60 Legal Digest of International Fair Trial Rights judges during their term of office as a corollary of the independence of judges.208 This does not mean that judges must be appointed for life. Judicial appointments for fixed terms, with or without possibilities of reappointment, have been treated as consistent with judicial independence.209 The European Court of Human Rights has refrained from setting up a minimum term of appointment that would satisfy the requirement of independence. Clearly, however, the longer the term the more likely it is that the European Court would find a tribunal to have been established in compliance with Article 6(1) of ECHR. In Campbell and Fell v the United Kingdom, the European Court found that the appointment of members of a prison disciplinary body for terms of three years as “relatively short” but acceptable in view of the unpaid character of the assignment.210 Considerations of security of tenure also involve the conditions governing the promotion, adequate remuneration, pension, transfer, suspension or termination of office, or other conditions of service of a judge, which must all be adequately secured by law.211 The Human Rights Committee has explained that the dismissal of a judge by the executive prior to the expiry of a judge’s term of office may only be contemplated “on serious grounds of misconduct or incompetence, in accordance with fair procedures ensuring objectivity and impartiality set out in the constitution or the law”.212 The third feature of independence – adequate guarantees against outside pressures – will normally be met by virtue of the existence of mechanisms and procedures aimed at minimizing the risk of undue influence. If, however, the treatment of individual judicial officers is subject to executive control without measures in place to protect the judicial officers from being influenced, this will amount to a violation of the requirements of independence.213 The Human Rights Committee has explained, in this regard, that the functions and competencies of the judiciary and the executive must be clearly distinguishable.214 A situation where the executive is able to control or direct the judiciary is incompatible with the notion of an independent tribunal.215 For the distribution of cases among judges, for instance, proper rules and procedures will render external interference more difficult. The assignment (or re-assignment) of a case to a particular judge or court has been treated as falling within a State’s margin of appreciation. When assigning a case, authorities are entitled to take into account a wide range of factors, including available resources, the qualification of judges, 208 Campbell and Fell v the United Kingdom [1984] ECHR 8, para 80. 209 Le Compte, Van Leuven and De Meyere v Belgium [1981] ECHR 3, paras 26, 57.  210 Campbell and Fell v the United Kingdom [1984] ECHR 8, para 80. 211 UN Human Rights Committee, CCPR General Comment 32 (2007), para 19. 212 UN Human Rights Committee, CCPR General Comment 32 (2007), para 20. See, for example: Pastukhov v Belarus, HRC Communication 814/1998, UN Doc CCPR/C/78/D/814/1998 (2003), para 7.3; Mundyo Busyo et al. v Democratic Republic of Congo, HRC Communication 933/2000, UN Doc CCPR/C/78/D/933/2000 (2003), para 5.2; and Bandaranayake v Sri Lanka, HRC Communication 1376/2005, UN Doc CCPR/ C/93/D/1376/2005 (2008), para 7.3. 213 UN Human Rights Committee, Concluding Observations: Slovakia, UN Doc CCPR/C/79/Add.79 (1997), para 18; and Kadubec v Slovakia [1998] ECHR 81, paras 56–57. 214 UN Human Rights Committee, CCPR General Comment 32 (2007), para 19. 215 Oló Bahamonde v Equatorial Guinea, HRC Communication 468/1991, UN Doc CCPR/C/49/D/468/1991 (1993), para 9.4.