefits of secure tenure until the resolutive condition occurs that puts a legal end to their mandate. 40. Furthermore, the Inter-American Court stated that the tenure of provisional judges is closely related to the guarantee against external pressures because, if temporary judges do not have security of tenure during a pre-determined period, they will be vulnerable to pressure from different sectors, particularly those who have the authority to decide on dismissals or promotions in the Judiciary. 50 41. Also, the Inter-American Court held that provisional appointments must be the exception and not the rule, and that provisional appointments cannot be prolonged indefinitely. 51 42. Similarly, the Court stated that any public authority, whether administrative, legislative or judicial, whose decisions may affect the rights of individuals are required to adopt said decisions with full respect for the guarantees of due legal process. It also reiterated that any State body that exercises function of a substantially jurisdictional nature, has the obligation to adopt decisions that respect the guarantees of due legal process under the terms of Article 8 of the American Convention. 52 43. The Inter-American Court further emphasized that the authority to annul the appointment of judges based on “comments” must be minimally justified and regulated, at least specifying the facts that support those comments, and that the respective grounds are not of a disciplinary or punitive nature. If a disciplinary sanction is involved, the need for justification would be even greater, given that the purpose of disciplinary oversight is to assess the conduct, suitability and performance of the judge as a public official and, therefore, to analyze the seriousness of the conduct and the proportionality of the sanction. 53 44. In the Judgment that prompts this reasoned opinion, the Inter-American Court also considered its jurisprudential position on judicial independence 54 with reference to the standards issued by the Human Rights Committee and the United Nations Basic Principles 50 Ibid. paras. 104 to 106. 51 Ibid. para. 107. 52 Ibid. para. 115. 53 Ibid. para. 120. 54 Paragraph 144 of the Judgment establishes that “In its case law, the Court has indicated that the scope of judicial guarantees and effective judicial protection for judges must be examined in relation to the standards on judicial independence.” 10