9 only to the obligation of the State to ensure the right to life of the victims, but rather to take all the appropriate measures to ensure the continuance of the relationship of the Saramaka People with their land or their culture”. 30. The representatives understood this point to relate to the threshold between lesser impacts and impacts that deny the capacity of the Saramaka to survive as a tribal entity. However, the representatives considered that Suriname has incorrectly interpreted the phrase “survival as a tribal people” to mean that a proposed operation must “not endanger the life of the victims”. A correct interpretation, according to the representatives, would involve an assessment of the extent to which proposed development or investment projects, separately or cumulatively, interfere with, impair, or negate the maintenance and continued enjoyment of the Saramaka people’s full spectrum of relationships to their traditional lands, territories and resources. According to the representatives, particular attention should also be given to the cumulative impacts of multiple restrictions or other relevant circumstances caused by past and present projects, in relation to proposed future projects. The representatives also considered that the ESIA is one way, but not the only way, of assessing the significance of a development or investment project’s impact on the maintenance and continued enjoyment of indigenous and tribal peoples’ relationships with their traditional territories. Therefore, in order to properly assess the effect that a restriction on property rights may have on other rights, the representatives submit that, at a minimum, a Human Rights Impact Assessment is required as part of the ESIA process. a) General requirements and safeguards 31. The Court deems that the issues raised indicate that the State may require further guidance in order to appropriately implement the Judgment. To ensure clarity on both the meaning and scope of the Judgment, and to ensure its appropriate application, the Court will address the State’s concerns related to the issue of the environmental and social impact assessments. 32. As the Court indicated in the Judgment, pursuant to Article 21 of the Convention, the State must respect the special relationship that members of the Saramaka people have with their territory in a way that guarantees their social, cultural, and economic survival.17 The Court stated in paragraph 121 of its Judgment: […] the aim and purpose of the special measures required on behalf of the members of indigenous and tribal communities is to guarantee that they may continue living their traditional way of life, and their distinct cultural identity, social structure, economic system, customs, beliefs, and traditions are respected, guaranteed, and protected by the states. 33. Such protection of property under Article 21 of the Convention, read in conjunction with Articles 1(1) and 2 of said instrument, poses a positive obligation on the State to adopt special measures that guarantee the members of the Saramaka people the full and equal exercise of their right to the territories they have traditionally used and occupied. 34. Any attempt to restrict the property rights of the members of the Saramaka people must adhere to the strict requirements established by the Court in the Judgment and the Tribunal’s jurisprudence. In the context of restrictions of property rights in general, the Court has previously held that, 17 Cf. Case of the Saramaka People, supra note 1, Operative Paragraphs 5, 7, and 9, and paras. 81, 86, 90, 91, 103, 120-123, 126-129, 139-141, 146, 148, 155, 157, 158, 194(a), 194(c), and 194(e).