Chapter iii  Right to a Hearing by a Competent, Independent and Impartial Tribunal Established by Law 59 also 3.3.4), tribunals of faceless judges (See also 3.3.5) and religious courts or courts based on customary law (See also 3.3.6). 3.3.1 Independence of a tribunal In determining whether a body can be considered to be independent, regard must be had to four main features: (a) The manner in which judicial officers are appointed;202 (b) The security of tenure of judicial officers, i.e., the duration of their term of office and the general principle that they should not be subject to removal;203 (c The existence of adequate guarantees protecting the tribunal and its members from external pressures;204 and (d) An outward appearance that the tribunal is independent.205 Concerning the manner in which judicial officers are appointed, the fact that members of a tribunal are appointed by the executive does not itself violate the requirements of independence. In Campbell and Fell v the United Kingdom, for example, the appointment of members of Parole Boards for England and Wales by the British Home Secretary was not, by itself, considered to mean that those members were not independent of the executive, even though the Office could issue the Boards with guidelines as to the performance of their functions.206 The European Court of Human Rights found, inter alia, that there was a sufficient guarantee of independence due to the fact that the members of the Boards were not subject to the British Home Secretary’s instructions in their adjudicatory role.207 Security of tenure requires that, during their term of office, judicial officers must enjoy a le­vel of independence such that they do not fear that decisions made contrary to any asserted or implied pressure would result in their removal from office or a detriment to their conditions of service. The European Court of Human Rights has described the irremovability of 202 UN Human Rights Committee, CCPR General Comment 32 (2007), para 19; Le Compte, Van Leuven and De Meyere v Belgium [1981] ECHR 3, para 57; and Campbell and Fell v the United Kingdom [1984] ECHR 8, para 78; Findlay v the United Kingdom [1997] ECHR 8, para 73; Bochan v Ukraine [2007] ECHR, para 65; Moiseyev v Russia [2008] ECHR 1031, para 173. 203 UN Human Rights Committee, CCPR General Comment 32 (2007), para 19; and Campbell and Fell v the United Kingdom [1984] ECHR 8, paras 78, 80; Findlay v the United Kingdom [1997] ECHR 8, para 73; Bochan v Ukraine [2007] ECHR, para 65; Moiseyev v Russia [2008] ECHR 1031, para 173. 204 UN Human Rights Committee, CCPR General Comment 32 (2007), para 19; Piersack v Belgium [1982] ECHR 6, para 27; and Campbell and Fell v the United Kingdom [1984] ECHR 8, para 78; Findlay v the United Kingdom [1997] ECHR 8, para 73; Bochan v Ukraine [2007] ECHR, para 65; Moiseyev v Russia [2008] ECHR 1031, para 173. 205 Delcourt v Belgium [1970] ECHR 1, para 31; and Campbell and Fell v the United Kingdom [1984] ECHR 8, para 78; Findlay v the United Kingdom [1997] ECHR 8, para 73; Bochan v Ukraine [2007] ECHR, para 65; Moiseyev v Russia [2008] ECHR 1031, para 173. 206 Campbell and Fell v the United Kingdom [1984] ECHR 8, para 79. 207 Campbell and Fell v the United Kingdom [1984] ECHR 8, para 79.