46 invading the core zone of the [Punta Sal National] Park and [that] others were mucking it out”; the witness also stated that as a result of a complaint filed with the Corporación Hondureña de Desarrollo Forestal (National Corporation for Forestry Development, AFECOHDEFOR) by the PROLANSATE foundation, “the national authorities […] terminated [a timber extraction] contract.”201 152. In Chapter VII, the Court held that it had been established that at least one agent of the State had been involved in the events that ended the life of Blanca Jeannette KawasFernández, and that such acts were motivated by Ms. Kawas-Fernández’s work in defense of the environment through the PROLANSATE foundation, especially in retaliation for reporting and opposing the exploitation of natural resources of certain protected areas in the municipality of Tela. It is the Court’s view that her death, evidently, resulted in the deprivation of her right to associate freely with others. 153. As found in other cases,202 it is undeniable that these circumstances have also had an intimidating effect203 on other people who are engaged in the defense of the environment in Honduras or that are related to this type of causes. This intimidating effect is reinforced and exacerbated by the fact that the crime remains unpunished (supra para. 68). 154. Furthermore, in the case sub judice, it has been established that during the decade following the death of Blanca Jeannette Kawas-Fernández, five people lost their life as a result of their work in defense of natural resources and the environment in Honduras204 (supra para. 69). 201 Cf. statement rendered by Rafael Sambulá on March 1, 1995, supra note 31, and communication of February 28, 1996 from the executive director and coordinator of the “Vida y Naturaleza” (Life and Nature) radio show, broadcast on Radio América, supra note 32. It should be noted that the decree creating Punta Sal National Park established a system for the management and stewardship of the land comprising the national park which prohibits its use “for purposes other than conservation.” Article 5 of the Decree No. 154-94 provides that “for management and stewardship purposes, Punta Sal National Park shall comprise main areas that can meet the park management objectives [...] a) Core zone, [...] is comprised of natural areas with minimum man-made alterations that contains unique and fragile ecosystems, species of flora and/or fauna and/or natural phenomena which deserve full protection for scientific purposes of environmental control. No change to or alteration of the ecosystem shall be permitted. […] b) Buffer zone: special resources or habitats must be surrounded by a section of land that acts as a barrier to external impacts. This zone must be broad enough to absorb chemical and physical stressors, such as air, soil or water pollution, fires, illegal hunting, uncontrolled tourism, and noise. […] The management of the park shall have the authority to approve or reject any form of economic development in this zone.” In accordance with Section 14 of the aforesaid decree, the Park’s management that includes a representative of the PROLANSATE foundation, among others has “the authority to make a decision regarding any form of development to be built in the protected areas” and may “approve or reject any form of economic development” in the buffer zone of the Park. Cf. Decree No. 154-94, supra note 28. 202 Cf. García-Santa Cruz. Preliminary Objection, Merits, Reparations and Costs, supra note 183, para. 147. 203 Cf. statement rendered by Rafael Sambulá before the Inter-American Court, supra note 25. In his statement, the witness said that “initially, there was a great deal of agitation and fear among all the personnel working for the foundation; the relatives urged the co-workers to be careful because what happened to Jeannette could happen to us; she was a very responsible person and that she instilled a lot of confidence in the organization and that in the people who helped and supported us [...].” 204 In 1996, Carlos Escaleras, popular leader of the Honduran Aguán Valley was killed; Carlos Luna, environmental activist, was murdered in 1998; Carlos Flores, community leader and environmental activist of Olancho was killed in 2001, and Heraldo Zúñiga and Roger Iván Cartagena, members of the Olancho Environmental Movement (MAO) were murdered in 2006. Cf. Official Letter No. FEDH-575-2008 of July 2, 2008, supra note 78.

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