of public order in the region, there are others that arise from the tensions of the [land] restitution process that, in many cases, do not necessarily call for an increased military or police presence.” In this regard, the Special Supervisory Chamber considered that prevention mechanisms should be adopted “to reduce the risks of accusations against or individualization of members of the community as persons who jeopardize the permanence in the territory of those who oppose the land restitution.” Regarding the measures of protection for leaders of the communities of the Jiguamiandó and of the Curvaradó, the Chamber indicated that a fresh risk assessment should be made of the beneficiaries, Ligia María Chaverra and Enrique Petro, with a differentiated approach, because some of the measures adopted are no longer valid and, therefore, “their personal integrity is in danger.” The Constitutional Court, through the Supervisory Chamber, ordered different State authorities to adopt measures “to protect the Afro-Colombian communities of the Curvaradó and Jiguamiandó river basis,” in order “to protect [their] collective territory […],” and others of a general nature. 50. Based on all the above, the Inter-American Court concludes that several of the elements of risk still exist that originally gave rise to the adoption of measures of protection in favor of the members of the humanitarian zones of Nueva Esperanza, Pueblo Nuevo, Caño Claro and El Tesoro, and of the five biodiversity zones known as Erasmo Sierra, Enrique Petro, Familia Tuberquia, Ligia María Chaverra and Efrén Romaña, that are the subject of this Order. Nevertheless, the Court notes that, since these provisional measures were issued approximately 10 years ago, the State has gradually and increasingly adopted numerous measures of protection, of both a specific and a structural nature, in which various local and national State authorities are involved. 51. In addition, the Court emphasizes that the situation of the communities of the Jiguamiandó and of the Curvaradó has been supervised specifically by the Constitutional Court of Colombia – in other words, by one of the highest domestic courts – for approximately four years, following the above-mentioned Decision 005 of January 26, 2009, derived from judgment T-025 of January 22, 2004. As revealed by the preceding findings (supra considering paragraph 49), the said court ordered the design and implementation of a protection plan for the communities of the Jiguamiandó and Curvaradó river basins, which include the humanitarian zones and biodiversity zones covered by this Order. Among other matters, the Constitutional Court ordered the adoption of both individual and collective measures of protection with a differentiated approach, in keeping with the risk assessments that were made in this regard. Furthermore, the said decisions also reveal the special attention that the Constitutional Court has accorded to these communities and to the situation that warranted the adoption of provisional measures by the Inter-American Court, even mentioning them as a paradigmatic case owing to the acts of violence which the said communities have undergone, as well as to the supposed complexity of the process of restituting their lands. In addition, compliance with the orders issued by the Constitutional Court is currently monitored by the Special Supervisory Chamber (supra considering paragraph 49). 52. In order to rule on the State’s request to lift these provisional measures, the Court finds it pertinent to refer to the principle of subsidiarity or complementarity of the interAmerican human rights system contained in the Preamble to the American Convention. Under international human rights law, this principle supposes that, in the first place, it is for the State to respect and ensure these rights within the sphere of its jurisdiction. 12 If it does 12 Cf. E.C.H.R., Kudła v. Poland, Application No. 30210/96, Judgment of 26 October 2000, para. 152; E.C.H.R., Handyside v. the United Kingdom, Application No. 5493/72, Judgment of 7 December 1976, para. 48; 22