however have to be guarded by statute but should be assessed on all the basis of all the facts that are publicly known. 83. Also relevant is security of tenure.657 This includes procedures for dismissal, promotion, remuneration, suspension and termination of office and guarantees against irremovability.658 These procedures must be secured in law.659 84. Guarantees from external pressure: Independence also requires that each judge and tribunal member be free from outside instructions or pressure, whether from the executive, legislature, parties to the case or other members of the court or tribunal. The executive should not be able to control or direct the judiciary.660 85. A perception of independence is also important, although the possibility of influence may not necessarily amount of a lack of independence.661 86. Judges should enjoy personal immunity from civil suits in respect of acts done while exercising their judicial functions.662 The Special Rapporteur on the independence of judges and lawyers has also suggested there should be some form of criminal immunity.663 Such immunity should be balanced against the need to ensure the accountability of judges. Impartiality 87. The requirement for an impartial court or tribunal embodies the protection against actual and presumed bias. 88. This is both subjective: the judges themselves should not allow themselves to be influenced by their own bias or preconceptions; and objective: the external observer must consider the court or tribunal to be impartial.664 89. Subjective bias may be displayed by for example biased directions to the jury.665 90. Objective bias requires not only that the state protect the judiciary from conflicts of interest,666 but also that there is a responsibility on the individual judge to excuse themselves from any cases in which such conflicts may arise. ‘What 657 General Comment No.32, CCPR/C/GC/32 (2007), para 19. Basic Principles on the Independence of the Judiciary, Principle 12. 658 Special Rapporteur on Independence of judges and lawyers, A/HRC/11/41/Add.2, para 99. 659 Human Rights Committee General Comment No.32, CCPR/C/GC/32 (2007), para 20; Pastukhov v Belarus, Communication 814/1998, UN Doc.CCPR/C/78/814/1998 (2003, para 7.3. 660 Communication 468/1991, Oló Baramonde v Equatorial Guinea, 20 October 1993, para 9.4. 661 Belilos v Switzerland, [1998] ECHR 4, para 67. 662 Basic Principles on the independence of judges and lawyers. 663 A/HRC/11/41, para 66. 664 Human Rights Committee, General Comment No.32, CCPR/C/GC/32 (2007), para 21; Communication 387/1989, Kartunnen v Finland, 23 October 1992, para 7.2. 665 Communication 349/1988, Wright v Jamaica, 27 July 1992, para 3.3. 666 Human Rights Committee General Comment No.32, CCPR/C/GC/32 (2007), para 19. 115