27 using and enjoying property, or of seeking equal access to judicial protection against alleged violations of their communal rights.155 85. The Court went on to explain that recognition of collective juridical personality is a way to ensure that collective property rights are respected. In the Court’s words, “the right to have their juridical personality recognized by the State is one of the special measures owed to indigenous and tribal groups in order to ensure that they are able to use and enjoy their territory in accordance with their own traditions.”156 Failure to recognize their juridical personality places the indigenous community in a vulnerable situation because (i) individual property rights may trump collective rights over communal property, and (ii) indigenous people may not seek, as a collective juridical personality, judicial protection against violations of their rights.157 This situation of vulnerability exists vis-à-vis the State as well as private third parties. The Court concluded that the State must establish, in consultation with the relevant indigenous people and fully respecting their traditions and customs, “the judicial and administrative conditions necessary to ensure the recognition of their juridical personality, with the aim of guaranteeing them the use and enjoyment of their territory in accordance with their communal property system, as well as the rights to access to justice and equality before the law.”158 86. In this case, the petitioners have proven, and the State does not dispute, that Surinamese law does not recognize the legal personality of indigenous people (see paragraph 39). As with the Saramaka People, Surinamese law does not recognize the Kaliña and Lokono Peoples’ right to juridical personality protected by Article 3 of the American Convention. Although Suriname states that it is in the process of recognizing indigenous rights, and that it acknowledges the precedential effect of the Saramaka judgment, it has provided no concrete evidence in this case to demonstrate that it has enacted laws, regulations or other provisions to give effect to the Saramaka decision relating to Article 3. In this case, Suriname has also not demonstrated that it has adopted measures to recognize the legal personality of the Kaliña and Lokono indigenous peoples. For the foregoing reasons, the IACHR finds that Suriname has violated the right of the Kaliña and Lokono Peoples to the recognition of their juridical personality pursuant to Article 3 of the American Convention, in connection with Articles 1.1 and 2 of the same instrument. 87. D. The Right to Property 88. Article 21 of the American Convention provides: 1. Everyone has the right to the use and enjoyment of his property. The law may subordinate such use and enjoyment to the interest of society. 155 I/A Court H.R., Saramaka People. v. Suriname Case. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007 Series C No. 172, para. 167. 156 I/A Court H.R., Saramaka People. v. Suriname Case. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007 Series C No. 172, para. 172. 157 I/A Court H.R., Saramaka People. v. Suriname Case. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007 Series C No. 172, para. 173. 158 I/A Court H.R., Saramaka People. v. Suriname Case. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007 Series C No. 172, para. 174.