29 and cultural survival and comply with the obligations enshrined in Article 21 of the American Convention.163 The IACHR and the Inter-American Court have explained that the protections of Article 21 encompass the property rights of indigenous peoples over their ancestral territories. These rights protect the close relationship that indigenous peoples have with their ancestral lands, territories, natural resources and intangible elements stemming from this relationship.164 This relationship and notion of “ownership” is frequently conceived at the collective level, as opposed to the individual ownership commonly found in non-indigenous contexts, and is based on, among other things, the culture, uses, customs, and traditions of each community. The Inter-American Court has stated unequivocally that this form of land ownership receives equal protection under Article 21.165 93. The Inter-American Court has also stated that the right to use and enjoy indigenous and tribal territories must also include the right to use and enjoy the resources found therein. 166 The inclusion of the right over natural resources is necessary to protect and preserve the lifestyle of indigenous and tribal peoples. This protection applies to the natural resources that have been used traditionally by indigenous peoples and which are necessary for their physical and cultural survival, as well as for preserving their worldview, social structure, customs, beliefs and tradition.167 The Inter-American Court has also stated that even if an indigenous people temporarily is forced to leave its traditional territory, “as long as this [special] relationship [with the land] exists, the right to claim those lands remains in force.”168 94. As mentioned earlier, the Kaliña and Lokono indigenous peoples satisfy most of their survival needs from their territory. Their subsistence depends on hunting, fishing, slash-andburn agriculture, gathering forest produce and fruit, and collecting building materials, medicines, utensils, timber for fuel, among others.169 In addition, their customary law contemplates collective ownership of their traditional lands, and subsidiary communal rights over land and resources are vested in kinship groups.170 Their uses and customs also provide for boundaries between villages, which are observed by other members of the community, as well as for collective ownership of 163 See, e.g., Case of the Saramaka People, para. 90; I/A Court H.R., The Mayagna (Sumo) Awas Tingni Community v. Nicaragua Case. Judgment of August 31, 2001. Series C No. 79, para. 149; I/A Court H. R., Indigenous Community Sawhoyamaxa v. Paraguay Case. Judgment of March 29, 2006. Series C No. 146, para. 118. 164 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. IACHR, Indigenous and Tribal Peoples’ Rights Over Their Ancestral Lands and Natural Resources. Norms and Jurisprudence of the Inter-American Human Rights System. OEA/Ser.L/V/II.Doc.56/09, December 30, 2009, paras. 48-57. 165 See, e.g., 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. 166 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. 146. 167 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. 146. 168 I/A Court H.R., Case of the Xákmok Kásek Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of August 24, 2010. Series C No. 214, para. 112. 169 See above, para. 36. 170 See above, para. 38.