from that required by the principle of legality in criminal matters owing to the nature of the disputes that each one is intended to settle.126 130. Similarly, in the case of López Mendoza v. Venezuela, this Court asserted that problems regarding uncertainty of the sanctioning regulation do not, per se, give rise to a violation of the Convention; in other words, the fact that a regulation grants some type of discretion is not incompatible with the degree of predictability that the regulation should reveal, provided that the scope of the discretion and the way in which it should be exercised are indicated with sufficient clarity to provide adequate protection from arbitrary interference.127 131. In this case, the disciplinary proceedings were of a sanctioning nature; therefore, according to the Court’s case law, the guarantees of Article 9 of the Convention are applicable. In addition, in the case of disciplinary sanctions imposed on judges, compliance with the principle of legality is even more important because it constitutes a guarantee against external pressures on judges and, consequently, of their independence (supra paras. 105 and 106).128 On this point, the Statute of the Iberoamerican Judge establishes that: Art. 19. Principle of legality in the judge’s responsibility. Judges shall be held criminally, civilly and disciplinarily responsible pursuant to the provisions of the law. The requirement of responsibility shall not protect attacks on judicial independence that it is attempted to conceal by their official nature.129 132. Based on the arguments of the parties and of the Commission, the Court will examine whether paragraph 4 of Article 323 of the Organic Code of the Courts, applied to sanction the presumed victim in this case, complied with the principle of legality. The representatives also argued that the Supreme Court had violated the principle of legality by hearing the appeal filed by Judge Urrutia, when “it was this very court that, in first instance, had forwarded the academic paper to the court of La Serena so that it would sanction him.” The Court has already examined this argument in relation to the guarantee of impartiality and therefore finds it unnecessary to rule on it again. 133. Article 323 of the Organic Code of the Courts prohibits judicial officials from: 4. Publishing, without authorization from the President of the Supreme Court, documents defending their official conduct or attacking, in any way, that of other judges or justices. […] 134. This Court notes that paragraph 4 of Article 323 of the Organic Code of the Courts prohibits “attacking, in any way,” the conduct of other judges or justices. It does not establish the type of act that can be considered an attack, and the phrase “in any way” contains a high degree of uncertainty, so that it can be interpreted that this attack does not have to have been published. Thus, the regulation gives the authority responsible for exercising disciplinary powers broad discretion and therefore does not provide protection against the possibility that it may be used in an arbitrary manner. 135. This Court considers that, by sanctioning Mr. Urrutia Laubreaux under paragraph 4 of Article 323 of the Organic Code of the Courts, the Supreme Court of Chile used a regulation that permitted a discretion that was incompatible with the degree of predictability that the Cf. Case of Maldonado Ordóñez v. Guatemala. Preliminary objection, merits, reparations and costs, supra, para. 89, and Case of Rico v. Argentina. Preliminary objection and merits, supra, para. 102. 126 Cf. Case of López Mendoza v. Venezuela. Merits, reparations and costs. Judgment of September 1, 2011. Series C No. 233, para. 202, and Case of Rico v. Argentina. Preliminary objection and merits, supra, para. 102. 127 Bangalore Principles of Judicial Conduct adopted by the Judicial Group on Strengthening Judicial Integrity, supra, para. 1.1 to 1.6. 128 Iberoamerican Summit of Presidents of Supreme Courts and Tribunals of Justice. Statute of the Iberoamerican Judge, supra, article 19. 129 34