consists of 35 indigenous communities of the Mataco (Wichi), Chorote (Iyjwaja), Toba (Quom), Chulupí (Nivacklé) and Tapiete (Tapy´y) ethnic groups, who have been living in the area of Pilcomayo River (fiscal lots 14 and 55) since time immemorial. Specifically, fiscal lots 14 and 55 in the Chaco-Salteño region, Department of Rivadavia, Municipality of Santa Victoria Este, Province of Salta, are home to some 45 indigenous communities (with between 6000 and 7000 people), belonging to nine indigenous groups, and coexisting with about 2600 criollos. This is a sparsely populated zone, with few signs of urbanization, covering about 600,000 hectares. Background 30. The petitioners maintain that, although they are the legitimate owners of the lands on which they live, as recognized by the national Constitution, and have taken various steps since Argentina returned to democracy in 1983 in order to win legal recognition of community ownership of these lands, to date they have received nothing but promises. As background, the petitioners note that in 1991 a memorandum of understanding was signed between the indigenous communities, which the petitioners represent, and the Director General of State Land Acquisitions of the Province of Salta, setting of the conditions for the award of the territories in which the indigenous people were living. Subsequently, the Governor of Salta issued a Decree ratifying all the points recognized in that MOU. With the change of government, that Decree was ratified for a second time on November 6, 1992 by the new Governor of Salta, who declared his willingness to award the lands as had been agreed. Consequently, the Governor of Salta issued Decree 18/93 on January 13, 1993, creating the Honorary Advisory Commission to examine the situation and make recommendations on the methodology to be used to finalize the delivery of the lands. That Commission presented its conclusions in April 1995, recommending that the indigenous people be given title to the land in the "areas de recorrido" (i.e. the lands customarily frequented) of the communities with settlements on both lots, in the form of community ownership, with no subdivisions, and a single title. 31. The petitioners maintain that, despite the technical studies that have been approved, the legal basis that has been demonstrated, the expressed intention of the political authorities to give effect to the delivery of the land, and the indigenous consensus, at the time the petition was presented the lands had not been delivered.

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