65 243. Accordingly, the IACHR considers that on having failed to take effective actions to prevent the invasion and illegal deforestation of the indigenous territory, and to effectively protect the territory and natural resources of the alleged victims, the State of Panama triggered its international responsibility for violating Article 21 of the American Convention in relation to its Article 1(1), to the detriment of the Kuna indigenous people of Madungandí and the Emberá indigenous people of Bayano and their members. 2.3. Failure to provide an adequate and effective procedure for access to territorial property rights and protection vis-à-vis third persons – Articles 8 and 25 of the Convention, in relation to Articles 1(1) and 2 a) Obligation to provide an adequate and effective procedure for the recognition, titling, demarcation, and delimitation of the collective property rights of the indigenous peoples 244. As established by the Inter-American Court in its case-law in respect of indigenous peoples, the obligations contained in Articles 8 and 25 of the Convention presuppose that the States granted effective protection that takes account of their own particularities, their economic and social characteristics, and their situation of special vulnerability, their customary law, values, and uses and 340 customs. In addition, the case-law of the inter-American human rights system has determined that indigenous and tribal peoples have a right for there to be effective and expeditious administrative mechanisms to protect, ensure, and promote their rights over ancestral territories by which they can carry 341 out the processes of recognition, titling, demarcation, and delimitation of their territorial property. 245. The procedures in question should abide by the rules of due process of law enshrined in 342 Articles 8 and 25 of the American Convention. In this respect, the Inter-American Court has specified that due process should be followed both in administrative proceedings and in any other proceeding 343 whose decision may affect the rights of persons. In light of this requirement, the case-law of the interAmerican system has identified a series of characteristics that these administrative mechanisms should have under Articles 8, 25, 1(1), and 2 of the American Convention. 246. These special mechanisms and procedures should be effective. The Inter-American Court has examined, in light of the requirements of effectiveness and reasonable time established in Article 25 of the American Convention, whether the states have established administrative procedures for the titling, delimitation, and demarcation of indigenous lands, and if they do have them, whether they 340 I/A Court H.R.. Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, para. 63. I/A Court H.R.. Case of the Sawhoyamaxa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of March 29, 2006. Series C No. 146, paras. 82, 83. 341 I/A Court H.R.. Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. Merits, Reparations and Costs. Judgment of August 31, 2001. Series C No. 79, para. 138. Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, para. 143. 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, para. 335. 342 I/A Court H.R.. Case of the Sawhoyamaxa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of March 29, 2006. Series C No. 146, paras. 81, 82. 343 I/A Court H.R.. Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, para. 62. I/A Court H.R.. Case of Baena Ricardo et al. v. Panama. Merits, Reparations and Costs. Judgment of February 2, 2001. Series C No. 72, para. 127. I/A Court H.R.. Case of the Sawhoyamaxa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of March 29, 2006. Series C No. 146, paras. 82, 83. The effective remedy that the states should offer under Article 25 of the American Convention “must be substantiated according to the rules of due legal process (Article 8 of the Convention)” [I/A Court H.R.. Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, para. 62]. The Inter-American Court has indicated that among the domestic administrative procedures that should ensure the guarantees of due process are, for example, procedures for recognizing indigenous leaders, procedures for recognition of juridical personality, and the procedures for restitution of lands [I/A Court H.R.. Case of the Sawhoyamaxa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of March 29, 2006. Series C No. 146, paras. 81, 82].