32 125. In connection with the relationship between the right enshrined in Article 25 of the Convention and the obligations set out in Articles 1.1 and 2 thereof, the Court has ruled that: Article 25 is closely linked to the general obligation in Article 1.1 of the American Convention, in that it assigns duties of protection to the States Parties through their domestic legislation, from which it is clear that the State has the obligation to design and embody in legislation an effective recourse, and also to ensure the due application of the said recourse by its judicial authorities. 91 At the same time, the State’s general duty to adapt its domestic law to the stipulations of said Convention in order to guarantee the rights enshrined in it, established in Article 2, includes the enactment of regulations and the development of practices that seek to achieve an effective observation of the rights and liberties enshrined in it, as well as the adoption of measures to suppress the regulations and practices of any nature that imply a violation to the guarantees established in the Convention. 92 126. Regarding judicial protection in cases of removal of judges, the Human Rights Committee held that the removal of judges before the expiry of the term for which they were appointed without giving any concrete reason whatsoever and without affording them any effective judicial protection to challenge the removal is incompatible with judicial independence. 93 In addition, the Commission has considered that the impossibility of having an effective remedy against alleged acts in violation of the right to stability as a judge constituted a violation of Article 25 of the American Convention. 94 127. According to what is set forth in the preceding paragraphs, international law establishes that judges should have a judicial body before which they can question the legality of their removal. In addition, that review body should be previously established and include adequate guarantees of impartiality and independence, and an institutional design in keeping with the nature of the remedy. In this case, the information available indicates that in Ecuador there was no specific remedy or mechanism by which to question either the removal of the judges by resolution of the National Congress or the removal by impeachment. In these circumstances, the only jurisdiction the judges of the Constitutional Court could turn to were the regular actions provided for in domestic law. 128. The Commission observes that five of the victims filed amparo actions against the resolution of the National Congress that terminated them. Based on the facts proven in this report, these amparo actions were systematically rejected by the civil judges who heard them. In particular, from the information available one can note that the results of those actions in which the resolution questioned was initially annulled and the parties were called to a hearing were subsequently revoked based on the resolution of the Constitutional Court elected November 25, 2004. In addition, the victims did not file motions of appeal against the rejection of the judges of first instance, given that 91 I/A Court H.R., Reverón-Trujillo v. Venezuela Case. Preliminary Objection, Merits, Reparations, and Costs. Judgment of June 30, 2009. Series C No. 197. Para. 60. Citing: c.f. Case of the Street Children (Villagrán Morales ‘‘et al.) v. Guatemala, Merits, Judgment of November 19, 1999, Series C No. 63, para. 237; Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua, Merits, Reparations, and Costs, Judgment of August 31, 2001, Series C No. 79, para. 135; and Case of the Yakye Axa Indigenous Community v. Paraguay, Merits, Reparations, and Costs, Judgment of June 17 2005, Series C No. 125, para. 99. 92 I/A Court H.R., Reverón-Trujillo v. Venezuela Case. Preliminary Objection, Merits, Reparations, and Costs. Judgment of June 30, 2009. Series C No. 197. Para. 60. Citing: c.f. Case of Castillo Petruzzi v. Peru, Merits, Reparations, and Costs, Judgment of May 30, 1999, Series C No. 52, para. 207. 93 United Nations, Human Rights Committee, General Comment No. 32, Article 14: Right to equality before courts and tribunals and to a fair trial, CCPR/C/GC/32, August 23, 2007, para. 20. 94 IACHR, Report No. 30/97, Case 10,087, Merits, Gustavo Carranza , Argentina, September 30, 1997, para. 72.

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