a) Richard Pané, Ramses Kajoeramari, Henry Zaalman, Romeo Pierre, Harold Galgren, Leo Maipio, Jona Gunther, Frans Pierre, village leaders of the Kaliňa and Lokono Peoples of the Lower Marowijne River; b) The Vererniging van Inheese Dorpshoofden in Suriname (“VIDS”), which is known in English as the Association of Indigenous Village Leaders in Suriname. VIDS is an association of indigenous leaders from each of the 46 indigenous villages in Suriname. According to the petition, this association was established in 1992 to promote and defend the rights of indigenous peoples; c) The Commissie Landrechten Inheemsen Beneden-Marowijne (“CLIM”), which is known in English as the Lower Marowijne Indigenous Land Rights Commission, CLIM is described as the “working arm”2 of the Association of Indigenous Village Leaders in Suriname and was created in 2003 to enhance the efforts of the Lower Marowijne Peoples to obtain title to their traditional territory. According to the Petitioners, CLIM is headed by a board comprised of the eight village leaders, as well as other members of the village councils of their villages. 12. The petition states that the alleged victims are the Kaliňa and Lokono Peoples of the Lower Marowijne River , their eight constituent communities, and the members thereof. According to the Petitioners, the traditional territory of the Lower Marowijne Peoples is situated on the northeast coast of Suriname and is composed of moist and dry tropical forests, savannahs, coastal mangrove forests, beaches, coastal seas, inland waterways, and a variety of wetlands. The Petitioners state that the Lower Marowijne Peoples have occupied their territory for at least 2000 to 3000 years. The total resident population of the Lower Marowijne Peoples (distributed among the eight communities) is approximately 2026 persons. 13. According to the Petitioners, the territory of the Lower Marowijne Peoples represents “the foundation of their spiritual, cultural and physical sustenance and well-being, and is integral to their cosmologies and views of the world.”3 The Petitioners maintain that the culture and identities of the Kaliňa and Lokono Peoples are “thus inextricably tied to the maintenance of their ongoing and multiple relationships with their traditional territory and it resources.”4 14. In accordance with customary law, the Petitioners state that paramount title to the territory as a whole is vested collectively and jointly in the Kaliňa and Lokono Peoples, and that subsidiary rights to communal and land resource ownership are vested in extended kindship groups associated with each of the eight villages. These land and resource ownership rights apply to defined areas of their traditional territory and the boundaries of the various villages are clearly understood and observed. The Petitioners further state that within the village lands, members have rights of occupation and use over specific areas associated with their immediate family as well as rights in communal areas not associated with any particular family group. 15. According to the Petitioners, the traditional territory of the Lower Marowijne Peoples provides for “the vast majority of their subsistence needs and is extensively used for hunting, fishing (inland and coastal), swidden agriculture, and the harvesting and gathering of forest produce.”5 The Petitioners contend that traditional resources gathered in the territory continue to provide a large part of the diet of the alleged victims in addition to building materials, medicines, utensils, clays for pottery, cotton for hammocks, and timber for fuel, and for watercraft. Lack of legal recognition of the property rights of the Lower Marowijne Peoples 16. The Petitioners allege that the indigenous property rights and customary laws of the Lower Marowijne Peoples are internationally guaranteed, yet are neither recognized nor respected in 2 3 4 5 See Petitioners’ petition, page 3. Petitioners’ petition, para. 43, page 11. Ibid. Ibid, para. 47. 3