47 (…)”260 The Special Rapporteur has also underscored “the need for new paradigms for protected areas in order to ensure that violated indigenous rights are restored and are respected in the future,” reiterating that the “defence of human rights must be a priority in environmental campaigns (…)”261 that: 139. This is consistent with Principle 1 of the Principles and Guidelines, which states there should be no inherent conflict between the objectives of protected areas and the existence, within and around their borders, of indigenous and other traditional peoples. Moreover, they should be recognised as rightful, equal partners in the development and implementation of conservation strategies that affect their lands, territories, waters, coastal seas, and other resources, and in particular in the establishment and management of protected areas.262 The Principles and Guidelines also underscore that “[i]ndigenous and other traditional peoples have long associations with nature and a deep understanding of it. Often they have made significant contributions to the maintenance of many of the earth’s most fragile ecosystems, through their traditional sustainable resource use practices and culture-based respect for nature.”263 140. 141. The African Commission on Human and Peoples’ Rights (“African Commission”) has also looked at the issue of indigenous communities’ rights to their ancestral lands and resources in the context of environmental conservation. In the Endorois case, the African Commission examined whether the State of Kenya’s establishment of a “Game Reserve,” which displaced some members of the Endorois indigenous community from their ancestral land and restricted the community’s access to it, was consistent with respect for the indigenous community’s rights to their ancestral lands and resources.264 The African Commission explained that in these types of cases, a State’s limitations on rights must be proportionate to a legitimate need and should be the least restrictive measures possible,265 and “[a]t the point where such a right [i.e., the right that is being infringed] 260 UN Human Rights Council, Report of the Special Rapporteur on the situation of human rights and fundamental freedoms of indigenous people, Rodolfo Stavenhagen, UN Doc. A/HRC/4/32, 27 February 2007, paras. 22. 261 UN Human Rights Council, Report of the Special Rapporteur on the situation of human rights and fundamental freedoms of indigenous people, Rodolfo Stavenhagen, UN Doc. A/HRC/4/32, 27 February 2007, paras. 23. 262 World Commission on Protected Areas (WCPA), The World Conservation Union (IUCN), World Wildlife Fund, Principles and Guidelines on Protected Areas and Indigenous/Traditional Peoples, Principle 1. Available at: http://data.iucn.org/dbtw-wpd/edocs/PAG-004.pdf. 263 World Commission on Protected Areas (WCPA), The World Conservation Union (IUCN), World Wildlife Fund, Principles and Guidelines on Protected Areas and Indigenous/Traditional Peoples, Principle 1. 264 African Commission on Human and Peoples’ Rights, Communication 276/2003 – Centre for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v. Kenya, November 2009. The Inter-American Court of Human Rights has cited the Endorois decision when analyzing indigenous peoples’ right to consultation and collective property in relation to the right to cultural identity. I/A Court H.R. Case of Kichwa Indigenous People of Sarayaku v. Ecuador, Merits and Reparations. Judgment of June 27, 2012. Series C No. 245, para. 216, n. 285. 265 African Commission on Human and Peoples’ Rights, Communication 276/2003 – Centre for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v. Kenya, November 2009, para. 214.