47 149. Furthermore, the dismissal decisions of which the judges and magistrate received notification did not set out the arguments supporting the reasoning that led the members of the Court to conclude that the victims had engaged in conduct that constituted the grounds for disciplinary action cited by the Office of the Director of Personnel Management. The decisions to dismiss invoke a number of procedural and disciplinary articles, without specifying their content or clearly spelling out how the conduct of the victims fit the situations described in the norms that content the disciplinary sanctions. The decisions also contained no reasoning concerning the seriousness of the misconduct that the victims were alleged to have committed and how dismissal was a proportionate sanction. 150. Concerning the obligation to state the grounds or reasons for a decision, the InterAmerican Court has pointed out that one of the effects this obligation has is to demonstrate to the parties that they have been heard and, when the decision is subject to appeal, to afford them the possibility to argue against it and have the decision reviewed by an appellate body.240 In this case, the SCJ’s decisions ordering the victims’ dismissal did not state the grounds for the decisions, yet these were the decisions that the alleged victims had to challenge when filing their appeals to the Council, which they had to do without knowing the grounds on which the decisions ordering their dismissal were based. The Commission believes this affected their ability to mount an adequate defense before the Council. 151. The Commission observes that after requesting copies of their disciplinary case files in the proceedings before the Council, the victims learned that those files contained decisions spelling out the reasons that supposedly justified the SCJ’s decision to dismiss them. Those decisions are signed by the Chief Justice of the Supreme Court and its Secretary, under a seal that reads “Office of the Chief Justice”. The signatures of the other members of the Supreme Court do not appear on the decision, nor is there any certification stating that the decisions are copies of an original. The Commission also notes that despite the questions that the petitioners raised at the domestic level and that the petitioners raised with the inter-American system, the State has been unable to prove that those decisions were duly notified. Thus, when the victims appeared for the appellate hearing, they had in their possession, on the one hand, the SCJ’s decision ordering their dismissal, without a sufficient statement of grounds and never formally notified, and on the other a decision by the Chair of the Council containing greater detail as to the grounds for their dismissal but which came to their attention only by chance, and without any explanation of its import and implications for the disciplinary proceedings. This situation necessarily hurt their chances of putting together, with the required legal certainty, an adequate defense strategy for their appearance before the Judicial Career Council on their appeal. 152. Given the foregoing, the Commission finds that the State violated article 8(1) and 8(2)(c) of the American Convention, to the detriment of Guillermo López Lone, Ramón Barrios, Luis Alonso Chévez de la Rocha and Tirza Flores Lanza. 3. Right to challenge the conviction and the right to a presumption of innocence 153. Concerning reviews of convictions, the United Nations Basic Principles provide that “[d]ecisions in disciplinary, suspension or removal proceedings should be subject to an independent review.”241 As the Office of the United Nations Special Rapporteur has written, “there should be some 240 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, paragraph 78. 241 Principle 20.