44 Human Rights Defenders concluded that the protection accorded to defenders “is not dependent on whether the focus of the work of the defenders […] is on civil and political rights or on economic, social and cultural rights.”191 148. Furthermore, in accordance with the case law of this Court192 and the European Court of Human Rights,193 there is an undeniable link between the protection of the environment and the enjoyment of other human rights. The ways in which the environmental degradation and the adverse effects of the climate change have impaired the effective enjoyment of human rights in the continent has been the subject of discussion by the General Assembly of the Organization of American States194 and the United Nations.195 It should also be noted that a considerable number of States Parties to the American Convention have adopted constitutional provisions which expressly recognize the right to a healthy environment.196 and 103; Case of the Girls Yean and Bosico v. Dominican Republic. Preliminary Objections, Merits, Reparations, and Costs. Judgment of September 8, 2005. Series C No. 130, paras. 142, 173 and 185; Case of Ximenes-Lopes v. Brazil. Merits, Reparations and Costs. Judgment of July 4, 2006. Series C No. 149, paras. 89, 90, 99 and 104; Case of the Sawhoyamaxa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of March 29, 2006. Series C No. 146, paras. 121, 164, 168 and 172; and García-Santa Cruz. Preliminary Objection, Merits, Reparations, and Costs, supra note 183, paras. 144 and 146. 191 Cf. Report submitted by Ms. Hina Jilani, Special Representative of the Secretary-General on the situation of human rights defenders. A/HRC/4/37 January 24, 2007. See website: http://daccessdds.un.org/doc/UNDOC/GEN/G07/104/20/PDF/G0710420.pdf 192 Particularly, in contentious cases and provisional measures regarding the rights of the members of indigenous communities and the special relationship they have with the land. Cf. Matter of Pueblo indígena de Sarayaku regarding Ecuador. Provisional Measures. Order of the Court of June 17, 2005, Considering clause No. 9; Case of the Mayagna Community (Sumo) Awas Tingni. Judgment of August 31, 2001. Series C No. 79, paras. 144, 149. Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, paras. 131, 137, and 141; Case of the Sawhoyamaxa Indigenous Community. Merits, Reparations and Costs, supra note 190, paras. 118, 121 and 131; Case of the Saramaka People. v. Suriname. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007. Series C No. 172, paras. 121, 122, 123, 126, 128 and 146. 193 Cf. European Court of Human Rights (ECHR), cases of Guerra and others v. Italy, (1998); Lopez Ostra v. Spain, (1994), and Fadeyeva v. Russia (2005). 194 Cf. Resolutions OEA/Ser.P AG/RES. 1819 (XXXI-O/01) “Human Rights and the Environment,” approved at the third plenary session held on June 5, 2001 (available at: http://www.oas.org/juridico/spanish/ag01/agres_1819.htm) AG/RES. 1896 (XXXII-O/02) “Human Rights and the Environment in the Americas,” approved at the fourth plenary session held on June 4, 2002 (available at: http://www.oas.org/juridico/spanish/ag02/agres_1896.htm); and AG/RES. 1926 (XXXII-O/03) “Human Rights and the Environment in the Americas,” approved at the fourth plenary session held on June 10, 2003 (available at: http://www.oas.org/juridico/spanish/ag03/agres_1926.htm); AG/RES. 2349 (XXXVII-O/07) “Water, Health and Human Rights,” approved at the fourth plenary session held on June 5, 2007 (available at: http://www.oas.org/dil/esp/AG-RES_2349_XXXVII-O07.doc), and AG/RES. 2429 (XXXVIII-O/08) “Human Rights and Climate Change in the Americas,” approved at the fourth plenary session held on June 3, 2008 (available at: http://www.oas.org/DIL/ESP/AGRES_2429.doc). 195 Cf. Resolution 2005/60 adopted by the United Nations Commission on Human Rights, entitled “Human rights and the environment as part of sustainable development,” approved on April 10, 2005, E/CN.4/2005/L.10/Add.17 (available at: http://ap.ohchr.org/documents/S/CHR/resolutions/E-CN_4-RES-200560.doc) 196 Cf. Constitution of the Argentine Republic, Article 41; Constitution of the Federative Republic of Brazil Art. 225; Constitution of the Republic of Chile, Art. 19(8); Constitution of the Republic of Colombia, Art. 79; Constitution of the Republic of Ecuador, Art. 14; Constitution of Haiti, Arts. 253 and 254; Constitution of the United Mexican States, Art. 4; Constitution of the Republic of Nicaragua, Art. 60; Constitution of the Republic of Panamá, Arts. 118 to 121; Constitution of the Republic of Paraguay, Art. 7, Constitution of the Republic of Perú, Art. 2(22); Constitution of the Bolivarian Republic of Venezuela, Art. 127.