18 There is a dispute between the parties as to whether indigenous peoples inhabited the specific areas where individual titles were granted at the time those titles were granted.92 Nonetheless, it is undisputed that some titles were issued in lands that the Kaliña and Lokono Peoples claim are part of their ancestral territories.93 Although the State alleges that some of the lands claimed are inside the town of Albina,94 the petitioners explicitly state that they make no claim over land or titles issued in Albina.95 Most of the non-indigenous title-holders are “holiday citizens” who have used their parcels to build vacation homes.96 On at least one occasion, in the village of Wan Shi Sha, non-indigenous titleholders have secured the assistance of the Surinamese courts to assert their property rights to the exclusion of those of the indigenous members.97 Indigenous peoples have written to the Surinamese authorities on at least two occasions to complain about the issuance of land titles in their territories and related practices.98 The State did not provide evidence of having responded to these communications. 61. 62. In accordance with the L-Decrees of 1982, any Surinamese citizen is entitled to request a piece of unencumbered State land. These Decrees are available to recognized legal persons, which include individuals, corporate bodies, and certain foundations.99 Indigenous peoples, their communities or other traditional entities are not recognized as legal persons for purposes of holding land title under Surinamese law.100 63. From 1986 to 1987, an armed opposition group known as the Jungle Commando attacked military installations in eastern Suriname.101 As a result, many of the occupants of the Tuinstad area were forced to leave for security reasons.102 When they returned in the early 1990s, disagreements with some indigenous communities arose again over who were the rightful owners of these communities.103 The affected Kaliña and Lokono peoples have requested the State to 92 Petitioners claim they inhabited these areas and protested to the sub-division into parcels. Annex 6. Petition, para. 74. The State, on the other hand, claims that the parceled areas were uninhabited for many years preceding the issuance of the titles, and that the Lower Marowijne indigenous peoples “never protested against the project to parcel out areas in the suburbs of Albina.” Submission of Suriname, March 22, 2008, pp. 3-4. 93 Annex 6. Petition, para. 74; Submission of Suriname, March 22, 2008, p. 3. 94 Submission of Suriname, March 22, 2008, p. 3, n. 6. 95 Annex 6. Petition, para. 73. See also Annex 4. Map of Lower Marowijne area, indicating the Kaliña and Lokono traditional territory, presented during the Hearing on the Merits, March 27, 2012, IACHR 144 Period of Sessions, Case 12.639 – Kaliña and Lokono Peoples, Suriname. 96 Submission of Suriname, September 12, 2008, pp. 12-13. 97 Annex 6. Petition, para. 76, citing Tjan A Sjin v. Zaalman and Others, Cantonal Court, First Canton, Paramaribo, May 21, 1998; Annex 19. Submission of Suriname, September 12, 2008, Annex II, Affidavit of Rudy Emanuel Strijk, p. 1. 98 See Annex 23. Petition, Annex C, translations of communications dated December 2004, addressed to Head of Service Domains, and May 22, 2006, to the Minister of Spatial Planning, Land and Forest Policy. 99 Annex 6. Petition, paras. 71-72. 100 See I/A Court H.R., Case of the Moiwana Community v. Suriname. Preliminary Objections, Merits, Reparations and Costs. Judgment of June 15, 2005. Series C No. 124, para 86(5); I/A Court H.R., Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 28, 2007. Series C No. 172, para. 230. 101 Submission of Suriname, March 22, 2008, p. 4. 102 Submission of Suriname, March 22, 2008, p. 4. 103 Submission of the petitioners, May 28, 2008, para. 27.