environment by the creation of a metropolitan park was a legitimate reason to restrict the right to property established in Article 21 of the Convention.212 172. In addition, the Court has emphasized the importance of the protection, conservation and improvement of the environment contained in Article 11 of the Additional Protocol to the American Convention in the area of Economic, Social and Cultural Rights “Protocol of San Salvador,”213 as an essential human right related to the right to a dignified life derived from Article 4 of the Convention in light of the existing international corpus iuris on the special protection required by members of indigenous communities “in relation to the general obligation to ensure rights contained in Article 1(1), and to the obligation to achieve the full recognition of the rights progressively, contained in Article 26 thereof.”214 Nevertheless, as indicated in the case of the Xákmok Kásek Indigenous Community, the Court has determined that “[…] the State must adopt the necessary measures to ensure that [its domestic laws concerning the protected area] do not represent an obstacle to the return of traditional lands to the members of the Community.” 215 173. The Court considers it important to refer to the need to ensure the compatibility of the safeguard of protected areas with the adequate use and enjoyment of the traditional territories of indigenous peoples. In this regard, the Court finds that a protected area consists not only of its biological dimension, but also of its socio-cultural dimension and that, therefore, it requires an interdisciplinary, participatory approach. 216 Thus, in general, the indigenous peoples may play an important role in nature conservation,217 since certain traditional uses entail sustainable practices and are considered essential for the effectiveness of conservation strategies.218 Consequently, respect for the rights of the indigenous peoples may have a positive impact on environmental conservation. Hence, the rights of the indigenous peoples and international environmental laws should be understood as complementary, rather than exclusionary, rights.219 212 Cf. Case of Salvador Chiriboga v. Ecuador. Preliminary Objection and Merits. Judgment of May 6, 2008. Series C No. 179, para. 76 213 Article 11 of this instrument stipulates that: “1. Everyone shall have the right to live in a healthy environment and to have access to basic public services. 2. The States Parties shall promote the protection, preservation, and improvement of the environment.” Suriname ratified the Protocol of San Salvador on February 28, 1990. The Protocol entered into force internationally on November 16, 1999. 214 Cf. Case of the Yakye Axa Indigenous Community supra, para. 163, and Case of the Xákmok Kásek Indigenous Community, supra, para. 187. 215 Cf. Case of the Xákmok Kásek Indigenous Community, supra, para. 313. 216 Cf. Secretariat of the Convention on Biological Diversity (2004), Addis Ababa Principles and Guidelines for the Sustainable Use of Biological Diversity (CBD Guidelines), Montreal: Secretariat of the Convention on Biological Diversity, Practical principle 9, p. 16. Available at: https://www.cbd.int/doc/publications/addis-gdl-en.pdf, and Durban Accord and Action Plan adopted at the Vth World Parks Congress, Durban, South Africa, 2003, p. 25. During this Congress, organized by the International Union for Conservation of Nature (IUCN) and the World Commission on Protected Areas, a new protected area paradigm was adopted that superseded the consideration of a nature reserve as a mere national conservation space and introduced scientific, economic and cultural claims and implemented management and funding policies involving different stakeholders. Available at: http://www.danadeclaration.org/pdf/durbanactioneng.pdf. 217 Cf. Rio Declaration on Environment and Development, Principle 22, adopted at the United Nations Conference on Environment and Development held in Rio de Janeiro from June 3 to 14, 1992, which Suriname adhered to without any reservations. Available at: http://www.unep.org/documents.multilingual/default.asp?documentid=78&articleid=1163; World Conference on Indigenous Peoples, high-level plenary meeting of the General Assembly of the United Nations, in which Suriname took part, Resolution adopted by the General Assembly on September 22, 2014, paras. 22, 26, 34 and 35. Available at: http://daccess-dds-ny.un.org/doc/UNDOC/GEN/N14/468/28/PDF/N1446828.pdf?OpenElement. 218 Cf. WWF International, 2008. Indigenous Peoples and Conservation: WWF Statement of Principles. Gland, Switzerland: WWF International, pp. 5 and 9. Available at: http://www.worldwildlife.org/publications/wwf-statement-ofprinciples-on-indigenous-peoples-and-conservation. 219 Cf. International Union for Conservation of Nature and WWF-International, Indigenous and Traditional Peoples and Protected Areas: Principles, Guidelines and Cases Studies. IUCN, Gland, Switzerland, and Cambridge, UK, and WWF International, Gland, Switzerland, Principle 1. The principles, guidelines and case studies presented in this report respond 46