5 absence of effective judicial remedies for the protection of the rights of indigenous peoples. In that regard, the structural nature of this problem means that the case may have a significant impact on the recognition and exercise of the rights of indigenous peoples in Suriname, an impact that goes beyond the victims of the case. In addition, the violations of the right to property in the instant case require further development in the case-law in at least three respects. First, the Court is called upon to make an analysis of the restrictions on the right to property when there is tension between the private or individual property rights of non-indigenous persons and the collective property rights of an indigenous people. Specifically, the Court will have an opportunity, at the moment of weighing both types of property rights, to give specific effect to its case-law on the special link indigenous peoples have with their land and its importance for the survival of the people as such. In addition, the instant case poses a debate not yet addressed in detail in the caselaw of the Court related to how the states should make their initiatives and policies in the area of environmental protection compatible with the rights of indigenous peoples. Concretely, the Court will have the opportunity to develop standards applicable to the establishment of natural reserves where they may have a negative impact on the lands, territories, and natural resources of indigenous peoples. This analysis includes both the obligation to consult with a view to obtaining the consent of indigenous peoples, and the need to explore the environmental conservation alternatives least harmful to the rights of indigenous peoples. In light of these issues, which have a significant impact on inter-American public order, in keeping with Article 35(1)(f) of the Inter-American Court’s Rules of Procedure, the Commission takes this opportunity to offer the following expert witnesses: xxxxxxxxxxxx, who will testify on the international standards and, as relevant, comparative law, applicable to situations of tension between the right to private property of non-indigenous persons and the collective property rights of indigenous peoples. The expert will offer the Court a model for analyzing restrictions on rights that takes into account and gives effect to the particularities of indigenous peoples’ the right to property. The expert will also indicate the possible means of compensation that a State would have to activate in response to the result of this analysis of restrictions. To the extent pertinent, the expert will apply the standards and analytical model proposed to the facts of the specific case. xxxxxxxxxxxx, who will testify on the international standards and, as relevant, comparative law applicable to situations of real or apparent tension between the rights of indigenous peoples and environmental protection. The expert will offer elements of analysis that enable the Inter-American Court to establish the scope of state obligations in relation to the right to property of indigenous peoples when designing and implementing environmental protection initiatives and polices.

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