indigenous land tenure vis‐à‐vis the acts of third parties or of State agents, and “this merely abstract or legal recognition of indigenous lands, territories or resources, is practically meaningless if the property is not physically delimited and established.” 210 170. In the instant case, there is no dispute regarding the duty to delimit, demarcate and title the territory, because the State has already met these obligations and the territory in question is currently titled in favor of the said Garifuna community. However, it is necessary to define the relevance and scope of the obligation to effectively ensure the use and enjoyment of the indigenous property which is directly recognized by Article 21 of the American Convention. B.2.1 Obligation to ensure the use and enjoyment of collective property under international law 171. In this section, the Court will refer to the principal general standards concerning the use and enjoyment of indigenous and tribal property, notwithstanding the specific considerations applicable to this particular case. 172. Regarding the use and enjoyment of indigenous and tribal territory, the Court recalls its case law according to which, inter alia: “(1) traditional possession of their lands by indigenous people has equivalent effects to those of a State-granted full property title; (2) traditional possession entitles indigenous people to demand official recognition and registration of property title; (3) the members of indigenous peoples who have unwillingly left their traditional lands, or lost possession thereof, retain property rights thereto, even though they lack legal title, unless the lands have been lawfully transferred to third parties in good faith, and (4) the members of indigenous peoples who have unwillingly lost possession of their lands, when those lands have been lawfully transferred to innocent third parties, are entitled to restitution thereof or to obtain other lands of equal extension and quality.” 211 Additionally, in the Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua, the Court found that States must guarantee effective ownership by the indigenous peoples and refrain from acts which could result in agents of the State itself or third parties acting with its acquiescence or its tolerance, affecting the existence, value, use or enjoyment of the territory. 212 In the Case of the Saramaka People v. Suriname, it was established that States must guarantee the right of indigenous peoples to effectively own and control their territory without outside interference of any kind. 213 In the Case of the Kichwa Indigenous People of Sarayaku v. Ecuador, the Court established that States must ensure the right of the indigenous peoples to control and use their territory and natural resources. 214 The Inter-American Commission has also ruled in this regard. 215 210 Cf. Case of the Yakye Axa Indigenous Community, supra, para. 143, and Case of the Kuna Indigenous People of Madungandí and the Emberá Indigenous People of Bayano and their members, supra, para. 135. 211 Cf. Case of the Sawhoyamaxa Indigenous Community, supra, para. 128, and Case of the Xákmok Kásek Indigenous Community, supra, para. 109.. 212 Cf. Case of the Mayagna (Sumo) Awas Tingni Community, supra, para. 164, and Case of the Kuna Indigenous People of Madungandí and the Emberá Indigenous People of Bayano and their members, supra, para. 232. 213 Case of the Saramaka People v. Suriname. Preliminary objections, merits, reparations and costs. Judgment of November 28, 2007. Series C No. 172, para. 115. 214 Case of the Kichwa Indigenous People of Sarayaku v. Ecuador. Merits and reparations. Judgment of June 27, 2012. Series C No. 245, para. 146. 215 In its Report on Indigenous and Tribal Peoples’ Rights over their Ancestral Lands and Natural Resources, the Inter-American Commission systematized some criteria to be taken into account whenever there are property disputes with third parties. The Commission indicated that “indigenous and tribal peoples 51