6 Peoples. Third, the State argues that the granting of private title has not interfered with the rights of indigenous people to the land or their access to it. Lastly, Suriname argues that the petitioners have consented to the State actions in the area and have substantially benefitted from the economic development resulting from such actions. 25. The State first argues that the indigenous “groups” of the Lower Marowijne River area are not a homogenous group of people, given that the nature, scope, and intensity of their relationship with the claimed land is highly varied. It claims that the alleged victims do not live in the area, do not cultivate it, and that their economic, social and cultural activities are not distinguishable from those of other non-indigenous people living in those villages and in the area near the town of Albina. The State claims that the inhabitants of certain villages do not have a prominent and unique relationship with nature and only treat it as their hunting and fishing grounds. 26. Second, the State argues that its actions within the asserted traditional territory of the Lower Marowijne indigenous people are permissible restrictions upon any alleged property rights of the indigenous peoples in accordance with Article 21 of the American Convention. The State contends that the questions before the Inter-American Commission should be whether the grant of individual titles to non-indigenous persons, the establishment of the Nature Reserves, and the issuance of a mining concession in the Wane Kreek area are permissible restrictions on the alleged property rights of the Lower Marowijne indigenous peoples. 27. The State argues that the establishment and preservation of the three Nature Reserves in the Lower Marowijne area is consistent with what it calls the Inter-American Court’s “four way test” for permissible interferences with indigenous land rights. As described by Suriname, this four-way test provides that a State may interfere with Article 21 property rights if the restrictions are: i) previously established by law; ii) necessary; iii) proportional, and iv) with the aim of achieving a legitimate objective in a democratic society. In the present case, Suriname claims that the Reserves were created pursuant to the 1954 Nature Protection Act, thereby complying with the first element of the test. Secondly, it maintains that these Reserves are necessary because they are geared toward satisfying a public interest of protecting certain flora and fauna in the region. Suriname claims that these measures are proportional because their establishment has no impact on the traditional way of life of the alleged victims, and there are no restrictions for the local indigenous people to practice their traditional rights in the Reserves. Lastly, Suriname argues that the Nature Reserves meet the fourth element of the four-way test because the alleged environmental protection interests are important and prevail over the necessity of full enjoyment of the restricted alleged property rights of the Kaliña and Lokono. 28. Suriname adds that the establishment of the Nature Reserves should not lead to the ordering of any reparations even if, arguendo, their establishment amounted to a dispossession in the terms of Article 21(2) of the Convention. According to the State, the conservatory objective of the Reserves is itself a justification not to reverse their establishment, and they comply with the four-way test for interfering with Article 21 property rights, as discussed above. 29. Third, the State claims that the issuance of individual land titles to non-indigenous persons does not interfere with the traditional activities of the Kaliña and Lokono Peoples, and so it does not amount to a violation of Article 21. Suriname claims that during the armed conflict in the 1980s, many of the non-indigenous inhabitants of the Kaliña and Lokono villages had to abandon their homes. According to the State, this was abused by the Lower Marowijne indigenous peoples, who allegedly occupied vacant houses of non-indigenous people in the parceled out areas and