45 lack of such consultation, in connection with the bauxite mining activities planned and commenced after 1990. c. Establishment of the Nature Reserves 133. The petitioners also claim that Suriname has violated their Article 21 property rights by establishing three Nature Reserves in part of what they claim as their ancestral territory: the Wia Wia, Galibi, and Wane Kreek Nature Reserves. Suriname argues that the Nature Reserves were established before its accession to the American Convention, so it cannot be held liable for acts or omissions related to their heir establishment. As explained above (see paragraph 76), the effects of establishing the Nature Reserves have continued after Suriname’s accession to the American Convention in 1987, and the Commission therefore has jurisdiction to determine potential human rights violations arising from their establishment. Suriname adds that the Reserves serve a legitimate public interest, namely environmental conservation, and do not interfere with indigenous peoples’ rights or the exercise of their traditional lifestyle. (i) The Rights of Indigenous Peoples and Environmental Conservation 134. The IACHR, the Inter-American Court and other international human rights bodies have expressed that environmental preservation is an important public imperative, but it must not be pursued at the cost of denying the rights of indigenous peoples. The Inter-American Commission, for instance, has explained that “in some cases the establishment of protected natural areas can be a form of limitation or deprivation of indigenous peoples’ right to the use and enjoyment of their lands and natural resources, derived from the State’s unilateral imposition of regulations, limitations, conditions and restrictions upon said use and enjoyment for reasons of public interest, in this case the conservation of nature.”252 The IACHR has also stated that when the establishment of protected areas affects indigenous territories, the special safeguards mentioned above in connection to development projects also apply.253 The Inter-American Court of Human Rights has also addressed the issue. In the case of Xákmok Kásek Community v. Paraguay, the Court analyzed, among other things, the establishment of a protected area in ancestral indigenous territory without consulting the indigenous community.254 The Court held that the establishment of the protected area without consulting the Xákmok Kásek community was one factor, among others, that contributed to the violation of their Article 21 property rights because it implied serious restrictions to the basic, traditional activities of the indigenous community, as well as the impossibility of expropriating those lands to restitute them to the Xákmok Kásek.255 135. 252 IACHR, Indigenous and Tribal Peoples’ Rights over Their Ancestral Lands and Natural Resources, Doc. OEA/Ser.L/V/II, Doc. 56/09, December 30, 2009, para. 222. 253 IACHR, Indigenous and Tribal Peoples’ Rights over Their Ancestral Lands and Natural Resources, Doc. OEA/Ser.L/V/II, Doc. 56/09, December 30, 2009, para. 222. 254 I/A Court H.R., Case of the Xákmok Kásek Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of August 24, 2010. Series C No. 214, paras. 80-82, 157-158, 169-170. 255 I/A Court H.R., Case of the Xákmok Kásek Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of August 24, 2010. Series C No. 214, paras. 169-70.