71 273. In the IACHR’s opinion, the procedures resulting from those applications do not amount to a suitable remedy for the recognition of indigenous property, in the above-mentioned terms, as they do not constitute specific mechanisms for addressing the titling of land occupied by the indigenous peoples or its demarcation, taking into account their particular characteristics, based on historical occupation of the land. They constitute, rather, a general mechanism for individual property titling, based on productive exploitation of the land, ignoring the special, unique, and internationally protected relationship between indigenous peoples and their ancestral territories, which is not found in the case of nonindigenous peoples. Similarly, the Court has pointed out in relation to indigenous territorial claim procedures that they invoke agrarian legislation, “wherein the yardstick is whether or not the claimed lands are rationally exploited, regardless of considerations specific to the indigenous peoples, such as what lands mean for 359 them.” 274. The Commission is well aware that the nonexistence of an appropriate remedy for recognition of indigenous ownership that takes the particular characteristics into account meant that the indigenous Community had considerable difficulty accessing justice, considering the oral tradition of the Garífuna Community of Triunfo de la Cruz, the language, scarcity of financial resources, and the fear expressed by lawyers regarding possible reprisals. Moreover, the Commission notes that the Garífuna culture is essentially oral, and, given the interest of third parties in their territories, they had to make arrangements for titling their lands and documenting their rights. In that way, they were forced to adapt their oral tradition and pursue existing legal mechanisms to substantiate and document their claims. 275. With respect to effectiveness, the IACHR notes that it is a documented fact that the territorial claims of the Community of Triunfo de la Cruz date back to 1946, and for decades the Community has filed at least seven applications with the Honduran authorities for recognition of its ancestral land. It has also been documented that over a period of time --1979, 1993 y 2001—it was given various titles recognizing its ancestral possession as well as its collective ownership of 615 hectares and 28.51 centiares. In the IACHR’s opinion, in the instant case, the lack of effectiveness of the mechanism that exists under domestic law is demonstrated by the fact that it was necessary to file multiple applications with the INA, given that the process was not designed for recognition of indigenous ownership based on historical occupation criteria. It notes that the territorial claim process, taken as a whole, began in 1946 and is still unfinished, given that even now the Community lacks a collective title deed to its ancestral territory. 276. The above also has to do with the applications filed by the Community and not resolved in a timely fashion by the INA, which made it necessary to file further applications. Thus, as was shown in the proven facts Section, for example, on June 27 1969, a file was submitted for adjudication of the river Plátano area, a process that was suspended in March 1996. The IACHR believes that at least at that time -- 27 years after the process began and almost 19 years after ratification of the American Convention by Honduras – proceedings were still pending. Likewise, it is considered proven that on September 8, 1997 and July 8, 1998 the Community filed applications with the INA for titling of part of the ancestral territory without it being shown that the proceedings ended with a final decision. 277. In addition, the IACHR considers that the ineffectiveness of the proceedings with the INA is shown, as was indicated earlier, by the fact that they did not lead to the effective demarcation, delimitation, and regularization of the titled areas, which prevented peaceable possession of the land. Although the State argued that the administrative procedure involved a regularization phase ending in compensation of improvements carried out by outsiders on the Community’s land, it was not proved in the instant case that such regularization actually took place. On the contrary, the State itself asserted that it had not been carried out because of the economic outlays involved. Nevertheless, as the IACHR indicated, States may not use domestic circumstances as an excuse for failing to comply with their international organizations. 359 I/A Court H.R. Case of the Sawhoyamaxa Indigenous Community v Paraguay. Merits, Reparations, and Costs. Judgment of March 29, 2006. Series C No. 146, paragraph 104. Likewise, see Case of the Xákmok Kásek Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of August 24, 2010 Series C No. 214, paragraph 146.