13 traditional tenure patterns and laws, “the report […] advocates the use of a zoning system that conforms to the ‘survey standards of [Suriname].’” Moreover, the report “appears to deny indigenous and tribal peoples' legal personality in relation to holding and exercising property rights.” Finally, in response to the report’s contention that Moiwana Community members want individual land titles, the representatives indicated that “some [Community members have] decided this precisely because they have not been provided any information about alternative sources of credit [and] have been told by State officials that they must accept individual titles [in order] to secure financ[ing].” The representatives stressed that “the State cannot simply assign […] collectively owned lands to individuals without the consent of the N'djuka people as a whole[, as that] would amount to a nonconsensual alienation of collective […] lands.” 23. During the hearing, the Commission indicated that it valued the steps taken by the State in order to comply with this obligation. However, it also stated that the extent of the impact of these measures on the members of the Moiwana Community is unclear and requested updated information on the State’s work with the UN Special Rapporteur (supra Considering clause 19). Subsequently, the Commission affirmed that “the State has not taken specific steps to comply with this measure of reparation, nor […] duly consulted with the Moiwana people regarding the implementation of the order.” It further noted that the State did not provide information on the “Presidential Commission” referred to in its previous report, nor on the manner in which the SSDI project “has or will have a direct effect in the present case,” and expressed concern that the State still has not provided the schedule requested by the Court in February 2010. Finally, the Commission highlighted “the amount of time that has passed since the order of the Court” and requested that the Tribunal require specific information on this obligation, as well as a timeline for the State’s compliance therewith. 24. The Court values the steps taken in order to achieve compliance with this order, such as possible consultations with international experts. However, though the Court recognizes the initiatives of the State aimed at a achieving a national solution to the land rights issue, the complexity of those initiatives is causing excessive delays in the State’s compliance with specific orders of the Tribunal meant to safeguard the land rights of the Moiwana Community in this case. Therefore, the Court reiterates that pursuant to Article 68(1) of the Convention, the State must fully and promptly comply with the Judgment regardless of its efforts to comply with other decisions or to implement changes at a national level (supra Considering clause 3). Furthermore, in light of the representatives' many concerns regarding the implementation of this order and, specifically, regarding the Final Report of the National Commission on Land Rights and the draft report of the Amazon Conservation Team, the Court reminds the State that measures taken in order to comply with the Judgment must conform to the specific orders contained therein and to the Court’s jurisprudence on the property rights of indigenous peoples. 25 Thus, in order to ensure the property rights of the members of the Moiwana Community, as 25 In the Judgment, the Court found that “the Moiwana [C]ommunity members, a N’djuka tribal people, possess an ‘all-encompassing relationship’ to their traditional lands, and their concept of ownership regarding that territory is not centered on the individual, but rather on the community as a whole. Thus, this Court’s [jurisprudence] with regard to indigenous communities and their communal rights to property under Article 21 of the Convention must also apply to the tribal Moiwana [C]ommunity members […].” Case of the Moiwana Community v. Suriname, supra note 8, para. 133.

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