A/HRC/28/61 they have traditionally occupied.10 At the national level, a number of courts have also issued decisions clarifying the rights of tribal peoples. For example, the Supreme Court of Mexico decided in 2013 that the Government had not adequately consulted with the Yaqui tribe with respect to construction of an aqueduct, and that the authorization of the project must wait until after consultation takes place. Also in 2013, the Supreme Court of India requested the state of Odisha to consult with tribal assemblies in accordance with the Indian Forest Rights Act, which recognizes a broad range of customary forest rights of tribal peoples and traditional forest dwellers, in connection with an application to clear a forest area to mine for bauxite. After the tribal assemblies rejected the proposal, the Minister for the Environment and Forests turned down the application. 99. Another type of good practice is legislative action that recognizes the legal rights of indigenous representatives in natural resources. After many years of legal uncertainty about the management and use of natural resources in the county of Finnmark, the ancestral land and home of the Sami people, in 2005 the Norwegian Parliament adopted the Finnmark Act through a process of consultation with the Sami Parliament. The Act transferred ownership of the land to a new entity governed by a board half of whose members are appointed by the Sami Parliament, and created a special court to decide disputes concerning land rights. 100. Indigenous organizations have engaged in good practices to protect indigenous rights and promote the sustainable use of resources, including in connection with protected areas. For example, the Commission on Environmental, Economic and Social Policy of the International Union for Conservation of Nature, the Forest Peoples Programme and other indigenous peoples’ organizations help local communities to assess and redress situations where they believe that they have been negatively affected by the designation or management of a protected area. 101. An example of a good practice in the management of protected areas is provided by the Sarstoon Temash Institute for Indigenous Management (SATIIM), a community-based indigenous environmental organization that co-manages, together with the Forest Department of Belize, the Sarstoon Temash National Park on lands traditionally used by indigenous Garifuna and Maya communities. With the assistance of SATIIM, in 2008 the communities of Conejo and Santa Teresa prepared forest sustainable management plans, which identify the timber and other resources that each community can harvest based on ecological surveys, and which include mitigation measures for any possible adverse effects on the environment. 102. Another good practice is raising the awareness of indigenous communities of their rights. Natural Justice, a civil society organization based in South Africa, assists local communities and indigenous groups to prepare “community protocols” that set out their understanding of their customary, national and international rights relating to their land and natural resources. Each community develops its own protocols in a format that is most meaningful to that community. Protocols can be written documents, and can also take the form of visual art, theatre or music. IV. Conclusions and recommendations 103. The practices described in this report demonstrate concrete, innovative ways that the use of human rights obligations can help to make environmental policies fairer, more effective and more respectful of the concerns of those most affected by 10 20 See, for example, Mayagna (Sumo) Agwas Tingni Community v. Nicaragua, 31 August 2001, and Saramaka People v. Suriname, 28 November 2007.