23 Specifically, it has been proven that Suriname granted, among other things, longterm leases that continue to be valid after 1987. Suriname has not provided information to show that the long-term leases or land titles issued before November 12, 1987 to non-indigenous persons have been revoked or otherwise left without effect. Therefore, these titles, long-term leases and lease holds are still valid and continue to exclude the possibility that the Kaliña and Lokono are recognized as the traditional owners of their lands and receive legal title over them.133 Similarly, it is undisputed that the Nature Reserves have remained in place after Suriname’s accession to the American Convention. The Reserves have been administered after 1987, and continue to be administered today, pursuant to the terms of their establishment. Moreover, the legal status of the territories of the Kaliña and Lokono Peoples vis-à-vis the Nature Reserves also remains the same: their rights are not recognized, while the Nature Reserves are legally-protected. In fact, Suriname acknowledges that the lands covered by the Nature Reserves “were and still are domain land,” that is, State-owned land.134 When acts or omissions, or the effects of acts or omissions, that took place before a State’s ratification or accession to a treaty continue after the date of a State’s ratification or accession, the State can be internationally liable for violating that treaty.135 As for the mining concession, it has also continued after 1987, and the State’s own submissions confirm that plans for mining activities of the Wane I and Wane II deposits commenced in the mid 1990s, and actual mining started in 1997.136 Therefore, the acts and/or omissions committed in connection with the commencement of mining activities in the Kaliña and Lokono’s ancestral lands are protected by Article 21, and Suriname was obligated to comply with its obligations deriving from it. 75. 76. Accordingly, the IACHR considers that the issuance of individual land titles, leaseholds and long-term leases to non-indigenous persons, the establishment and administration of the Nature Reserves, and the granting of the mining concession, as well as their effects, have continued after Suriname’s accession to the Convention, and continue to the present. Therefore, the IACHR has jurisdiction ratione temporis, and Suriname can be held liable for violations of the American Convention if the effects of these acts and omissions infringe upon the Kaliña and Lokono’s rights. In addition, the Commission notes that in the present proceedings Suriname has acknowledged the judgment of the Inter-American Court of Human Rights in the case of Saramaka People v. Suriname137 and has expressly recognized “the force of precedent of the judgment for the consideration of the claims in the present case.”138 133 Cf., I/A Court H. R., Indigenous Community Yakye Axa v. Paraguay Case. Judgment of June 17, 2005. Series C No. 125, paras. 146-156. 134 Submission of Suriname, September 12, 2008, p. 10. 135 Admissibility Report, para. 47, n. 22 (citing I/A Court H.R., Case of Blake. Preliminary Objections. Judgment of July 2, 1996. Series C No. 27; I/A Court H.R., Case of Cantos. Preliminary Objections. Judgment of September 7, 2001. Series C No. 85; I/A Court H.R., Case of Alfonso Martín del Campo-Dodd. Preliminary Objections. Judgment of September 3, 2004. Series C No. 113; I/A Court H.R., Case of Almonacid-Arellano et al. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 26, 2006. Series C No. 154; IACHR Report N° 74/90 Case 9850, Hector Geronimo Lopez Aurelli, Argentina, 4 October 1990.). 136 Submission of Suriname, March 22, 2008, p. 6; Annex 21. Submission of Suriname, September 12, 2008, Annex III, Affidavit of Glenn Renaldo Kingswijk. 137 I/A Court H.R., Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 28, 2007. Series C No. 172. 138 Submission of Suriname, March 22, 2008, p. 1.