complicated to the point of making it impossible, in practice, to hold a legal strike; and c) the obligation to give notice to the employer before calling a strike is admissible, provided that such notice is reasonable. 43 22. Regarding the second element (the power to declare the strike illegal), the InterAmerican Court has held that this power should not be vested in an administrative body, but rather in the Judiciary, in application of the grounds previously established by law, and in accordance with the rights to judicial guarantees established in Article 8 of the American Convention. Furthermore, the Inter-American Court considers that the State must refrain from applying sanctions to workers when they participate in a legal strike, since it is a lawful trade union activity that also constitutes the exercise of a human right, and must ensure that such sanctions are not applied by private companies. 44 23. Finally, the right to strike may only be limited or prohibited with respect to: a) public officials acting as organs of the public administration exercising authority on behalf of the State, and b) workers in essential services. 45 Regarding the latter, the InterAmerican Court has considered that they should be understood in the strict sense of the term, that is, those who provide services whose disruption poses a clear and imminent threat to the life, safety, health or liberty of all or part of the population (for example, workers in hospitals, electricity or water supply services). 46 However, with respect to these workers, the Court has pointed out that States must create compensatory guarantees in favor of those services considered essential and for the public administration, so that the limitation of the right to strike must be accompanied by adequate, impartial and expeditious conciliation and arbitration procedures in which the interested parties may participate at all stages, and in which the decisions issued are fully and promptly enforced. 47 24. In sum, although the right to strike has had little development within the framework of the regional human rights systems, we cannot deny the importance of this right, especially in the collective aspect of workers’ rights. IV. THE RIGHT TO STRIKE AS A JUSTICABLE RIGHT IN THE CONTENTIOUS CASE LAW OF THE INTER-AMERICAN COURT 25. The right to strike is a basic right that is closely related to workers’ rights; the way in which inter-American labor law has gradually developed is a process in which the 43 Cf. Advisory Opinion OC-27/21, supra, para. 100. 44 Cf. Advisory Opinion OC-27/21, supra, para. 101. Cf. Advisory Opinion OC-27/21, supra, para. 102. The Court has also stated that: “104. […] in relation to essential services, the Court emphasizes that States should seek alternative solutions for those cases in which the total prohibition of strikes can be avoided when a minimum service would be an adequate solution to guarantee the basic needs of users or the safe operation of the facilities in which the service considered "essential" is provided. In this regard, it should be emphasized that the minimum service must be limited to those operations that are necessary to meet the basic needs of the population or the minimum requirements of the service, ensuring that the scope of the minimum services does not result in the strike becoming inoperative. Negotiations on minimum services should take place before a labor dispute has arisen, so that all parties concerned (public authorities, workers' and employers' organizations) can negotiate as objectively and calmly as possible.” 45 46 Cf. Advisory Opinion OC-27/21, supra, para. 103. 47 Cf. Advisory Opinion OC-27/21, supra, para. 103. 8