79 as well as to maintain and develop their own indigenous decision-making institutions. The Supreme Electoral Council “did exactly the contrary; that is, it erected barriers to YATAMA’s participation”; (f) The State’s discrimination against the members of YATAMA, as regards their right to elect and to be elected, resulted from the imposition of a series of excessive requirements, that were too burdensome for the indigenous people: the State’s interpretation of the Electoral Act, indicating that it required the presentation of documents exclusively before the Supreme Electoral Council in Managua; diverse barriers erected by the Supreme Electoral Council and by the administration of justice itself, which translated into grave violations of due process and effective judicial protection; and the failure to adopt special measures that would allow political participation in conditions of equality. “The indigenous organizations do not have the same possibilities as the national political parties to comply with the requirements of the Electoral Act”; (g) Special measures of protection are necessary and urgent to ensure that the indigenous communities can exercise their rights effectively, on an equal footing with the rest of the population, in order to guarantee the survival of their cultural values and, in particular, their forms of political participation; (h) The State’s laws established inappropriate requirements that had a discriminatory impact on the indigenous people, did not provide for measures to protect the rights of the alleged victims, and arbitrarily excluded the candidates presented by YATAMA; (i) “The State did not allow the YATAMA candidates to participate in the 2000 municipal elections on an equal footing; it did not ensure equality of access to public office and positions; it did not ensure that the indigenous voters were represented on an equal footing with the other voters”; and (j) The State has also violated the right to equality because it did not adopt special measures of protection to facilitate and ensure the political participation of the indigenous people, according to their values, practices and customs. 180. Arguments of the State:152 (a) The 2000 municipal elections respected the constitutional provisions and the Electoral Act in force; (b) The candidates for the positions of mayors, deputy mayors and councilors did not obtain favorable results in these elections owing to errors in complying with the requirements established in the electoral laws; (c) The statements made in affidavits by Lidia Chamorro and Mauricio Carrión Matamoros established the validity of the Electoral Act, the constitutional level of the Supreme Electoral Council, and the application of the law. The statements of the expert witnesses, Carlos Hurtado Cabrera, Secretary of the Presidency for Atlantic Coast Affairs, and Saul Castellón reveal the State’s 152 The State did not present independent arguments referring specifically to the alleged violation of Article 23 of the Convention.