5. The Court has ruled on prior consultation in four cases concerning indigenous or tribal peoples, namely: Case of the Saramaka People v. Suriname; Case of the Kichwa Indigenous People of Sarayaku v. Ecuador; and Case of the Garífuna Community of Punta Piedra and its members, and Case of the Garífuna Community of Triunfo de la Cruz and its members, both v. Honduras. 6. In this regard, in addition to the considerations in paragraph 201 of this judgment, in the case of the Saramaka People, the Court indicated that the consultation must ensure the effective participation of the members of the Community and that the consultation must be: (i) in good faith and designed to reach an agreement; (ii) in keeping with the community’s own traditions and customs and their traditional method of decision-making; (iii) during the initital stages of the project in question, and (iv) following the delivery of all relevant information, including information on possible risks.2 7. In the case of the Kichwa Indigenous People of Sarayaku and, subsequently, in the case of the Garífuna Community of Triunfo de la Cruz, the Court specified that “to ensure that the exploration for, or extraction of, natural resources in ancestral territories does not entail a negation of the survival of the indigenous people as such, the State must comply with the following safeguards: (i) conduct an appropriate and participatory process that guarantees the right to consultation, particularly with regard to large-scale development or investment projects; (ii) make an environmental impact assessment, and (iii) as appropriate, reasonably share the benefits produced by the exploitation of natural resources (as a form of just compensation required by Article 21 of the Convention), with the community itself determining and deciding who the beneficiaries of this compensation should be, according to its customs and traditions.” 3 8. In the case of the Garífuna Community of Punta Piedra, the Court reiterated that it had established that, “in the case of any development, investment, exploration or extraction project in traditional territories of indigenous or tribal communities, the State must comply with the following safeguards: (i) conduct an appropriate and participatory process that guarantees their right to consultation; (ii) make a prior social and environmental impact assessment, and (iii) as appropriate, reasonably share the benefits produced by the exploitation of the natural resources.” 4 9. In addition, it should be pointed out that, as established in the instant judgment, even though Suriname is not a party to ILO Convention 169, the Court reiterated what it had established in the Saramaka case,5 to the effect that “the right to property protected by Article 21 of the American Convention, and interpreted in light of the rights recognized in Article 1 common to the two Covenants, and Article 27 of 2 Cf. Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 28, 2007. Series C No. 172, para. 133. 3 Case of the Kichwa Indigenous People of Sarayaku v. Ecuador. Merits and Reparations. Judgment of June 27, 2012. Series C No. 245, para. 157, and Case of the Garífuna Community of Triunfo de la Cruz and its members v. Honduras. Merits, Reparations and Costs. Judgment of October 8, 2015. Series C No. 305, para. 156. 4 Case of the Garífuna Community of Punta Piedra and its members v. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of October 8, 2015. Series C No. 304, para. 215. 5 Case of the Saramaka People, supra, para. 95. 3