87. Similarly, the jurisprudence of the Inter-American System of Human Rights has determined that indigenous and tribal people have the right to effective administrative mechanisms to protect, ensure and promote their rights over ancestral lands, through which it is possible to carry out the processes of recognition, titling, demarcation and delimitation of their territory 91. 88. Subsequently, the Commission will examine, first, the effectiveness of the administrative process for the recognition, demarcation and titling of the Xucuru indigenous territory. Secondly, the Commission will refer to the fulfillment of such obligations in the legal proceedings relating to the demarcation of indigenous territory of which the IACHR is aware. 1. The effectiveness of the administrative process of recognition and demarcation of Xucuru indigenous territory 89. As was established in the proven facts, the administrative process of demarcation of the Xucuru indigenous territory dates from 1989, and the registration of the " Xucuru Indigenous Land" took place on November 18, 2005, over sixteen years later. At this point, the IACHR will examine the reasonableness of the time that it took to obtain that title of "possession" of the Xucuru indigenous territory. 90. The Inter-American system has taken into account four factors to determine whether the time is reasonable: i) the complexity of the matter; ii) the procedural activity of the interested party; iii) the conduct of judicial authorities, and iv) the impairment in the legal situation of the person involved in the process92. On this last item, to determine whether the time is reasonable, the impairment generated by the length of the proceeding in the legal situation of the person involved in such proceeding must be taken into account93, considering, among other elements, the subject matter of the controversy 94. In this regard, the Court has established that if the passage of time has a relevant impact on the legal status of the alleged victim, it will be necessary for the process to advance more diligently so that the case is resolved in a short time 95. 91. On the complexity of the case, the State indicated that the process of demarcation of indigenous lands is inherently complex, particularly due to the presence of non-indigenous settlers. The Commission considers that the issue of complexity requires a case by case analysis based in its circumstances. The Commission considers that establishing a priori that every process of demarcation and delimitation of land is complex could render illusory the right of indigenous peoples to a simple, prompt and effective resource to guarantee their right to collective property. The Commission stresses that this analysis is necessarily made on the basis of the specific facts of each case. 92. While as indicated by the State in the case Yakye Axa vs. Paraguay the Court indicated that it was a complex issue, it did so "based on the evidence presented in the chapter on Proven Facts" 96. However, it also notes that in the case of Kuna Indigenous People of Madungandí and Embera of Bayano and its Members vs. Panama, the Inter-American Court stated that, "with respect to the first element [complexity], the Court Inter-American Court of Human Rights, 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 Yakye Axa Indigenous Community vs. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, par. 143; and Commission, the rights of indigenous and tribal people to their ancestral lands and natural resources. STANDARDS AND JURISPRUDENCE INTER-AMERICAN SYSTEM OF HUMAN RIGHTS. OEA / Ser.L / V / II.Doc.56 / 09, December 30, 2009, par. 335. 92 IACHR, Report No. 111/10, Case 12,539, background, Sebastián Claus Furlan and Family, Argentina, October 21, 2010, par. 100; Court HR, Case of Valle Jaramillo et al v Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, par. 155. 93 Inter-American Court of Human Rights, Case of Valle Jaramillo et al v Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, par. 155; and Case Furlan and Family Vs. Argentina. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 31, 2012. Series C No. 246, par. 194. 94 Inter-American Court of Human Rights, Case Indigenous Community Xákmok Kásek. Vs. Paraguay. Merits, Reparations and Costs. Judgment of August 24, 2010, Series C No. 214, par. 136; and Case Furlan and Family Vs. Argentina Preliminary Objections, Merits, Reparations and Costs. Judgment of August 31, 2012. Series C No. 246, par. 194 95 Inter-American Court of Human Rights, Case of Valle Jaramillo et al v Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155; and Case Furlan and Family Vs. Argentina. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 31, 2012. Series C No. 246, par. 194 96 Inter-American Court of Human Rights, Case Indigenous Community Yakye Axa v Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, par. 87 91 22