A/HRC/19/34 regional human rights mechanisms, namely the African, Inter-American and European systems. 33. These three regional human rights systems have addressed cases involving environmental issues and developed jurisprudence linking human rights and the environment. These bodies of law have identified how environmental issues relate to the rights protected under the relevant regional human rights instruments. In their jurisdictional exercise in response to individual and collective complaints, the regional systems have clarified the environmental dimensions of a number of protected rights, such as the right to life, the right to health, the right to private and family life, the right to property and the right to development. 34. The African Commission on Human and Peoples’ Rights has especially focused on the rights of indigenous and tribal peoples affected by environmental degradation resulting from extraction activities and their forceful removal from their traditional lands.1 The African Commission has detailed the importance of the right to a healthy environment recognized in the African Charter on Human and Peoples’ Rights, underscoring the role of carrying out environmental impact and independent scientific assessments prior to such activities. The African Commission has also given details on the right to benefit from natural resources and the right to development, articulating important standards regarding informed consultations and free and prior informed consent. 35. The Inter-American Court of Human Rights has contributed to establishing important standards of protection for indigenous and tribal peoples in relation to the environment. The Court has recognized that indigenous and tribal peoples have a right to property over the lands and territories that they have traditionally occupied. 2 To reach this conclusion, the Court interpreted the American Convention of Human Rights in the light of other relevant international human rights treaties. For example, the right to the ancestral lands, territories and natural resources has been supported by the right to self-determination recognized in both the International Covenant on Civil and Political Rights and the International Covenant on Economic Social and Cultural Rights, and by the standards set by International Labour Organization Convention No. 169 (1989) concerning Indigenous and Tribal Peoples in Independent Countries. 36. The Inter-American Court has also developed a system of safeguards that apply where the State is considering approving development or investment projects that may impair the enjoyment of the rights of indigenous peoples. In such cases, in order to safeguard the survival of the peoples concerned, the State is required to: conduct independent environmental and social assessments; ensure adequate benefit-sharing schemes; and conduct effective and culturally appropriate consultations, as well as obtaining free and prior informed consent in certain cases. These safeguards doubtless contribute to clarifying the linkage between human rights and the environment. At the same time, further guidance is needed to implement these safeguards. 37. The European Court of Human Rights has also contributed to elucidating the human rights and environmental relationship, particularly in cases involving environmental 1 2 8 See, for example, SERAC and CESR v. Nigeria, communication No. 155/96, 27 May 2002; Centre for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v. Kenya, communication No. 276/2003, 4 February 2010. See, for example, Moiwana Community v. Suriname, 15 June 2005; Claude-Reyes, et al. v. Chile, 19 September 2006; Sawhoyamaxa Indigenous Community v. Paraguay, 29 March 2006.