28 2. No one shall be deprived of his property except upon payment of just compensation, for reason of public utility or social interest, and in the cases and according to the forms established by law. 3. Usury and any other form of exploitation of man by man shall be prohibited by law. 89. Read in conjunction with Articles 1 and 2 of the American Convention, Article 21 establishes an obligation for States to respect the property rights described above and to give them effect in their domestic legal regime.159 The petitioners allege that Suriname has violated the alleged victims’ property rights enshrined in Article 21 by failing to recognize those rights, and by issuing individual land titles, establishing and maintaining three Nature Reserves, and granting mining concessions in their traditional and ancestral territories. The State replies that the restrictions on the property rights of the alleged victims are permissible under inter-American jurisprudence, even if such rights have not yet been recognized under Surinamese domestic law. The following sections address each of these issues separately. 90. 1. Violation of the Property Right of the Kaliña and Lokono due to Its NonRecognition 91. As stated by the Inter-American Court, Article 21 of the American Convention protects the close relationship that indigenous peoples have with their ancestral lands and territories, as well as with the natural resources and intangible elements stemming from them.160 The communitarian tradition of land ownership that exists among indigenous peoples is based on the culture, uses, customs, and beliefs of each community, and does not necessarily conform to the classic concept of property, in which land ownership is individualistic. The Inter-American Court and the IACHR have nonetheless stated unequivocally that this communitarian form of land ownership receives equal protection under Article 21.161 A contrary view would render the property rights protected by Article 21 of the American Convention illusory for millions of people.162 In the case of indigenous peoples, the right to land ownership is also connected to their traditional relationship with their territory, natural resources and other immaterial elements. The Court has stressed on several occasions the importance of protecting the relationship between indigenous peoples and their territories and natural resources in order to safeguard their physical 92. 159 See, e.g., I/A Court H.R., Saramaka People. v. Suriname Case. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007 Series C No. 172, paras. 97, 115-116. 160 I/A Court H.R., Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. Preliminary Objections. Judgment of February 1, 2000, para. 149; I/A Court H.R., Case of Kichwa Indigenous People of Sarayaku v. Ecuador, Merits and Reparations. Judgment of June 27, 2012. Series C No. 245, para. 145. 161 I/A Court H.R., Case of Kichwa Indigenous People of Sarayaku v. Ecuador, Merits and Reparations. Judgment of June 27, 2012. Series C No. 245, para. 145; I/A Court H.R., Saramaka People. v. Suriname Case. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007 Series C No. 172, paras. 88-89; IACHR, Report on the Situation of Human Rights in Ecuador, OAS/Ser.L/V/II.96.Doc.10 rev 1, April 24, 1997, p. 115. 162 I/A Court H.R., Case of Kichwa Indigenous People of Sarayaku v. Ecuador, Merits and Reparations. Judgment of June 27, 2012. Series C No. 245, para. 145.