7 prevented the title holders from returning to them. The State adds that the alleged victims invoked an exclusive traditional relationship with the land, which did not exist, and their own occupancy of these lands, to justify these acts. 30. In addition, the State submits that the petitioners have consented to the State actions in the area and have substantially benefitted from the economic development resulting from such actions. According to Suriname, the Kaliña and Lokono Peoples did not inhabit the area where the titles were granted for many years before the granting of the titles, and the issuance of individual land titles to non-indigenous people has not interfered with their traditional activities. Suriname claims that the non-indigenous title-holders who come as holiday citizens to the Lower Marowijne area have been welcome by the inhabitants of the community, as their presence creates a source of income for many local people. Suriname also argues that the non-indigenous titleholders should have their land respected because their titles were issued based on pre-existing legislation and in good faith, and these title-holders are innocent with respect to any claim by the petitioners. The State thus claims that the alleged victims are not entitled to any compensation or reparation for the granting of these titles. 31. Similarly, Suriname argues the mining concessions complained of only have marginal, trivial and de minimis effects on the alleged victims. The State claims that the mining area is relatively small and the scale of the activities so limited that there is no question of a substantial effect to the alleged victims’ exercise of their rights and traditional activities. The State claims that no mining concession has been granted in some of the villages. The effects of the limited mining activities on the lifestyle of the Kaliña and Lokono Peoples, according to the State, are trivial and have been exaggerated by the petitioners to give apparent legitimacy to their claims, but there is only small-scale interference that does not rise to the level of a Convention violation. Suriname adds that any damage the petitioners may have suffered as a result of the mining concessions and mining activities in the area have been more than compensated by the benefits petitioners have received from the mining activities, such as the opportunities to use the haul road for their logging activities and to transport timber. Accordingly, Suriname maintains that there is no justification for any compensation, monetary or otherwise, based on the mining concessions and activities. 32. The State also argues that it has not violated Article 25 of the American Convention. Suriname cites Article 1386 of the Suriname Civil Code, which according to the State enables a citizen to apply to the independent judiciary in case of an alleged unlawful infringement of his interests by any person, including a public authority. The State asserts that any violation by act or omission of a person or the State, either of the law, of a subjective right or an unwritten standard of due care or good governance, that causes someone harm is an unlawful infringement of that person’s interests and entitles that person to the reparation of the harm. The State adds that Article 1386 of the Suriname Civil Code provides adequate and effective remedies to address the alleged violations of Articles 3, 21, and 25 of the American Convention. IV. PROVEN FACTS