65 damage caused by natural resource exploration and exploitation concessions exacerbates the violations 321 of communal property right by the authorities, and render them internationally liable. In this regard, the IACHR has reiterated that it “acknowledges the importance of economic development for the prosperity of 322 the populations of this Hemisphere;” but it also acknowledges that “at the same time, development activities must be accompanied by appropriate and effective measures to ensure that they do not proceed at the expense of the fundamental rights of persons who may be particularly and negatively affected, including indigenous communities and the environment upon which the depend for their physical, cultural 323 and spiritual well-being.” 253. For its part, in the cases of the Saramaka People v. Suriname and the Kichwa Indigenous People of Sarayaku v Ecuador, the inter-American Court has established that in the event of restrictions or limitations on the exercise of the indigenous peoples’ property right to their lands, territories, and natural resources, the States have a duty to comply with the provision of certain guarantees. First, the Court has pointed out that States must comply with the requirements established for instances of expropriation in Article 21 of the American Convention on Human Rights. As the Court explained “the protection of the right to property under Article 21 of the Convention is not absolute […] Although the Court recognizes the interconnectedness between the right of members of indigenous and tribal peoples to the use and enjoyment of their lands and their right to those resources necessary for their survival, said property rights, like many other rights recognized in the Convention, are subject to certain limitations and restrictions. In this sense, Article 21 of the Convention states that the “law may subordinate [the] use and enjoyment [of property] to the interest of society”. Thus, the Court has previously held that, in accordance with Article 21 of the Convention, a State may restrict the use and enjoyment of the right to property where the restrictions: a) previously established by law; b) necessary; c; proportional, and d) with the aim 324 of achieving a legitimate objective in a democratic society.” 254. The second requirement that is binding upon States is to ensure that the granting of a concession does not affect the survival of the indigenous or tribal people concerned in accordance with its ancestral way of life. As the inter-American Court states, “another crucial factor to be considered is whether the restriction amounts to a denial of their traditions and customs in a way that endangers the 325 very survival of the group and its members.” As the Court pointed out in its interpretation judgment in the Saramaka case, the notion of “survival” is not to be equated with mere physical subsistence but “must be understood as the ability of the Saramaka to “preserve, protect and guarantee the special relationship that [they] have with their territory”, so that “they may continue living their traditional way of life, and that their distinct cultural identity, social structure, economic system, customs, beliefs and traditions are respected guaranteed and protected […]”. That is, the term “survival” in this context signifies much more 326 than physical survival.” Likewise, for the IACHR “the term ‘survival’ does not refer only to the obligation of the State to ensure the right to life of the victims, but rather to take all the appropriate measures to 327 ensure the continuance of the relationship of the indigenous people with their land or their culture.” 321 IACHR, Report No. 40/04, Case 12.053, Maya Indigenous Communities of the Toledo District (Belize), October 12, 2004, paragraph 148. 322 IACHR, Report No. 40/04, Case 12.053, Maya Indigenous Communities of the Toledo District (Belize), October 12, 2004, paragraph 150. 323 IACHR, Report No. 40/04, Case 12.053, Maya Indigenous Communities of the Toledo District (Belize), October 12, 2004, paragraph 150. 324 I/A Court H.R. Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007. Series C No. 172, paragraph 127. I/A Court H.R. Case of the Kichwa Indigenous People of Sarayaku v. Ecuador. Merits and Reparations. Judgment of June 27, 2012. Series C No. 245. paragraph 156. 325 I/A Court H.R. Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007. Series C No. 172, paragraph 128. I/A Court H.R. Case of the Kichwa Indigenous People of Sarayaku v. Ecuador. Merits and Reparations. Judgment of June 27, 2012. Series C No. 245. paragraph 156. 326 I/A Court H.R. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 37. 327 I/A Court H.R. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 29.