instant case, the Court will analyze the State’s alleged failure to comply with these safeguards in relation to the start-up of bauxite extraction operations in 1997. 202. Furthermore, the Court reiterates that Article 23 of the American Convention establishes that: “[e]very citizen shall enjoy the following rights and opportunities: (a) to take part in the conduct of public affairs […].” Similarly, Article 18 of the United Nations Declaration on the Rights of Indigenous Peoples establishes that “[i]ndigenous peoples have the right to participate in decision-making in matters which would affect their rights, through representatives […],” and the pertinent part of Article 32 stipulates that “States shall consult and cooperate in good faith […] prior to the approval of any project affecting their lands or territories and other resources, particularly in connection with the […] utilization or exploitation of mineral […] resources.” 203. Consequently, in order to ensure the use and enjoyment of the right to indigenous collective property recognized in Articles 1.1 and 21 of the Convention, in relation to the utilization or exploitation of natural resources in their traditional territory, the State must, for the effects of this case, put in place mechanisms for the effective participation of the indigenous peoples using procedures that are culturally adapted to the decision-making of such peoples. This is not only a matter of public interest, but also forms part of the exercise of their right to take part in any decision-making on matters that affect their interests, in accordance with their own procedures and institutions, in relation to Article 23 of the American Convention (supra para. 196). 3. In this regard, we are essentially in agreement with the majority of the Court in the sense of reiterating the safeguards established by the Court in its case law in relation to investment or development projects in indigenous or tribal territory. In particular, the State’s obligation to organize an effective participation process, implemented by means of prior, free and informed consultation. Prior, free and informed consultation 4. One of the most significant contributions of the Inter-American Court’s case law in indigenous and tribal matters has been the interpretation made of Article 21 of the American Convention. Thus, the Court has developed an interpretation that protects one of the characteristic stuations in the region, the communal ownership of ancestral territories. In this understanding, in the context of major development, investment, exploration, exploitation and extraction projects and plans, the Court has established a solid line of case law concerning the obligation to consult the indigenous and tribal peoples insofar as such projects affect both their territory and their way of life within that territory.1 1 The Court has determined that “[i]ndigenous groups, by the fact of their very existence, have the right to live freely in their own territory; the close ties of indigenous people with the land must be recognized and understood as the fundamental basis of their cultures, their spiritual life, their integrity, and their economic survival. For indigenous communities, relations to the land are not merely a matter of possession and production but a material and spiritual element which they must fully enjoy, even to preserve their cultural legacy and transmit it to future generations.” Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. Merits, Reparations and Costs. Judgment of August 31, 2001. Series C No. 79, para. 149. 2