right to the due process of law that applies in criminal matters.118 To reinforce this position, in the Judgment in the instant case,119 the Inter-American Court also based itself on the case of Baena Ricardo et al. v. Panama, which indicates, inter alia, “that the series of minimum guarantees established in paragraph 2 of Article 8 of the Convention apply to the spheres mentioned in paragraph 1 of this article; that is the determination of rights and obligations of a civil, labor, fiscal, or any other nature. This reveals the broad scope of due process; the individual has the right to due process understood in the terms of Article 8(1) and 8(2), in both criminal matters and in all these other spheres.” 120 84. It should be stressed that, in the Judgment that prompts this opinion, the ICourtHR does not make a specific analysis of the meaning that the 2001 precedent attributes to the expression “in general,”121, which is fundamental in order to determine whether each and every one of the “minimum guarantees” established in Article 8(2) apply to spheres other than criminal matters and, specifically, if they all apply to impeachment. However, the Judgment declared the violation of Article 8(2) (for different forms of adequate defense) and 8(4) (the guarantee of ne bis in idem). I consider that, in the future, the InterAmerican Court will have to clarify, precisely, the full applicability – or case by case – of the “minimum guarantees” established in Article 8(2) for the other non-criminal procedures and proceedings; a matter of extreme importance for understanding due process under the Convention, and over and above the specific case of impeachment. 85. As established in the Judgment, when the Court considers its own most representative precedents, it must be understood that judges can only be removed based on serious disciplinary offenses or incompetence, and in accordance with proceedings with due guarantees, or when their mandate has ended. Removal can never be the result of an arbitrary measure, and this must be examined in light of the existing domestic context and the circumstances of the specific case.122. C) The violation of different rights established in Articles 8 of the American Convention, as well as of Articles 23(1)(c) and 25 of the Pact of San José in this case 86. In the instant case, in order to reveal the different violations of due process in the impeachment proceedings filed against the members of the Constitutional Tribunal, it is sufficient to refer to the proven facts and to the domestic law in force and applicable in this respect, which is outlined in the Judgment. 87. At the time of the facts, articles 92 and 93 of the Organic Law on the Legislative Function indicated that the time frame for filing impeachment proceedings after the presentation of the respective motion was 5 to 10 days in cases of ordinary sessions of Congress and 30 days in the case of special sessions, and that this period could be extended for up to 60 days. However, when the impeachment proceeding started, these time frames had expired. Also, when Congress decided on the impeachments, the context Case of the Constitutional Court v. Peru. Merits, reparations and costs. Judgment of January 31, 2001. Series C No. 71, para. 70. 118 119 Para. 167 of the Judgment. Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 125. 120 Case of the Constitutional Court v. Peru. Merits, reparations and costs. Judgment of January 31, 2001. Series C No. 71, para. 70. 121 122 Para. 200 of the Judgment. 23