54 European Court wrote that the principle of legality requires not only that the impugned measure should have some basis in domestic law, but also refer to the quality of the law in question. The law should be accessible to the persons concerned and formulated with sufficient precision to enable them – if need be, with appropriate advice – to foresee, to a degree that is reasonable in the circumstances, the consequences which a given action may entail.271 As the Inter-American Court has held, “[i]n the disciplinary sphere, it is essential to indicate the violation precisely and to submit arguments that allow it to be concluded that the comments provide sufficient grounds to justify removing a judge from a post.” 272 176. From this standpoint, the grounds for removal of judges established by constitutional law may be set out in more or less general and abstract terms, given the nature of constitutional clauses. However, when embodied in a disciplinary system, those constitutional clauses must be restated in very precise terms that clearly establish what the prohibited behaviors are.273 As the InterAmerican Court wrote in its judgment on a case in which the principle of strict legality also should have been applied, this means establishing a clear definition of the punishable conduct and its elements, so as to distinguish that conduct from non-punishable behaviors.274 This is essential to enable judges to steer their behavior according to an established legal system.275 Vague and broad disciplinary systems that give an unacceptable margin of discretion to the authorities charged with conducting proceedings in which magistrates and judges are tried, are incompatible with the American Convention.276 The United Nations Special Rapporteur on the Independence of Judges and Lawyers has written that “the law must give detailed guidance on the infractions by judges triggering disciplinary measures, including the gravity of the infraction which determines the kind of disciplinary measure to be applied in the case at hand.”277 2. Analysis of the present case a. Concerning the absence of a connection between the articles cited and the conduct for which the victims were disciplined. provides that “Disciplinary action against a judge can only be taken when provided for by pre-existing law and in compliance with predetermined rules of procedure.” Article 11 of the Universal Charter of the Judge, unanimously approved by the delegates attending the meeting of the Central Council of the International Association of Judges in Taipei (Taiwan) on November 17, 1999. 271 ECHR. Case of Maestri v. Italy (Application no. 3974/98). Judgment. Strasbourg, 17 February 2004, p. 30. 272 I/A Court H.R. Case of Chocrón Chocrón v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2011. Series C No. 227, paragraph 120. 273 Cf. I/A Court H.R. Case of Usón Ramírez v Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, paragraph 55. 274 Cf. I/A Court H.R. Case of Usón Ramírez v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, paragraph 55 and Cf. Case of Baena Ricardo et al. v. Panama. Merits, Reparations and Costs. Judgment of February 2, 2001. Series C No. 72, paragraphs 105-107. 275 Cf. I/A Court H.R. Case of Baena Ricardo et al. v. Panama. Merits, Reparations and Costs. Judgment of February 2, 2001. Series C No. 72, paragraphs 106 and 108. 276 Cf. 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, paragraphs 43 and 44. 277 United Nations, Report of the Special Rapporteur on the Independence of Judges and Lawyers, A/HRC/11/41, March 24, 2009, paragraph 57.