A/HRC/11/41 page 17 56. The Special Rapporteur also notes that probationary periods for judges are used by some Member States. Specific safeguards need to be established in order to prevent that such short initial appointments turn into a risk for the independence of the judiciary.69 In the Special Rapporteur’s view, a short, non-extendable, probationary period may be employed, provided that life appointment or fixed tenure is automatically granted afterwards, except for probationary judges who were dismissed as a consequence of disciplinary measures or the decision of an independent body following a specialized procedure that determined that a certain individual is not capable of fulfilling the role of a judge.70 In any case, the Special Rapporteur is concerned that the requirement of re-appointment following a probationary period runs counter to the principle of the independence of judges.71 57. Independently of whether the mandate of the judge is for life or for a limited period of time, it is crucial that tenure be guaranteed through the irremovability of the judge for the period he/she has been appointed. The irremovability of judges is one of the main pillars guaranteeing the independence of the judiciary. Only in exceptional circumstances may the principle of irremovability be transgressed. One of these exceptions is the application of disciplinary measures, including suspension and removal. As the Special Rapporteur noted in one of his country mission reports, the law must give detailed guidance on the infractions by judges triggering disciplinary measures, including the gravity of the infraction which determines the kind of disciplinary measure to be applied in the case at hand.72 This requirement is also reflected on Recommendation N. R (94) 12, principle VI (2). 58. In this connection, the Special Rapporteur recalls that disciplinary measures to be adopted must be in proportionality to the gravity of the infraction committed by the judge. Therefore, he calls for the adoption of a well-defined scheme of available disciplinary measures.73 In this context, the Special Rapporteur underscores that judges must not be removed from office because of errors in judicial decisions or because their decision has been overturned on appeal or review by a higher judicial body. This has also been confirmed by the Human Rights Committee on several occasions.74 69 CCPR/CO/75/MDA, para. 12. 70 A/HRC/11/41/Add.2, para. 99. 71 Ibid., para. 57. 72 Ibid., para. 99. 73 See for examples of different disciplinary measures, see Recommendation No. R (94) 12 (footnote 14), principle VI (1). 74 CCPR/CO/75/VNM, para. 10; CCPR/CO/71/UZB, para. 14.