A/HRC/4/37 page 12 families have been physically attacked, kidnapped, tortured and even killed. These violations have allegedly been perpetrated both by the State or its agencies, and non-State entities. 37. The following seven subsections deal with the activities of defenders within specific areas of ESCR. In each section, the activities of defenders within this specific area is analysed through cases of violations against the rights of defenders in this area. These cases are based on communications sent to Governments by the Special Representative since the establishment of the mandate, and the geographical focus of violations is identified only with reference to these communications. The next section provides a general overview of the challenges faced by defenders working across the spectrum of ESCR and the violations of the rights recognized by the Declaration on Human Rights Defenders. 1. Land rights, natural resources and environmental issues 38. On the issue of land rights and national resources, article 1 (2) of ICESCR stipulates that “All peoples may, for their own ends, freely dispose of their natural wealth and resources without prejudice to any obligations arising out of international economic cooperation, based upon the principle of mutual benefit, and international law. In no case may a people be deprived of its own means of subsistence.” This comes in addition to the previously mentioned article 17 of the UDHR on the right to property. Section IV of the Millennium Declaration is devoted to “Protecting our common environment” and the Member States reaffirm their “support for the principles of sustainable development […]” and resolve to “adopt in all our environmental actions a new ethic of conservation and stewardship […]”. 39. Since the establishment of the mandate, the Special Representative has sent 81 communications dealing with violations of the rights of defenders working on issues of land rights, natural resources such as oil, gas, forests and water, environmental issues such as pollution and waste-dumping and related issues. 40. Defenders working on land rights, natural resources or environmental issues seem to be particularly vulnerable to attacks and violations of their rights under the Declaration on Human Rights Defenders in countries of Latin America and in parts of Asia. The Special Representative has sent a high number of communications to the Governments of Brazil (12 cases) and Guatemala (9 cases). Forty-five communications were sent to Governments in South America and 23 cases were sent to Governments in Asia. 41. Land rights and natural resources is an area where a large part of the defenders come from indigenous populations and minority groups. These populations are often working to secure their right to utilize and live on the land they consider to be theirs. The Special Representative provides more information on the challenges they face in chapter III, section A, below, dealing with indigenous peoples and minority groups. 42. Women as a group are particularly vulnerable concerning issues of land rights and, in particular, inheritance rights. Defenders are working against discriminatory inheritance laws and customary practices that deprive women of their equal rights to own, inherit and control property, including land and housing. The Special Representative provides more information on the challenges they face in chapter III, section C, below, on women human rights defenders.